The practice aims to meet the requirements of the Data Protection Act 2018, the General Data Protection Regulation (GDPR), the guidelines on the Information Commissioner’s website ICO as well as our professional guidelines and requirements.
The data controller is Rosa Cicero.
This privacy Notice is available if you contact firstname.lastname@example.org or by calling the practice on 0207 060 0086.
The categories of data we process are:
- Personal Data for the purposes of staff and self-employed team member management
- Personal data for the purposes of direct mail, email, text or marketing
- Special category data including health records for the purposes of the delivery of healthcare
- Special category date including the health records and details of the criminal record checks for managing employees and contracted team member
We never pass your personal details to the third party unless we have a contract for them to process data on our behalf and will otherwise keep it confidential. If we intend to refer a patient to another practitioner or to secondary care such as a hospital we will gain the individual’s permission before the referral is made and the personal data is shared.
- [Personal Data Is stored in the [EU] whether in digital or hard copy format]
- [Personal data is stored in the US in digital format when the data storage company is certified with the EU-US Privacy Shield]
- Personal data is obtained when a patient joins the practice, when a patient is referred to the practice and [when a patient subscribes to an email list]
The lawful basis for processing special category data such as patients’ and employees’ health data are:
- Processing is necessary for the purposes of preventative or occupational medicine, for assessing the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or management of health or social care systems and services based on Union or Member State Law or a contract with a health professional.
The lawful basis for processing personal data such as name, address, email or phone number is:
- Consent of the data subject
- Processing is necessary for the performance of a contract with the data subject to or to take steps to enter into a contract
The retention period for special data in patient records is a minimum of 10 years and may be longer for complex records to meet our legal requirements. The retention period for staff records is 6 years. The retention periods for other personal data is 2 years after it was last processed. Details of other retention periods are available in the Record Retention procedure available from the practice.
You have the following personal data rights:
- The right to be informed
- The right of access
- The right to rectification
- The right to erasure (clinical records must be retained for a certain time period)
- The right to restrict processing
- The right to data portability
- The right to object
Further details of these rights can be seen in our Information Governance Procedures or at the Information Commissioner’s website. Here are some practical examples of your rights:
- If you are a patient of the practice you have the right to withdraw consent for important notifications, newsletters, surveys or marketing. You can inform us to correct errors in your personal details or withdraw consent from communication methods such as telephone, email or text. You have the right to obtain a free copy of your patient records within one month.
- If you are not a patient of the practice you have the right to withdraw consent for processing personal data, to have a free copy of it within one month, to correct errors in it or to ask us to delete it. You can also withdraw consent from communication methods such as telephone, email or text.
Comments, suggestions and complaints
Please contact Rosa Cicero at the practice for a comment, suggestion or a complaint about your data processing at email@example.com or by writing to or visiting the practice at 86 Harley Street, London, W1G 7HP. We take complaints very seriously.
If you are unhappy with our response or if you need any advice you should contact the Information Commissioner’s Office (ICO). Our membership number is ZA342297. Their telephone number is 0303 123 1113. You can also visit their website for information of how to make a data protection complaint.
To be reviewed: 23.05.19
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Last reviewed 23.05.18
Next review 23.11.18