15th March 2016

Privacy and Cookie Policy

Walford Mill Dental Care takes great care to protect the personal data we hold for our patients in line with the requirements of the General Data Protection Regulation (GDPR).

The purpose of collecting and storing personal data about our patients is to ensure we can:

  • Provide, appropriate, safe and effective dental care, treatment and advice for all our patients
  • Fulfil any contracts we hold in relation to their care
  • For business administration of their care.

Personal data held for our patients

The personal data we process (processing includes obtaining the information, using it, storing it, securing it, disclosing it, and destroying it) for our patients includes:

  • Name, address, date of birth
  • Next of kin
  • Email address
  • Phone numbers
  • GP contact details
  • Occupation
  • Medical history
  • Dental care records
  • Photographs / radiographs
  • Family group
  • Payment plan details
  • Financial information
  • Credit cards receipts
  • Correspondence
  • Details of any complaints received

 

We keep an inventory of personal data we hold on our patients and this is available for patients on request. A list of personal information held is also included in our Privacy Notice that is given to all patients.

Disclosure to third parties

The information we collect, and store will not be disclosed to anyone who does not need to see it.

We will share our patients’ personal information with third parties when required by law or to enable us to deliver a service to them or where we have another legitimate reason for doing so. Patient data may also be stored for back-up purposes with our computer software suppliers who may also store it securely. Third parties we may share patients’ personal information with may include:

  • Regulatory authorities such as the General Dental Council or the Care Quality Commission
  • NHS Local Authorities
  • Dental payment plan administrators
  • Insurance companies
  • Dental Laboratories
  • Specialists (for referrals)
  • Loss assessors
  • Fraud prevention agencies
  • In the event of a possible sale of the practice at some time in the future.

We may also share personal information where we consider it to be in a patient’s best interest or if we have reason to believe an individual may be at risk of harm or abuse.

Personal privacy rights

Under the GDPR all individuals who have personal information held about them have the following personal privacy rights:

  • Right to subject access.
  • Right to have inaccuracies deleted.
  • Right to have information erased.
  • Right to object to direct marketing.
  • Right to restrict the processing of their information, including automated decision-making.
  • Right to data portability.

Patients who wish to have inaccuracies deleted or to have information erased must speak to the dentist who provided or provides their care.

Legal basis for processing data held about patients

The GDPR requires us to state the legal basis upon which we process all personal data for our patients and it requires us to inform our patients of the legal basis on which we process their personal data. This is clearly stated in our privacy notice that is given to all patients.

The legal bases for recording individual types of data are recorded in our patient personal data inventory. This is available for all patients to see on request.

The legal basis on which we process personal information for our private patients is in our Legitimate Interest to do so.

The legal basis on which we process personal information for our payment plan patients is for the need to fulfil a Contract with us.

The legal basis on which we process personal information for our NHS patients is for the need to fulfil a Contract with the NHS.

Automated decision making

You will be asked to opt in to any processes involving automated decision making.

This includes:

  • Automated SMS Text messages and email appointment reminders when this information is provided
  • Automated SMS Text messages and email recalls

Consent

Walford Mill Dental Care will always obtain specific, unambiguous opt in consent from all patients to whom we send direct marketing information. This consent is obtained through the practices’ New Patient Screening form.

We will also obtain specific, opt in consent from you for receiving appointment reminders by text and /or email, taking clinical photographs and sending personal data, relevant clinical information, including relevant details of medical histories, supporting x-rays and photographs to other healthcare professionals for the purpose of receiving dental treatment elsewhere. This consent is also obtained through the practices’ New Patient Screening form.

For a new patient, we obtain consent for these things when the patient first attends the practice. For an existing patient, we ask the patient for consent when they attend for their recall appointment or for a treatment appointment. We refresh this consent annually when the patient completes a new medical history proforma.

Withdrawal of consent

Patients who have given their opt in consent have a right to withdraw their consent at any time. Patients are advised of their right to withdraw their consent for anything they wish to withdraw from in our privacy notice.

Retention period

This practice retains dental records and orthodontic study models while the patient is a patient of the practice and after they cease to be a patient, for at least eleven years, or for children until age 25, whichever is the longer.

Complaints

 You have a right to complain about how we process your personal data.

All complaints concerning personal data should be made in person or in writing to our Data Protection Officer, Michelle Tait at Walford Mill Dental Care on 01202 888303 and we will do our best to resolve the matter.  If this fails, you can complain to the Information Commissioner at www.ico.org.uk/concerns or by calling 0303 123 1113. All complaints will be dealt with in line with the practice complaints policy and procedures.

Transferring personal data outside the EU

Your personal data is not transferred outside the EU.

Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

How we use cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes, by gathering and remembering information about your preferences.

Wherever possible we do not use cookies unless they are required for the website to function correctly (these are known as “essential” cookies) or they are required as part of our ongoing commitment to improving your user experience and monitoring the traffic to our website (these are known as “non-essential” cookies).

Unless you have chosen to decline the use of cookies through your browser options or through the options available on this page then we will assume that we have your “implied consent” to continue using them.

If you have agreed to let us use cookies then the following types of cookies may be placed on your computer:
Google Analytics uses tracking cookies to collect anonymous traffic data about your use of this site.

This information is stored by Google and is subject to their privacy policy, which can be seen at http://www.google.com/privacy.html.
Google Analytics collects information such as pages you visit on this site, the browser and operating system you use and time spent viewing pages.

The purpose of this information is to help us improve the site for future visitors.
If you see any Social Media features on this site e.g. Twitter, Facebook and Google+1, they may also set or retrieve cookies on your machine.

If you have previously agreed that we may use cookies and wish to change your mind you may do so by deleting the existing cookies in your browser. Thereafter we will not be using cookies or collecting any information about you until you provide your consent again.
If you have any questions about this issue please contact us.

Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Complaints

All individuals who have personal data held about them have a right to complain. All complaints concerning personal data should be made in person or in writing to Dr Neil D Greenway at Walford Mill Dental Care on 01202 888303 and we will do our best to resolve the matter. If this fails, patients can complain to the Information Commissioner at www.ico.org.uk/concerns or by calling 0303 123 1113. All complaints will be dealt with in line with the practice complaints policy and procedures. 

Patients’ personal data is not transferred outside the EU.

This Policy was reviewed and implemented on: 26/03/19

This policy and relevant procedures will be reviewed annually and are due for review

on: 01/03/2020 or prior to this date in accordance with new guidance or legislative changes.