REHAB HUB LTD – PRIVACY NOTICE
(Why we collect your personal data and what we do with it)
When you supply your personal details to this clinic it is stored and processed for 4 reasons (the bits in bold are the relevant terms used in the General Data Protection Regulation – i.e. the law):
1. We need to collect personal information about your health in order to provide you with the best possible treatment. Your requesting treatment and our agreement to provide that care constitutes a contract. You can, of course, refuse to provide the information, but if you were to do that we would not be able to provide treatment.
2. We have a “Legitimate Interest” in collecting that information, because without it we couldn’t do our job effectively and safely.
3. We also think that it is important that we can contact you in order to confirm your appointments with us or to update you on matters related to your medical care. This again constitutes “Legitimate Interest”, but this time it is your legitimate interest.
4. Provided we have your consent, we may occasionally send you general health information in the form of articles, advice or newsletters. You may withdraw this consent at any time – just let us know by any convenient method.
We have a legal obligation to retain your records for 8 years after your most recent appointment (or age 25, if this is longer), but after this period you can ask us to delete your records if you wish. Otherwise, we will retain your records indefinitely in order that we can provide you with the best possible care should you need to see us at some future date.
Your records are stored:
· On paper, in locked filing cabinets. The offices are always locked and alarmed out of working hours.
· Within a specialist healthcare computer system named Cliniko.
Occasionally it is necessary for an Associate to take your paper records home for the purpose of note-writing. We have the policy that these are returned within one week, and that they are securely (locked away) within their home premises. This practice will cease by the end of 2018 as we transition fully to the Cliniko solution.
Supporting information about you, and regarding you is stored:
· Electronically (“in the cloud”), using Dropbox. This provider has given us their assurances that they are fully compliant with the General Data Protection Regulations. Access to this data is password protected, and the passwords are changed regularly.
· As mentioned previously in a specialist healthcare computer system, named Cliniko. This provider has given us their assurances that they are fully compliant with the General Data Protection Regulations. Access to this data is password protected, and the passwords are changed regularly. We have methods of toggling marketing preferences on/off within this system, and this information carries through to our Mailchimp marketing solution.
· On our office computers. These are password-protected, backed up regularly, and the office is locked out of working hours.
· Some limited information about you (your name, email address, phone number, appointment information) is held within the Rehab My Patient clinic software. Again, these providers have given us their assurances that they are fully compliant with the General Data Protection Regulations. Access to this data is password protected, and the passwords are changed regularly.
· If you engage with us via our social media platforms (Facebook, Google+, Instagram, Twitter) you should be aware that your posts are in the public and for all to see. Private messages sent to us remain so. Only the Data Controller and clinic Associates have access to the social media accounts and their access is limited by password.
· Your name, phone number and email is likely stored on our Associates’ phones and notepads for the purpose of contacting you regarding your treatment. It should be noted also that clinic software Ovatu and Rehab My Patient (see above) is also accessible via these devices. These devices are locked with passwords also.
We will never share your data with anyone who does not need access without your written consent.
From time to time, we may have to employ consultants to perform tasks which might give them access to your personal data (but not your medical notes). We will ensure that they are fully aware that they must treat that information as confidential, and we will ensure that they sign a non-disclosure agreement.
You have the right to see what personal data of yours we hold, and you can also ask us to correct any factual errors. Provided the legal minimum period has elapsed, you can also ask us to erase your records.
We want you to be absolutely confident that we are treating your personal data responsibly, and that we are doing everything we can to make sure that the only people who can access that data have a genuine need to do so.
Of course, if you feel that we are mishandling your personal data in some way, you have the right to complain. Complaints need to be sent to what is referred to in GDPR jargon as the “Data Controller” (the undersigned). If you have reason to complain and you are not satisfied with our response, then you have the right to raise the matter with the Information Commissioner’s Office.
Georgina Baglin – Data Controller. Clinic Director.
Rehab Hub Ltd