The practice aims to meet the requirements of the Data Protection Act 2018, the General Data Protection Regulation (GDPR] 25th May 2018, the guidelines on the Information Commissioner’s website as well as our professional guidelines and requirements.
The Data Controller is Anglia Orthodontics, as PM,Louise Hand manages this together with the information Governance Lead and (in NHS practices) the Data Protection Officer.
This Privacy Notice is available on the practice website at www.practice.com/privacynotice / at reception/ by email if you contact firstname.lastname@example.org/ by calling 01223 305526
You will be asked to provide personal information when contacting or joining the practice. The purpose of us processing this data is to provide optimum orthodontic health care to you. We will collect data about you by phone, email, our website, verbally, text, referral, post directly from you or indirectly e.g. Dental referral.
Personal data is any information that relates to a living individual who can be identified from the information alone, or from information combined with other data e.g. post codes, dob,etc
Special data is the more sensitive information e.g. health, race and ethnicity,etc
The categories of data we process are:
Personal data for the purposes of staff and self-employed team member management
Personal data for the purposes of direct mail/email/text/other marketing
Personal data for fulfilling a public authority role given by legislation e.g. NHS England to deliver our responsibilities
Personal data for taking steps to enter into a contract or necessary for the performance of a contract
Special category data including health records for the purposes of the delivery of health care
Special category data including health records and details of criminal record checks for managing employees and contracted team members
We never pass your personal details to a third party unless we have an agreement contract for them to process data on our behalf and will otherwise keep it confidential. If we intend to refer a patient to another practitioner or to secondary care such as a hospital we will gain the individual’s permission before the referral is made and the personal data is shared.
We have binding agreements in place with: OurIT, Orthotrac, TIO, S4Slabs, payrole
For your information the minimum relevant personal or special data for your personal Orthodontic treatment may be shared with; Invisalign, Dentist, Vivera, S4Slabs, Referral hospitals, iTero, Align Technology, 3M(lingual lab),DM or your GP
Personal data is stored in the UK whether in digital or hard copy format
Personal data is stored in the US in digital format when the data storage company is certified with the EU-US Privacy Shield
Personal data is obtained when a patient joins the practice, when a patient is referred to the practice, when a person completes our online forms, when a person uses our website and when a patient subscribes to an email list
The lawful basis of processing personal data for NHS patients as a public authority -Article 6public task (NHS Act 2006 section 83 NHS England to secure the provision of primary care), e.g. such as name, address, email or phone number is:
Processing is necessary for fulfilling a role given by legislation e.g. NHS England to deliver our responsibilities
The lawful basis of processing personal data for private patients–Article 6contracts or legitimate interests -Necessary for performance of a contract with the data subject or to take steps to enter into a contract
The lawful basis of processing personal data for staff and self employed team members–Article 6legitimateinterests
The lawful basis of processing personal data for CCTV–Article 6legitimate interests The various conditions for processing special data are listed in Article 9(2) of the GDPR.
The lawful basis for processing special category data e.g.patients’ and employees’ data –Article 9Health andsocial care :
Processing is necessary for the purposes of preventative or occupational medicine, for assessing the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or management of health or social care systems and services on the basis of Union or Member State Law or pursuant to contract with a health professional and subject to the conditions of safeguarding.
The lawful basis for processing special category data e.g. pensions, equality data–Article 9substantial publicinterests
The lawful basis for processing special category data concerning an employee–Article 9employment andsocial security
The retention period for special data in patient records is a minimum of 10 years and may be longer for complex records in order to meet our legal requirements. The retention period for staff records is 6 years. The retention periods for other personal data is 2 years after it was last processed. Details of other retention periods are available in the Record Retention (M 215) procedure available from the practice.
You have the following data subject rights:
The right to be informed
The right of access
The right to rectification(we will put a note on the record)
The right to erasure (clinical records must be retained for a certain time period/we will place a note on the records)
The right to restrict processing
The right to data portability
The right to object
Further details of these rights can be seen in our Information Governance Procedures (M 217C) or at the Information Commissioner’s website. Here are some practical examples of your rights:
If you are a patient of the practice you have the right to withdraw consent for important notifications, newsletters, surveys or marketing. You can inform us to correct errors in your personal details or withdraw consent from communication methods such as telephone, email or text. You have the right to obtain a free copy of your patient records within one month.
If you are not a patient of the practice you have the right to withdraw consent for processing personal data, to have a free copy of it within one month, to correct errors in it or to ask us to delete it. You can also withdraw consent from communication methods such as telephone, email or text.
We have carried out a Privacy Impact Assessment (M 217S) and you can request a copy from the details below. The details of how we ensure security of personal data is in our Security Risk Assessment (M 217M) and Information Governance Procedures (M 217C).
Dealing with other people: It is our policy to only talk to other people on your behalf if you have named them on your medical history form. This applies to everyone over the age of 16 years. Please note this applies to everything including appointments.
Email: transmission of information via the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; transmission is at your own risk. Once we have received your information, we will uses strict procedures to prevent unauthorised access.
Comments, suggestions and complaints
Please contact Louise Hand at the practice for a comment, suggestion or a complaint about your data processing at Anglia Orthodontics,Lammas Field Pavilion Driftway Cambridge CB3 9PA or 01223 305526 or by writing to or visiting the practice at the www.angliaorhodontics.co.uk. If we cannot abide by your request we will give you an explanation in writing. We take complaints very seriously.
If you are unhappy with our response or if you need any advice you should contact the Information Commissioner’s Office (ICO). Their telephone number is 0303 123 1113, you can also chat online with an advisor. The ICO can investigate your claim and take action against anyone who’s misused personal data. You can also visit their website for information on how to make a data protection complaint.
Related practice procedures
You can also use these contact details to request copies of the following practice policies or procedures:
Data Protection and Information Security Policy (M 233-DPT), Consent Policy (M 233-CNS), Privacy Impact Assessment (M 217S), Information Governance Procedures (M 217C), Record Retention management(M215)
Links to other websites: our website may use links to other websites of interest, Once you have used these links to leave our site, you should note, we do not have control over any other websites. Therefore we cannot be responsible for the protection and privacy of your information once you have left our website and they are not governed by this privacy notice