GENERAL DATA PROTECTION REGULATION (GDPR) 2018 PRIVACY NOTICE – FORM GDPR 2018_001
This document refers to personal data, which is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain.
The General Data Protection Regulation (GDPR) which is EU wide and far more extensive than its predecessor the Data Protection Act, along with the Privacy and Electronic Communications Regulations (PECR), seek to protect and enhance the rights of EU data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU and its storage within the EEA.
1 – AVIQI LIMITED, trading as The Park Lane Practice based at 70d Park Lane, Chippenham, Wiltshire, SN15 1LW, which hereafter for the purposes of this Privacy Notice will be referred to as the Practice, is pleased to provide the following information:
2 – Who we are
The Practice is a leading provider of affordable integrated private healthcare and human development. Our team of independent professionals work together to provide clients with the best combination of multi-speciality healthcare and personal development consultations. We aim to continually improve and expand our innovative, individualised, and systematic approach. Our consultants may include but are not limited to, Osteopaths, Acupuncturists, Chiropractors, Physiotherapists, Doctors, Nutritionists, Naturopaths, Colonic Hydrotherapists, Podiatrists & Chiropodists, Counsellors & Psychotherapists, Alexander Technique Teachers, Health Coaches, Medical Herbalists, NLP Practitioners, Massage Therapists, Hypnotherapists, Yoga Teachers, Pilates Teachers, Personal Development Coaches, Meditation Trainers, Personal Trainers, Sports, Fitness & Performance Coaches.
3 – Personal Data:
- a) For the purposes of providing consultations, the Practice may require detailed personal information and more sensitive information known as special category data e.g. information relating to your health, genetics, race, ethnic origin, religion, sex life, or sexual orientation. We will only collect what is relevant and necessary for your consultations. When you visit our practice, we will make notes which may include details concerning your medication, treatments and other issues affecting your health, personal development, and lifestyle. This data is always held securely, is not shared with anyone not involved in your consultations, although for data storage and processing purposes it may be handled by pre-vetted staff who have all signed a staff GDPR agreement, detailing our professional integrity and confidentiality standards. To be able to process your personal data it is a condition of any consultation that you give your explicit consent to allow the Practice to document and process your personal including special category data. Contact details provided by you such as telephone numbers, email addresses, internet and application profiles, and postal addresses may be used to arrange and remind you of future appointments and provide reports or other information concerning your consultations.
- b) To provide health and human development information for support, guidance, education and marketing purposes, the Practice may also use the contact details provided by you to respond to your enquiries, including making telephone contact, and emailing information to you which the practice believes may be of interest to you.
- c) In making initial contact with the Practice you consent to the Practice maintaining communications with you for the purposes of health and human development education, support, guidance, and marketing until you opt out (which you can do at any time or the Practice no longer chooses to make contact with you) The Practice may occasionally also act on behalf of its clients in the capacity of data processor, when we may promote other products, services and professionals who may or may not be based at our premises, and who may or may not be employed by us. The Practice does not sell your data and you can ask to be removed from our communication database by emailing or phoning the Practice using the contact details provided at the end of this Privacy Notice, or be removed from a particular system of communication we are using by following any opt-out links in our communications from that particular system.
- d) Some basic personal data and special category data may be collected about you from the marketing forms and surveys you complete, from records of our correspondence and phone calls and details of your visits to our practice, events or website, including but not limited to, personally identifying information like Internet Protocol (IP) addresses.
- f) The Practice will use closed-circuit television video recording to monitor communal and staff areas inside and outside the practice building for many purposes including: keeping clients and staff safe and secure by attempting to prevent crime, to control and provide access to areas of the building, to encourage excellent client and staff conduct, to monitor and improve staff productivity, and ensure staff comply correctly with the Practice’s policies, procedures, agreements and regulatory requirements, such as data security, and health and safety.
- g) We aim to continually improve and expand our services and products. For the purpose of improving our service to you, the Practice may analyse personal data including special category data, and use it to make personalised recommendations of products, services or consultants which we determine may be beneficial for you. We will also analyse and use all data to refine our innovative, individualised, and systematic approach. This will include the outcome data regarding the results achieved from attending consultations and using products and services. We will then use this data to adjust our recommendations.
- h) The Practice will only collect the information needed so that we can provide you with the services you require, the Practice does not sell your data.
4 – Legal basis for processing any personal data
To meet our contractual obligations obtained from explicit Client Consent and legitimate interest to respond to enquiries concerning the products and services the Practice and associated third parties provide.
5 – Legitimate interests pursued by The Practice
To promote products and services to individuals who may have an interest in improving their health and personal development as human beings.
6 – Consent
Through agreeing to this Privacy Notice you are consenting to the Practice processing your personal data for the purposes outlined. You can withdraw consent at any time by using the postal, email address or telephone number provided at the end of this Privacy Notice.
7 – Disclosure
The Practice will keep your personal information safe and secure, only staff engaged in facilitating the provision of your consultations will access your records. Our administration team will have access to your contact details so that they can make appointments and manage your account. The Practice will not disclose your Personal Information unless compelled to, in order to meet legal obligations, regulations or valid governmental requests. The practice may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of its staff.
8 – Retention Policy
The Practice will process personal data during the duration of any consultation and will continue to store only the personal data needed for eight years after the contract has expired to meet any legal obligations. After eight years all personal data may be deleted, unless basic information needs to be retained by us to meet our future obligations to you, such as erasure details. Records concerning minors will be retained at least until the child has reached the age of 25.
9 – Data storage
Personal Data including Special Category Data is stored electronically within GDPR compliant third-party processors and secured hardware devices. Data recorded on paper is stored in locked storage.
10 – Your rights as a data subject
At any point whilst the Practice is in possession of, or processing your personal data, all data subjects have the following rights:
- Right of access – you have the right to request a copy of the information that we hold about you.
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
- Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.
- Right of portability – you have the right to have the data we hold about you transferred to another organisation.
- Right to object – you have the right to object to certain types of processing such as direct marketing.
- Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.
In the event that the Practice refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge. At your request, the Practice can confirm what information it holds about you and how it is processed.
11 – You can request the following information:
- Identity and the contact details of the person or organisation (the Practice) that has determined how and why to process your data.
- Contact details of the data protection officer, where applicable.
- The purpose of the processing as well as the legal basis for processing.
- If the processing is based on the legitimate interests of the Practice and information about these interests.
- The categories of personal data collected, stored and processed.
- Recipient(s) or categories of recipients that the data is/will be disclosed to.
- How long the data will be stored.
- Details of your rights to correct, erasure, restrict or object to such processing.
- Information about your right to withdraw consent at any time.
- How to lodge a complaint with the supervisory authority (ICO).
- Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
- The source of personal data if it wasn’t collected directly from you.
Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
12 – To access the personal data held, identification will be required
The Practice will accept the following forms of identification (ID) when information on your personal data is requested: a copy of your driving licence, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If the Practice is dissatisfied with the quality of the ID, further information may be sought before personal data can be released. All requests should be made to email@example.com or by phoning +44 (0) 1249 652169 or writing to us at the address further below.
13 – Complaints
In the event that you wish to make a complaint about how your personal data is being processed by the Practice you have the right to complain to us. If you do not get a response within 30 days, you can complain to the ICO.
The details for each of these contacts are:
Telephone +44 (0) 1249 652169 or email: firstname.lastname@example.org
Wycliffe House, Water Lane, Wilmslow, SK9 5AF Telephone +44 (0) 303 123 1113 or email: https://ico.org.uk/global/contact-us/email/
The Institute of Osteopathy GDPR 2018 Privacy Notice