Last modified: 24 March 2021
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 Raman Sandhu, the Information Governance Lead is Kim Lawrence who is also the Data Protection Officer.
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 dental health care and prevention.
The categories and examples of data we process are:
▪ Personal data for the provision of dental 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 or text] 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, if you are having NHS treatment.
▪ Personal data is stored in the [EU] whether in digital or hard copy format
▪ Personal data is stored in the US in digital format when the data storage company is certified with the EU-US Privacy Shield
▪ 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.
For full details or where your data is stored, please ask to see Information Governance Procedures
We have established the following lawful bases for processing your data: Our lawful bases for processing personal data:
▪ The legitimate interests of the dental 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 dental treatment, prevention and oral health advice
▪ To carry out financial transactions with you
▪ To manage your NHS dental care treatment
▪ To send your personal data to the General Dental Council or other 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, NHS number, medical history, dental 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 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 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 free copy of your data that we have
▪ 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 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 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 and Information Governance Procedures.
Data Opt-Out Policy
How the NHS and care services use your information
Coulsdon Dental Clinic is one of many organisations working in the health and care system to improve care for patients and the public. Whenever you use a health or care service, such as attending Accident & Emergency or using Community Care services, important information about you is collected in a patient record for that service. Collecting this information helps to ensure you get the best possible care and treatment. The information collected about you when you use these services can also be used and provided to other organisations for purposes beyond your individual care, for instance to help with:
This may only take place when there is a clear legal basis to use this information. All these uses help to provide better health and care for you, your family and future generations. Confidential patient information about your health and care is only used like this where allowed by law.
Most of the time, anonymised data is used for research and planning so that you cannot be identified in which case your confidential patient information isn’t needed.
You have a choice about whether you want your confidential patient information to be used in this way. If you are happy with this use of information you do not need to do anything. If you do choose to opt out your confidential patient information will still be used to support your individual care. To find out more or to register your choice to opt out, please visit www.nhs.uk/your-nhs-data-matters. On this web page you will:
You can also find out more about how patient information is used at:
https://www.hra.nhs.uk/information-about-patients/ (which covers health and care research); and
https://understandingpatientdata.org.uk/what-you-need-know (which covers how and why patient information is used, the safeguards and how decisions are made)
You can change your mind about your choice at any time.
Data being used or shared for purposes beyond individual care does not include your data being shared with insurance companies or used for marketing purposes and data would only be used in this way with your specific agreement.
Health and care organisations have until 2020 to put systems and processes in place so they can be compliant with the national data opt-out and apply your choice to any confidential patient information they use or share for purposes beyond your individual care.
Our practice only uses your personal health data to provide individualised care to you and does not disclose your data for any other purposes. The national data opt-out does not apply to our usage of your data and we are compliant with the policy.
Comments, suggestions and complaints
Please contact the IG Lead at the practice for a comment, suggestion or a complaint about your data processing at firstname.lastname@example.org or by writing to or visiting the practice at 72 Brighton Road CR5 2BB. 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.
Related practice procedures
You can also use these contact details to request copies of the following practice policies or procedures:
▪ Data Protection and Information Security Policy, Consent Policy
▪ Privacy Impact Assessment , Information Governance Procedures, Record Retention
If you have an enquiry or a request please contact the Information Governance Lead