The processing of personal data is governed by the General Data Protection Regulation. GDPR grants you the right to know about what data is stored about you, how it is collected, how it is used, and how long it is kept.
Published on 25 May 2018.
Heather Adams (“I”, “me”, and in this document “we”) is the business owner and the person responsible for your data (the “data controller”).
How do we process personal data?
Patients, prospective patients, former patients and visitors to our clinic
- We use your name, address, telephone number and email address to make and rearrange appointments. We will monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send us is within the bounds of the law.
- Some patients and prospective patients return pre-first appointment questionnaires or tell us about their medical conditions and medication by email or online enquiry forms.
- We keep a permanent attendance register which records all appointments for patients attending our clinic to keep a record of when you were treated for tax purposes and to secure potential evidence in the event of a criminal prosecution, civil litigation, insurance claim or complaint to my regulatory body, the British Acupuncture Council.
- We may use your date of birth to help identify patients with the same name to avoid mistakes being made as to safe and appropriate treatment, for identification purposes if referring a patient to another health practitioner, and for identification purposes if writing to a registered medical practitioner so that they correctly identify the patient.
- We use your presenting complaint and symptoms reported by you for the purposes of making a full traditional diagnosis, formulating treatment strategy and treatment planning.
- We use any relevant medical and family history you have told us for making a full traditional diagnosis, formulating treatment strategy and treatment planning.
- We use your GP’s name and address if we need to contact your GP, including in an emergency and because it is a mandatory requirement in the British Acupuncture Code of Professional Conduct.
- We use our clinical findings about your health and wellbeing for making a full traditional diagnosis, and formulating treatment strategy and treatment planning.
- We keep a record of and refer to that record of any treatment given and details of progress of your case, including reviews of treatment planning to enable us to: review the full traditional diagnosis, treatment strategy and planning; and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint.
- We record and use any information and advice that we have given, especially when referring patients to any other health professional, to help you to receive the most appropriate treatment and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint.
- We record any decisions made in conjunction with you to help you to receive the most appropriate treatment and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint.
- We keep accident records for any patients, visitors or staff who are involved in accidents at our clinic in accordance with UK Health and Safety legislation including the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations (RIDDOR) to comply with the law and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint.
- In the event of an adverse incident occurring to any of our patients we report the matter to the British Acupuncture Council and our insurance company to enable the insurance company to deal with any potential claims and to help the British Acupuncture Council to develop its safe practice guidelines, as well as providing research data and information for the BAcC’s insurers and other interested parties.
- Where relevant we maintain records of the patient’s consent to treatment, or the consent of their next-of-kin to be able to prove that the patient (and/or parent/guardian/next of kin) has given informed consent to treatment to secure evidence in the event of a civil claim, criminal prosecution, insurance claim or complaint.
Complaints about our services
When we receive a complaint from a person we make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint.
We will only use the personal information we collect to process the complaint and to check on the level of service we provide. We usually have to disclose the complainant’s identity to whoever the complaint is about. If a complainant doesn’t want information identifying him or her to be disclosed, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis. We may need to provide personal information collected and processed in relation to complaints to the British Acupuncture Council or our insurance company.
We will keep personal information contained in complaint files in line with our retention policy. This means that information relating to a complaint will be retained for two years from closure. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.
Similarly, where enquiries are submitted to us we will only use the information supplied to us to deal with the enquiry and any subsequent issues and to check on the level of service we provide.
The website heatheradams.co.uk does not collect any personally identifiable information about you. It uses Google Analytics to collect anonymous usage data about how it is used. As a result, certain cookies are in use to enable the functionality of Google Analytics. More information about the data on the website and in electronic communication (such as email or text messages) is available on the privacy section of the website.
Who is my personal data shared with?
Our best effort is made at all times to keep your personal data safe and ensure it is only seen by people who need to see it. Your personal data is shared with the following parties where absolutely necessary:
- with named third parties only with your explicit consent;
- with the relevant authority such as the police or a court, if necessary for compliance with a legal obligation to which we are subject e.g. a court order;
- with your doctor or the police if necessary to protect yours or another person’s life;
- with the police or a local authority for the purpose of safeguarding a children or vulnerable adults; or
- with the regulatory body, the British Acupuncture Council, or the insurance company in the event of a complaint or insurance claim being brought against us; or
- our solicitor in the event of any investigation or legal proceedings.
For further details about the situations when information about you might be shared, see the Information Commissioner’s website.
How long do we keep your personal data?
We keep patient records for a period of 7 years in accordance with the British Acupuncture Code of Professional Conduct. Data is destroyed by shredding of physical paper records or secure deletion of electronic records. On death, responsibility for managing your data is transferred to my next of kin. You may request at any time that changes are made to your contact details.
Your rights and your personal data
Unless subject to an exemption under the GDPR, you have certain rights with respect to your personal data as follows:
- The right to request a copy of your personal data which we hold about you.
- The right to request that we correct any personal data if it is found to be inaccurate or out of date.
- The right to request your personal data is erased where it is no longer necessary for us to retain such data.
- The right to withdraw your consent to the processing at any time. This right does not apply where we are processing information using a lawful purpose other than consent.
- The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), where applicable.
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing.
- The right to object to the processing of personal data, where applicable.
- The right to be informed if your data is lost. We shall also inform the Information Commissioner’s Office in accordance with the time limits in the GDPR.
- The right to lodge a complaint with the Information Commissioner’s Office.
For further details about these rights, see the Information Commissioner’s website.
Please contact Heather Adams directly through the contact details posted on the website.