The inc-HEALTH Chiropractic Clinic we aware of our 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 and other relevant information about your data.
This notice applies to current and former patients
All data subjects whose personal data is collected, in line with the requirements of the GDPR.
The Data Protection Officer is responsible for ensuring that this notice is made available to data subjects prior to inc-HEALTH collecting/processing their personal data.
All staff of inc-HEALTH who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and their consent to the processing of their data is secured.
Who are we? inc-HEALTH provides chiropractic and allied services. The business strives to provide professional, friendly and effective care.
Our Data Protection Officer and data protection representatives can be contacted directly here:
inc-HEALTH St James Park or inc-HEALTH South Kensington
Responsible person: Ida Nørgaard. Buckingham Court, 78 Buckingham Gate, London SW1E 6PE. Alternatively, you may ask for an appointment with Ida Nørgaard. Telephone 020 7931 9572. E-mail firstname.lastname@example.org
The personal data we would like to collect from you is:
|Personal data type:||Source|
|Contact details||From referrer or individual data subject|
|Referral information||From referrer|
|Financial information including insurers||From referrer or individual data subject|
The personal data we collect will be used for the following purposes:
- To enable us to provide care to you
- To help us assess our services with a view to continual improvement
- To enable us to manage our finances including invoicing for our services
Our legal basis for processing for the personal data:
- Contractual obligations
Any legitimate interests pursued by us, or third parties we use, are as follows:
The special categories of personal data concerned are:
- Health data
Personal data is retained in the clinic. Paper records are stored in a locked filing cabinet and electronic data is encrypted and password protected. The clinic is locked when not in use and the access to the premises is controlled via a security guard. Out of hours, when the security staffs are off duty, access is controlled via a door entry system. CCTV is in use 24/7
By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified. Consent is required for inc-HEALTH to process both types of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.
You may withdraw consent at any time and we have a specific withdrawal of consent form for you to complete if required.
As we are contractually obligated to keep records related to care withdrawal of consent will necessitate our stopping treatment.
inc-HEALTH will not pass on your personal data to third parties without first obtaining your consent.
Retention period inc-HEALTH will process personal data for the duration of your care and will store the personal data for 8 years after your last session with us or 8 years after your 18th birthday.
Your rights as a data subject
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
- The 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 a restriction of processing – where certain conditions apply to have a right to restrict the processing.
- The 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 to be subject to the legal effects of automated processing or profiling.
- Right to judicial review: in the event that inc-HEALTH refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined below.
All of the above requests will be forwarded on, should there be a third party involved in the processing of your personal data.
In the event that you wish to make a complaint about how your personal data is being processed by inc-HEALTH or how your complaint has been handled, you have the right to lodge a complaint with inc-HEALTH’s Data Protection Officer/data protection representatives or directly the with the Information Commissionaires Office (ICO). Details on how to complain can be found at: inc-HEALTH – https://www.xxxxxx ICO – https://ico.org.uk/make-a-complaint/
Online privacy statement
Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:
“any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
How we use your information
This privacy notice tells you how we, inc-HEALTH, will collect and use your personal data for providing you care, improving our services and managing our finances including raising invoices to you.
Why does inc-HEALTH need to collect and store personal data?
In order for us to provide you with the health care services you need, we need to collect personal data for both correspondence purposes and your detailed healthcare provision. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy. In terms of being contacted for marketing purposes, inc-HEALTH would contact you for additional consent.
Will inc-HEALTH share my personal data with anyone else?
We may pass your personal data on to third-party service providers contracted to inc-HEALTH in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide you on our behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with inc-HEALTH’s procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.
We may also share your data with third parties as part of a Clinic sale or restructure, or for other reasons to comply with legal obligations upon us. We would always keep you informed of these situations
We do not share your data with bodies outside the European Economic Area
How will inc-HEALTH use the personal data it collects about me?
inc-HEALTH will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary.
inc-HEALTH is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.
Under what circumstances will inc-HEALTH contact me?
Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.
Can I find out the personal data that the organisation holds about me?
inc-HEALTH at your request can confirm what information we hold about you and how it is processed. If inc-HEALTH does hold personal data about you, you can request the following information:
- Identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU.
- 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 inc-HEALTH or a third party, information about those interests.
- The categories of personal data are collected, stored and processed.
- Recipient(s) or categories of recipients to whom the data is/will be disclosed to.
- If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
- How long the data will be stored.
- Details of your rights to correct, erase, 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.
- 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.
What forms of ID will I need to provide in order to access this?
inc-HEALTH accepts the following forms of ID when information on your personal data is requested: Passport, driving licence or birth certificate
Contact details of the Data Protection Officer/data protection representative are provided in the Privacy Notice above
Document Owner and Approval
The Data Protection Officer is the owner of this document and is responsible for ensuring that this record is reviewed in line with the review requirements of the GDPR.
Change History Record
|Issue||Description of Change||Approval||Date of Issue|