The Rose Clinic Ltd – Updated PRIVACY NOTICE May 2018
(Why I collect your personal data and what I do with it)
When you supply your personal details to this clinic as a Chiropractic or Thermal Imaging Client, they are stored and processed for 4 reasons
1. I 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 I would not be able to provide treatment.
2. I have a “Legitimate Interest” in collecting that information, because without it I couldn’t do my job effectively and safely.
3. I also think that it is important that I can contact you in order to confirm or remind you of your appointments with me or to update you on matters related to your medical care, including, for thermal imaging clients, sending you your EMI report. This again constitutes “Legitimate Interest”, but this time it is your legitimate interest. In the case of thermal imaging clients, I do email you annually to remind you that its time to think about whether or not you would like an annual follow up scan. I believe this is good practice.
4. Provided I have your consent, I may occasionally send you general health information in the form of articles or advice. You may withdraw this consent at any time – just let me know by any convenient method. To date I do not send / email newsletters and have no intention of starting to do this.
I have a legal obligation to retain your records for 8 years after your most recent appointment, but after this period you can ask me to delete your records if you wish. Otherwise, I will retain your records indefinitely in order that I can provide you with the best possible care should you need to see me at some future date.
Your records are stored*
on paper, in a locked drawer or in locked cupboards in the clinic room, and the clinic room is always locked out of working hours.
Thermal reports are stored electronically, both on my password protected laptop, and also on Meditherm US secure databases. This provider (Meditherm US) has given me their assurances that they are fully compliant with the HIPAA/ General Data Protection Regulations. Access to this data is password protected, and the passwords are changed regularly.
Your chiropractic records, drs letters and any correspondence with insurance companies that you have requested I make on your behalf, are stored on my clinic computer. This is password-protected, backed up regularly, and the clinic is locked out of working hours.
I will never share your data with anyone who does not need access without your written consent. Only the following people/agencies will have routine access to your data:
• Meditherm US who store your thermal reports
• Myself as your practitioner in order that I can provide you with treatment
• Other administrative staff, such as my bookkeeper and accountant may see your name and a sum paid (or refunded) on a bank transfer on my bank statement but they do not have access to your medical records or contact details
From time to time, I may have to employ consultants to perform tasks which might give them access to your contact details when in putting that onto my client database but they will not see your medical notes. I will ensure that they are fully aware that they must treat that information as confidential, and I 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.
I want you to be absolutely confident that we are treating your personal data responsibly, and that I am doing everything I 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 I am mishandling your personal data in some way, you have the right to complain. Complaints need to be sent to what is referred to in the jargon as the “Data Controller”. Here are the details you need for that:
Elizabeth Bayliss firstname.lastname@example.org
01256 892336 07775 692225 Town mill, Town Mill Lane, Whitchurch Hants RG28 7LZ
If you are not satisfied with my response, then you have the right to raise the matter with the Information Commissioner’s Office.