Clinic patient privacy statement
The Shirebrook and Clowne Chiropractic Clinic is aware of its obligations under the
General Data Protection Regulation (GDPR) and is committed to protecting the privacy and
security of your personal information. This privacy notice describes, in line with GDPR, how
we collect and use personal data about you during and after your time as a patient of this
clinic. It also sets out how we use that information, how long we keep it for and other
relevant information about your data.
This notice applies to current and former patients.
Data controller details
The Clinic is a data controller, meaning that it determines the processes to be used when
using your personal data. Our contact details are as follows:
Shirebrook Chiropractic
5 Shirebrook Business Centre
Border road Shirebrook
Notts NG20 8TB
01623 742028
gdpr@goodwinclinics.com
Data protection principles
In relation to your personal data, we will comply with data protection law. This says that the
personal information we hold about you must be:
- processed fairly, lawfully and in a clear, transparent way
- collected only for valid reasons that we find proper for the course of your time as a patient and not used in any way that is incompatible with those purposes
- only used in the way that we have told you about
- accurate and up to date
- kept only as long as is necessary for the purposes we outline
- process it in a way that ensures it will not be used for anything that you are not aware of or have consented to (as appropriate), lost or destroyed
- kept securely
Types of information we hold about you
Personal data or information means any information about an individual from which that
person can be identified. It does not include data where the identity has been removed.
We hold many types of data about you, including:
- your personal details including your name, address, date of birth, email address,
phone numbers
- banking or financial information
- gender
- marital status
- next of kin and their contact numbers
- personal medical or health information, including past medical history
- information concerning examination and treatment at your first and subsequent
visits
- letters of referral to or from the clinic regarding your treatment with us.
Special categories of data
There are "special categories" of more sensitive personal data which require a higher level
of protection, such as information about a person's health or sexual orientation.
- Health
- sex life
- sexual orientation
- race
- ethnic origin
- religion
- genetic and biometric data
We will use your special category data:
- to ensure the care you receive at the clinic is appropriate to your condition
- to determine reasonable adjustments that should be made for access to the clinic or
to treatment
We must process special categories of data in accordance with more stringent guidelines.
We will process special categories of data when the following applies:
- you have given explicit consent to the processing (on our consent form)
- we must process the data in order to carry out our legal obligations
- we must process data for reasons of substantial public interest
Less commonly, we may process this type of information where it is needed in relation to
legal claims or where it is needed to protect your interests (or someone else's interests) and
you are not capable of giving your consent, or where you have already made the
information public.
As with all cases of seeking consent from you, you will have full control over your decision to
give or withhold consent and there will be no consequences where consent is withheld.
Consent, once given, may be withdrawn at any time. There will be no consequences where
consent is withdrawn.
How we collect your data
We collect data about you in a variety of ways and this will usually start when you make an
enquiry to the clinic and continue when you attend your first and subsequent appointments.
At this clinic, we keep paper and electronic records . Information we write down on paper
may be transferred to our electronic system. We may receive information about you from
your GP or other health care provider regarding your referral or, with your permission,
additional information that will help us continue with your treatment. We may also hold the
results of tests that you have undertaken and that are relevant to your treatment with the
clinic.
Personal data is kept in the clinic. Paper notes are kept in a locked cabinet , in a room that is
locked when not in use and in a building with a security alarm. Archived paper notes are
kept in a locked cabinet at an alarmed building of head office. Electronic data is backed up
online with password protected security by GDPR compliant professionals and backed up in
encrypted , password protected usb memory.
Why we process your data (How we will use information about you)
The law on data protection allows us to process your data for certain reasons only, these are
classified as legitimate interests. Most commonly, we will use your personal information in
the following circumstances:
- in order for us to carry out our contract with you (your requesting treatment and
our agreement to provide it constitutes a contract) which will include confirming
appointments, informing you of changes to appointments or clinic arrangements,
changes to facilities or services at the clinic.
- in order to provide you with the best possible treatment by recording health and
treatment information which would be in your best interest.
- in order to carry out legally required duties such as those required by me by my
government appointed regulator
- where it is necessary for our legitimate interests and your interests and
fundamental rights do not override those interests
We may use your personal information in these rare situations:
- where we need to protect your or someone else’s interests
- where it is needed in the public interest or for official purposes
Your data may also be used for the purposes of Covid-19 considerations and the NHS Test and Trace Service
Situations in which we will use your personal information
We need all the categories of information to primarily allow us to perform our contract of
treatment with you and to enable us to comply with legal obligations.
If you do not provide your data to us
One of the reasons for processing your data is to allow us to carry out our duties in line with
your contract of care with us. If you do not provide us with the data needed to do this, we
will be unable to perform that care to ensure your best interests are being maintained. We
may also be prevented from continuing with your treatment with us due to our legal
obligations.
Change of purpose
We will only use your personal information for the purposes for which we collected it unless
we reasonably consider that we need to use it for another reason and that reason is
compatible with the original purpose. If we need to use your personal information
for an unrelated purpose, we will notify you and we will explain the legal basis which
allows us to do so.
Please note that we may process your personal information without your knowledge or
consent, in compliance with the above rules, where this is required or permitted by
law.
Automated decision making
No decision will be made about you solely on the basis of automated decision making
(where a decision is taken about you using an electronic system without human
involvement) which has a significant impact on you.
Sharing your data
Your data will be shared with colleagues within the Clinic but only where it is necessary for
them to undertake their duties. This includes, for example, other chiropractors working for,
at or on behalf of the clinic and reception staff.
We may share your data with third parties in order to facilitate a referral to another
healthcare practitioner, investigation or to keep your GP informed about your progress with
treatment. your insurance company requiring information for payment, your employer in
case of sick note requests or special reports
We may also share your data with third parties as part of a Clinic sale or restructure, or for
other reasons to comply with a legal obligation upon us. We would always keep you
informed of these situations.
Transferring information outside the EU
We may share your data with bodies outside of the European Economic Area should the
need arise. It is likely that this situation would be to share information regarding your
treatment or ongoing care with healthcare practitioners in these countries in accordance
with your wishes. However, we would not transfer your data unless we were assured that
the country in question had data security and protection laws of equivalence to those of the
UK and the European Economic Area.
We have put the following measures in place to
ensure that your data is transferred securely and that the bodies who receive the data that
process it in a way required by EU and UK data protection laws: We have a contract with
these companies that ensure privacy standards . These countries are Australia and the
reason for sharing with these countries is that we use their cloud based software to manage
patients notes, xlinic diary and patient reminders and emails
Data Security - Protecting your data
We have put in place measures to protect the security of your information against
accidental loss or disclosure, alteration, unauthorised access, destruction or abuse. We have
implemented processes to guard against such. In addition, we limit access to your personal
information to those employees, agents, contractors and other third parties who have a
business need to know. They will only process your personal information on our instructions
and they are subject to a duty of confidentiality. Details of our systems can be detailed by
request from the Data Controller or practice manager but include, firewalls, password
requirements, password changes, encryption , back ups, key locked cabinets, antivirus,
blank computers, safes and alarmed buildings.
Where we share your data with third parties, we provide written instructions to them to
ensure that your data are held securely and in line with GDPR requirements. Third parties
must implement appropriate technical and organisational measures to ensure the security
of your data.
How long we keep your data for
In line with data protection principles, we only keep your data for as long as we need it for,
which will be at least for the duration of your being a patient with us and we are
legally required, by the Chiropractic regulator, to keep this data for eight years after
your time as a patient has ended. To determine the any appropriate retention period
for personal data beyond eight years we consider the amount, nature, and sensitivity
of the personal data, the potential risk of harm from unauthorised use or disclosure
of your personal data, the purposes for which we process your personal data and
whether we can achieve those purposes through other means and the applicable
legal requirements.
Once we no longer have a lawful use for retaining your information, we will dispose of it in a
secure manner than maintains data security.
In some circumstances we may anonymise your personal information so that it can no
longer be associated with you, in which case we may use such information without
further notice to you.
Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current.
Please keep us informed if your personal information changes during your time as a
patient with us.
Your rights in relation to your data
The law on data protection gives you certain rights in relation to the data we hold on you.
- the right of access. You have the right to access the data that we hold on you. To do
so, you should make a subject access request. Find out how to do this from
- the right for any inaccuracies to be corrected. If any data that we hold about you is
incomplete or inaccurate, you can require us to correct it.
- the right to be informed. This means that we must tell you how we use your data,
and this is the purpose of this privacy notice. We also must inform you of any
changes to how we use your data.
- the right to have information deleted. If you would like us to stop processing your
data, you have the right to ask us to delete it from our systems where you believe
there is no reason for us to continue processing it.
- the right to restrict the processing of the data. For example, if you believe the data
we hold is incorrect, we will stop processing the data (whilst still holding it) until we
have ensured that the data is correct.
- the right to portability. You may request transfer the data that we hold on you for
your own purposes.
If you want to access your data, review, verify or correct your data, request we erase your
personal information, object to the processing of your personal data, or request that
we transfer a copy of your personal information to another party, please contact the
Data controller listed above in writing or in person.
Fees
You will not have to pay a fee to access your personal information (or to exercise any of the
other rights). However, we may charge a reasonable fee for a second or subsequent
copy of information or if your request for access is clearly unfounded or excessive.
Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and
ensure your right to access the information (or to exercise any of your other rights).
This is a security measure to ensure that personal information is not disclosed to any
person who has no right to receive it.
Right to withdraw consent
Where you have provided consent to the collection, processing and transfer of your data,
you have the right to withdraw that consent at any time. There will be no consequences for
withdrawing your consent. However, in some cases, we may continue to use the data where
so permitted by having a legitimate legal reason for doing so.
To withdraw consent, contact the Data Controller above
Making a complaint
If you have any questions about this Privacy Notice or how we handle your information, please contact the Clinic’s Data Protection Controller. They can be contacted on details above or 01623 742028.
You have the right to make a complaint at any time to the supervisory authority in the UK
for data protection matters, the Information Commissioner’s Office (ICO).
