Portland’s GDPR Data Security Policies

Scope

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.

Portland Physiotherapy and Sports Injury Clinic [PPC] is pleased to provide the following information:

1– Who we are
PPC is a physiotherapy clinic providing physiotherapy diagnosis, assessment and treatment to the general public.

The Physiotherapists at PPC diagnose and treat health conditions. Treatments are carried out in accordance with the Chartered Physiotherapy patient charter and are members of The Health Care Professional Council.

2 – Personal Data
a) Contact details provided by you such as telephone numbers, email addresses, postal addresses and details of past and future bookings and purchases made at PPC may be used to confirm or remind you of future appointments and bookings at PPC and provide reports or other information concerning those visits.  

b) Credit or debit card information is not stored.  Payments will not be processed on your behalf  by PPC without your prior consent.

c) For the purposes of providing treatment, our Physiotherapists may require detailed medical information. We will only collect what is relevant and necessary for your treatment. When you visit our practice, we will make notes which may include details concerning your medication, treatment and other issues affecting your health. This data is always held securely, is not shared with anyone not involved in your treatment, although for data storage purposes it may be handled by pre-vetted staff who have all signed an integrity and confidentiality agreement. To be able to process your personal data it is a condition of any treatment that you give your explicit consent to allow PPC to document and process your personal medical data. As part of our obligations as primary healthcare practitioners there may be circumstances related to your treatment, on-going care or medical diagnosis that will require the sharing of your medical records with other healthcare practitioners e.g GPs, consultants, surgeons and/or medical insurance companies. Where this is required we will always inform you first unless we are under a legal obligation to comply.

d) For marketing purposes, the PPC 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, ie: review reduced rate appointments. There is a quarterly newsletter which you initially opt into but may also unsubscribe at any time.

e)In making initial contact with the practice you are given the option to consent to PPC maintaining a marketing dialogue with you until you either opt out (which you can do at any time) or we decide to desist in promoting our services.

3– Legal basis for processing any personal data
To meet our contractual obligations obtained from explicit Patient Consent and legitimate interest to respond to enquiries concerning the services provided.

4– Consent
Through agreeing to this privacy notice you are consenting to PPC 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.

5 – Disclosure
PPC will keep your personal information safe and secure, only staff engaged in providing physiotherapy treatments will have access to your patient records, although our administration team will have access to your personal details as specified in 3 a) and b) above so that they can make appointments and manage your account. PPC will not disclose your Personal Information unless compelled to, in order to meet legal obligations, regulations or valid governmental requests. PPC 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.

6– Retention Policy
PPC will process personal data during the duration of any service or treatment and will continue to store only the personal data needed for eight years from your last visit to meet any legal obligations. After eight years all paper personal data  will be destroyed. Records concerning minors who have received treatment will be retained until the child has reached the age of 25.

7– Data storage
PPC uses the services of various data processors to facilitate the services we provide. These are TM2, Postmaster, Mailchimp.

8 – Your rights as a data subject
At any point whilst PPC 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 PPC 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 PPC can confirm what information it holds about you and how it is processed.

9 – You can request the following information:

• Identity and the contact details of the person or organisation (PPC) 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  PPC 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.

10– To access what personal data is held, identification will be required
PPC 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 PPC is dissatisfied with the quality, further information may be sought before personal data can be released. All requests should be made to portlandphysiotherapy@postmaster.co.uk or by phoning +44 (0) 1342 327246 or writing to us at the following address. Portland Physiotherapy and Sports Injury Clinic, Cantelupe House, Cantelupe Road, East Grinstead, West Sussex. RH19 3BZ.

11 – Complaints
We work hard to ensure your personal information is treated safely and securely. In the event that you wish to make a complaint about how your personal data is being processed by PPC you have the right to complain to us.

If you would like to discuss anything in relation to this policy or how we handle your personal information please contact :

Nikki Brown/ Adam Rawle/ Jo West
Telephone +44 (0) 1342 327246 or email: portlandphysio@postmaster.co.uk