In accordance with the General Data Protection Regulation (GDPR) we have implemented this privacy notice to provide our patients with details of how we collect and process your personal data. We also include within this policy the reasons for processing your data, the lawful basis that permits us to process it, how long we keep your data for and your rights regarding your data.
By providing us with your data and your child’s data, you warrant to us that you are over 13 years of age.
Rachel Clarke, secretary to Dr. Pierini, is the data controller and she is responsible for you and your child’s personal data (referred to as “we”, “us” or “our” in this privacy notice).
We have appointed a Data Protection Officer who is in charge of privacy related matters for us. If you have any questions about this privacy notice, please contact the Data Protection Officer using the details set out below.
Contact Details. Our full details are:
Data Protection Officer: Rachel Clarke
Full name of legal entity: Dr. Silvia Pierini, Private Paediatric Consultant
Email address: email@example.com
Postal address: 58 South Molton Street, Mayfair, London W1K 5SL
Telephone number: 0208 817 5278 or 07946299240
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint, so that we can try to resolve it for you.
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at firstname.lastname@example.org
- WHAT DATA DO WE COLLECT ABOUT YOU
Personal data means any information capable of identifying an individual. It does not include anonymised data. We may process certain types of personal data about you and your child as follows:
Identity Data may include your child’s first name, last name, title, date of birth and gender.
Contact Data may include your address, email address and telephone numbers.
Financial Data may include your bank account and payment card details.
Transaction Data may include details about payments between us.
External medical records may include records we collect from you, external records from GPs/consultants/procedures. These will always be collected with your consent.
Treatment notes may include notes written during and following your consultations.
We may also process Aggregated Data from your personal data but this data does not reveal your identity and as such in itself is not personal data. An example of this is where we review your Profile Data to give us statistics on feedback received from patients. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data.
We collect sensitive data about your child’s health to help us assess and treat them appropriately. We do not collect any other Sensitive Data about them. Sensitive data refers to data that includes details about a person’s race or ethnicity, their family’s religious or philosophical beliefs and political opinions.
- HOW WE COLLECT YOU AND YOUR CHILD’S PERSONAL DATA
We collect data about you and your child through a variety of different methods including:
Direct interactions: You may provide additional data to Dr. Pierini during your child’s consultation or to her secretary over the phone. You may also be asked to provide information for reasons of billing your medical insurance provider, or by communicating with us by post, phone, email or otherwise, including when you:
2. Book an appointment with us.
3. Have specific questions relating to your child’s health or information required for medical insurance.
- HOW WE USE YOUR PERSONAL DATA
The law on data protection allows us to process your data for certain reasons only. In the main, we process your child’s data to comply with a legal requirement or in order to manage their treatment. Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to contacting other health professionals involved in your child’s care or contacting your medical insurers.
Purposes for processing your personal data
Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are, where relevant.
We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please see the information below;
|Purpose/Activity||Type of data||Lawful basis for processing|
|To register you as a new patient||Identity, Contact||Legal obligation|
|To provide effective treatment using external medical notes and treatment notes.||
Identity,Contact, Treatment notes, External medical notes
|To ensure we receive payment for treatments.||Identity, Contact, Financial Transaction||Legal obligation|
|To administer and run our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).||Identity,Contact,Technical||
Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise
|To use data analytics to improve our website, services, patient relationships and experiences.||Technical Usage||Our legitimate interests. To develope our business|
Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to contacting other health professionals treating your child. You have the right to withdraw consent at any time by emailing Rachel Clarke at email@example.com
You will not receive marketing communications.
Change of purpose
We will only use your personal data for the purposes for which we have 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 data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.
- DISCLOSURES OF YOU AND YOUR CHILD’S PERSONAL DATA
We may have to share your personal data with a third party for the purposes set out in the table in paragraph 4 above:
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
- INTERNATIONAL TRANSFERS
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
- DATA SECURITY
We have put in place appropriate security measures to prevent you or your child’s personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data only to those employees or other third parties who have a need to know such data for the health and wellbeing of your child. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
- DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, 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.
By law we have to keep basic information about our patients (including Contact, Identity, Treatment notes, External medical notes, Financial and Transaction Data) for seven years after their 18th birthday or until they are 25 years old.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
- YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data.In some circumstances you can ask us to delete your data: see below for further information. These include the right to:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
You can see more about these rights at:https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
If you wish to exercise any of the rights set out above, please email us at firstname.lastname@example.org.
You will not have to pay a fee to access you or your child’s personal data (or to exercise any of the other rights). We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
- THIRD-PARTY LINKS: Our website, email and data storage system (Cliniko) do not include links to third-party websites, plug-ins and applications.