0203 617 6320

Privacy Policy

    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 as well as our professional guidelines and requirements.

    The data controller is Jon Rees The information governance lead is Jon Rees, who is also the Data Protection Officer.

    This Privacy Notice is available on the practice website, by email if you contact info@drjonrees.com

    You will be asked to provide personal information when joining the practice. The purpose of processing your personal data is to provide you with optimum care and prevention.

    The categories and examples of data we process are:

    • Personal data for the provision of health care
    • Personal data for the purposes of providing treatment plans, recall appointments, reminders or estimates
    • Personal data such as details of family members for the provision of health care to children or for emergency contact details
    • Personal data for the purposes of employed and self-employed team members employment and engagement respectively
    • Personal data for the purposes of email to inform you of important announcements or about new treatments or services
    • Personal data – IP addresses so that we can understand our patients better and inform our marketing approach as well as improve the web site experience
    • Special category data including health records for the purposes of the delivery of health care and meeting our legal obligations
    • Special category data including health records
    • Special category data to meet the requirements of the Equality Act 2010
    • Special category data details of criminal record checks for employees and contracted team members

    We minimise the data that we keep, and do not keep it for longer than necessary.

    We never pass your personal details to a 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. Your data will be shared with the NHS in England, Scotland and Wales or the HSC in Northern Ireland if you are having NHS or HSC treatment.

    Personal data is stored in the EU whether in digital or hard copy format

    • 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
    • Personal data is stored in the US in digital format when suitable safeguards have been put in place to allow personal data to be transferred out of the EU (invisalign)

    For full details or where your data is stored, please ask to see Information Governance Procedures (M 217C).

    We have established the following lawful bases for processing your data:

    Our lawful bases for processing personal data:

    • The legitimate interests of the practice
    • Processing is necessary for the performance of a contract with the data subject or to take steps to enter into a contract
    • Consent of the data subject
    • To comply with our legal obligations

    Our lawful bases for processing special category data:

    • Processing is necessary for health care purposes
    • Processing necessary for identifying or keeping under review the existence or absence of equality of opportunity or treatment between groups of people with the view to enabling such equality to be promoted or maintained
    • We obtain consent of the data subject to process criminal record checks

    The reasons we process the data include:

    • To maintain your contemporaneous clinical records
    • To provide you with treatment, prevention and advice
    • To carry out financial transactions with you
    • To send your personal data to any authority as required by law
    • To communicate with you as and when required including appointment reminders, treatment plans, estimates and other communications about your treatment or the practice
    • To communicate with your next of kin in an emergency
    • If a parent or carer to communicate with you about the person you parent or care for
    • To refer you to other dentists or doctors and health professionals as required
    • To obtain criminal record disclosures for team members
    • For debt recovery
    • To continually improve the care and service you receive from us

    The personal data we process includes:

    Your name, address, gender, date of birth, medical history, family medical history, family contact details, marital status financial details for processing payment, your doctor’s details and details of treatment at the practice. We may process more sensitive special category data including ethnicity, race, religion, or sexual orientation so that we can meet our obligations under the Equality Act 2010, or for example to modify treatment to suit your religion and to meet NHS or HSC obligations.

    The retention period for special data in patient records is a minimum of 10 years and may be longer for complex records or 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 retention periods are available in the Record Retention (M 215) procedure available from the practice.

    We obtain your personal details when you enquire about our care and service, when you join the practice, when you subscribe to our newsletter or register online, when you complete a registration or medical history form and when another practitioner refers you for treatment at our practice. Occasionally patients are referred to us from other official sources such as NHS clinics or hospitals.

    You have the following personal data rights:

    • The right to be informed about the collection and use of your personal data
    • The right of access –  to have a copy of the data we hold about you. Generally, we will not charge for this service
    • The right to rectification  – to correct the data we have if it is inaccurate or incomplete
    • The right to deletion of your personal data (clinical records must be retained for a certain time period)
    • The right to restrict processing of your personal data
    • The right to data portability – to have your data transferred to someone else
    • The right to object to the processing of your personal data
    • Rights in relation to automated decision making and profiling

    Further details of these rights can be seen in our Information Governance Procedures (M 217C) 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

    We have carried out a Privacy Impact Assessment in Sensitive Information Map, PIA and Risk Assessment (M 217Q) and you can request a copy from the details below. The details of how we ensure security of personal data is in our Security Risk Assessment (M 217M) and Information Governance Procedures (M 217C).

    Comments, suggestions and complaints

    Please contact the IG Lead at the practice for a comment, suggestion or a complaint about your data processing at info@drjonrees.com. 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). Their telephone number is 0303 123 1113, you can also chat online with an advisor. The ICO can investigate your claim and take action against anyone who’s misused personal data. You can also visit their website for information on how to make a data protection complaint.

     

    Rights What does this
    mean?
    1. Rights to be informed You have the right to be provided with clear, transparent and easily
    understandable information about how we use your personal data and your
    rights. This is why we are providing you with the information in this
    Privacy Policy.
    2. Right of access You have the right to obtain access to your personal data (if we are
    processing it) and certain other information (similar to that provided in
    this Privacy Policy). This is so you are aware and can check that we are
    using your personal data in accordance with data protection law.
    3. Right to rectification You are entitled to have your personal data corrected if it is inaccurate or
    incomplete.
    4. Right to erasure This is also known as ‘the right to be forgotten’ and, in simple terms,
    enable you to request the deletion or removal of your personal data where
    there is no compelling reason for us to keep using it. This is not a general
    right to erasure; there are exceptions.
    5. Right to restrict processing You have the right to ‘block’ or supress further use of your personal data
    in certain circumstances. When processing is restricted, we can still store
    your personal data, but may not use it further.
    6. Right of data portability You have the right to obtain and reuse your personal data in a structured,
    commonly used and machine-readable format in certain circumstances. In
    addition, where certain conditions apply, you have the right to have such
    information transferred directly to a third party.
    7. Right to object to processing You have the right to object to us processing your personal data for our
    legitimate business interests or for direct marketing purposes (including in
    each case any related profiling).
    8. Right to withdraw consent to processing If you have given your consent to us to process your personal data for a
    particular purpose (for example, direct marketing), you have the right to
    withdraw your consent at any time (although if you do so, it does not mean
    that any processing of your personal data up to that point is unlawful).
    9. Right to make a complaint to the data protection
    authorities    		 You have the right to make a complaint to the Information Commissioner’s
    Office (ICO) if you are unhappy with how we have handled your personal data
    or believe our processing of your personal data does not comply with data
    protection law.

    How to contact us

    If you would like to exercise your data protection rights or if you are unhappy with how we have handled your personal data, please feel free to contact us by using the details set out on our Site.

    If you’re not satisfied with our response to any enquiries or complaint or believe our processing of your personal data does not comply with data protection law, you can make a complaint to the Information Commissioner’s Office (ICO) by:

    • writing to: Information Commissioner’s Officer, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF;
    • calling: 0303 123 1113; or
    • submitting a message through the ICO’s website at: ico.org.uk

    Links to other websites

    Our website may contain hyperlinks to websites owned and operated by third parties. This Privacy Policy does not apply to those other websites. We encourage you to read the privacy statements on the other websites you visit, as they will govern the use of any personal data you provide when visiting those websites. We do not accept any responsibility or liability for the privacy practices of such third party websites and your use of such websites is at your own risk.

    Changes to this Privacy Policy

    This Privacy Policy may be updated from time to time, so you may want to check it each time you provide personal data to us.