Dear new and returning patients,

The clinic is aware of its 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 for and other relevant information about your data.

Data controller:
Freedom Healthcare (and covering the Ashdown Chiropractic clinic) based at 73 Edward Road Haywards Heath RH16 4QL, telephone 01444-416911.

Data protection principles
In relation to your personal data, we will comply with data protection law. This says that the personal information we hold about you must be:

• processed fairly, lawfully and in a clear, transparent way
• collected only for valid reasons that we find proper for the course of your time as a patient and not used in any way that is incompatible with those purposes
• only used in the way that we have told you about
• accurate and up to date
• kept only as long as is necessary for the purposes we outline
• process it in a way that ensures it will not be used for anything that you are not aware of or have consented to (as appropriate), lost or destroyed
• kept securely

The Personal Data We Process and What We Do With It
We record and use the following categories of personal data: name, address, telephone numbers, email address, date of birth, gender, marital status, next of kin, banking and financial information, health information including all aspects of your medical history, diagnosis and ongoing examination and treatment data. We may process letters or emails from you and on your behalf e.g. a medical report or x-ray or MRI. We may, with your permission, receive reports from your GP or other healthcare provider which we then store in you notes. We may, with your request, pass your name and address to third party sales companies who then send you a product you have requested e.g. a nutritional supplement. These companies have their own GDPR requirements once they receive your name and address.

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

As with all cases of seeking consent from you, you will have full control over your decision to give or withhold consent and there will be no consequences where consent is withheld. Consent, once given, may be withdrawn at any time. There will be no consequences where consent is withdrawn.

Why we process your data (How we will use information about you)
The law on data protection allows us to process your data for certain reasons only, these are classified as legitimate interests. Most commonly, we will use your personal information in the following circumstances:

• in order for us to carry out our contract with you (your requesting treatment and our agreement to provide it constitutes a contract) which will include confirming appointments, informing you of changes to appointments or clinic arrangements, changes to facilities or services at the clinic.
• in order to provide you with the best possible treatment by recording health and treatment information which would be in your best interest.
• in order to carry out legally required duties such as those required by me or by my government appointed regulator
• where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests

We may use your personal information in these rare situations:

• where we need to protect your or someone else’s interests
• where it is needed in the public interest or for official purposes
• where it is needed in the public interest or for official purposes

Situations in which we will use your personal information
We need all the categories of information to primarily allow us to perform our contract of treatment with you and to enable us to comply with legal obligations.

If you do not provide your data to us
One of the reasons for processing your data is to allow us to carry out our duties in line with your contract of care with us. If you do not provide us with the data needed to do this, we will be unable to perform that care to ensure your best interests are being maintained. We may also be prevented from continuing with your treatment with us due to our legal obligations.

Change of purpose
We will only use your personal information for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Automated decision making
No decision will be made about you solely on the basis of automated decision making (where a decision is taken about you using an electronic system without human involvement) which has a significant impact on you. 

Sharing your data
Your data will be shared with colleagues within the Clinic but only where it is necessary for them to undertake their duties. This includes, for example, other chiropractors working for, at or on behalf of the clinic and reception staff.

We may share your data with third parties in order to facilitate a referral to another healthcare practitioner, investigation or to keep your GP informed about your progress with treatment.

We may also share your data with third parties as part of a Clinic sale or restructure, or for other reasons to comply with a legal obligation upon us. We would always keep you informed of these situations.

Transferring information outside the EU
We do not share your data with bodies outside of the European Economic Area.

On your request we may share your data with bodies outside of the European Economic Area should the need arise. It is likely that this situation would be to share information regarding your treatment or ongoing care with healthcare practitioners in these countries in accordance with your wishes. However, we would not transfer your data unless we were assured that the country in question had data security and protection laws of equivalence to those of the UK and the European Economic Area. We have put the following measures in place to ensure that your data is transferred securely and that the bodies who receive the data that process it in a way required by EU and UK data protection laws.

Data Security – Protecting your data
We have put in place measures to protect the security of your information against accidental loss or disclosure, alteration, unauthorised access, destruction or abuse. We have implemented processes to guard against such. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Paper files are kept in locked files when not in use. Computer files are encrypted and protected.

Where we are asked to share your data with third parties, we provide written instructions to them to ensure that your data are held securely and in line with GDPR requirements. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.

Retaining Your Personal Data
In line with data protection principles, we only keep your data for as long as we need it for, which will be at least for the duration of your being a patient with us and we are legally required, by the Chiropractic regulator, to keep this data for eight years after your time as a patient has ended. To determine the any appropriate retention period for personal data beyond eight years we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means and the applicable legal requirements.

Once we no longer have a lawful use for retaining your information, we will dispose of it in a secure manner than maintains data security.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

Data may be stored on paper or electronically.

Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your time as a patient with us.

Your rights in relation to your data
The law on data protection gives you certain rights in relation to the data we hold on you.

• the right of access. You have the right to access the data that we hold on you. To do so, you should make a subject access request. Find out how to do this from the clinic.
• the right for any inaccuracies to be corrected. If any data that we hold about you is incomplete or inaccurate, you can require us to correct it.
• the right to be informed. This means that we must tell you how we use your data, and this is the purpose of this privacy notice. We also must inform you of any changes to how we use your data.
• the right to have information deleted. If you would like us to stop processing your data, you have the right to ask us to delete it from our systems where you believe there is no reason for us to continue processing it.
• the right to restrict the processing of the data. For example, if you believe the data we hold is incorrect, we will stop processing the data (whilst still holding it) until we have ensured that the data is correct.
• the right to portability. You may request transfer the data that we hold on you for your own purposes.

If you want to access your data, review, verify or correct your data, request we erase your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the clinic in writing.

Fees
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee for a second or subsequent copy of information or if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to withdraw consent
Where you have provided consent to the collection, processing and transfer of your data, you have the right to withdraw that consent at any time. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to use the data where so permitted by having a legitimate legal reason for doing so.

To withdraw consent, contact the clinic.

Making a complaint
If you have any questions about this Privacy Notice or how we handle your information, please contact the Clinic’s Data Protection officer: Freedom Healthcare who can be contacted on the above address or by email on info@freedom-healthcare.co.uk

You have the right to make a complaint at any time to the supervisory authority in the UK for data protection matters, the Information Commissioner’s Office (ICO).

Data Breaches
Should your personal data that we control be lost, stolen or otherwise breached, where this constitutes a high risk to your rights and freedoms, we will contact you without delay. We will give you the contact details of the Data Protection Officer who is dealing with the breach, explain to you the nature of the breach and the steps we are taking to deal with it.

Steven Rudd ND DC FRCC
Clinic Director