When you supply your personal information to this clinic it is stored and processed for 4 reasons:
1. We need to collect personal information about your health in order to provide you with the best possible treatment. Your requesting treatment and our agreement to provide that care constitutes a contract. You can, of course, refuse to provide the information, but if you were to do that, we would not be able to provide treatment.
2. We have a “Legitimate Interest” in collecting that information, because without it we could not do our job effectively and safely.
3. We also think that it is important that we can contact you in order to confirm your appointments with us or to update you on matters related to your medical care.
4. Provided we have your consent, we may occasionally send you general health information in the form of articles, advice or newsletters. You may withdraw this consent at any time – just let us know by any convenient method.
We have a legal obligation to retain your records for 8 years after your most recent appointment (or age 25, if this is longer), but after this period you can ask us to delete your records if you wish. Otherwise, we will retain your records indefinitely in order that we can provide you with the best possible care should you need to see us at some future date.
Your records are stored:-
I) on paper, in locked filing cabinets,
II) in the future they may be stored electronically (“in the cloud”). This will be using a specialist medical records service. This provider has given us their assurances that they are fully compliant with the General Data Protection Regulations. Access to this data will be password protected, and the passwords will be changed regularly.
III) on our office computers. These are password-protected, backed up regularly.
We will never share your data with anyone who does not need access without your written consent. Only the following people/agencies will have routine access to your data:
• The medical records service who store and process our files
• Your practitioner(s) in order that they can provide you with treatment
• Reception staff, because they organise our practitioners’ diaries, and coordinate appointments and reminders (but they do not have access to your medical history or sensitive personal information)
• Again, administrative staff will not have access to your medical notes, just your essential contact details.
• When we have a duty of care, and it is for the protection of others i.e. child protection services.
From time to time, we may have to employ consultants to perform tasks which might give them access to your personal data (but not your medical notes). We will ensure that they are fully aware that they must treat that information as confidential, and we will ensure that they sign a non-disclosure agreement.
You have the right to see what personal data of yours we hold, and you can also ask us to correct any factual errors. Provided the legal minimum period has elapsed, you can also ask us to erase your records.
We want you to be absolutely confident, that we are treating your personal data responsibly, and that we are doing everything we can to make sure that the only people who can access that data have a genuine need to do so.
Principles
The Practice will take all data protection complaints seriously, treat complainants fairly and respectfully, investigate complaints impartially, respond within reasonable timescales and take corrective action where appropriate.
How to Make a Complaint
Complaints may be submitted by email, post, telephone, or in person. Where a complaint is made orally, staff should document the complaint and seek confirmation from the complainant that the record is accurate.
Of course, if you feel that we are mishandling your personal data in some way, you have the right to complain.
Please see our complaints procedure.Information Required
Complainants should provide their name, contact details, a description of the concern, relevant dates, supporting evidence, and their desired outcome where known.
Complaint Handling Procedure
Complaints will be acknowledged within five working days, investigated appropriately, and a written response will normally be provided within one calendar month. Complex matters may be extended by up to two further months where permitted by law.
Personal Data Breaches
Where a complaint identifies a potential breach involving sensitive or personal data, the Practice will assess the breach and comply with applicable ICO notification requirements.
Subject Access Request Complaints
The Practice will ensure searches are reasonable and proportionate in accordance with current legislation.
Escalation
If dissatisfied, complainants should first contact the Practice Manager/Clinic Director. If their issue cannot be resolved this way, then they may contact the Information Commissioner’s Office (ICO), Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, www.ico.org.uk.
Complaint Records
The Practice will maintain a Data Protection Complaints Register and retain complaint records for a minimum of six years from closure unless a longer period is required by law.
Learning and Improvement
The Practice will periodically review complaints to identify trends, training needs and opportunities for improvement.
Responsibilities
The Clinic Director is responsible for overall compliance. All staff (including assistants, associates and consultants working as part of the Practice) must recognise and report complaints, cooperate with investigations and maintain confidentiality.
Policy Review
This policy will be reviewed annually, following significant legislative changes, significant incidents or updated regulatory guidance.
Please contact Celia Crook 01223 981079
Or GOSC