Privacy Policy

Welcome to the Dental Surgery’s Privacy Policy.

  1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY POLICY

We are committed to ensuring that your privacy and personal data is protected. This Privacy Policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

We will comply with the Data Protection Act 2018 (“DPA”) and the General Data Protection Regulation (EU) (2016/679) (“GDPR”) together with any national implementing laws, regulations and secondary legislation as amended or updated from time to time in the UK, and any successor legislation to the DPA and the GDPR (together “Data Protection Legislation”).

This Privacy Policy provides information on how and why we collect and process your personal data through the use of this website or when we provide our services to you.

It is important that you read this Privacy Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.

CONTROLLER AND CONTACT DETAILS

TDSML Limited, trading as The Dental Surgery, is a private company incorporated in England and Wales under company number 8503648 whose registered address is at:

27 Mortimer Street

London

W1T 3BL

United Kingdom

(“The Dental Surgery”/ “we” / “our” / “us”)

The Dental Surgery is the data controller and is responsible for the personal data you provide.

We have appointed Bridget McGrade as data protection officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy or our privacy practices, please contact us at feedback@thedentalsurgery.co.uk

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

 We keep our Privacy Policy under regular review.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD PARTY SITES

Our website may contain links to third party websites, including websites via which you are able to purchase products and services. They are provided for your convenience only and we do not check, endorse, approve or agree with such third-party websites nor the products and/or services offered and sold on them. We have no responsibility for the content, product and/or services of the linked websites. Please ensure that you review all terms and conditions of website use and the Privacy Policy of any such third-party websites before use and before you submit any personal data to those websites.

COOKIES

Our website uses cookies to distinguish you from other users of the website. For detailed information on the cookies we use and the purposes for which we use them, please see our cookie policy here.

  1. WHAT PERSONAL DATA DOES THE DENTAL SURGERY HOLD ABOUT YOU?

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, maiden name, last name, marital status, title, date of birth and gender.

Contact Data includes email address, postal address and telephone numbers.

Financial Data includes bank account and payment card details.

 Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

Technical Data includes the internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

Profile Data includes purchases or orders made by you, your interests, preferences, feedback and survey response.

Usage Data includes information about your visit to our website, products you viewed or searched for, page response times, website errors, length of visits to certain pages, page interaction information, methods used to browse away from the page.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

We will also collect, store and use the following types of more sensitive personal information: information about your health, including any medical condition, health and sickness records (“Health Data”).

We do not collect any information about criminal convictions and offences.

  1. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact, Health and Financial Data by filing in forms or by corresponding with us by phone, email or otherwise. This includes personal data you provide when you:
    • Apply for our services and book appointments through the online booking portal and late availability app (Gappt);
    • Complete enquiry forms on our website;
    • Subscribe to our service or publications;
    • Request marketing to be sent to you;
    • Enter a survey; or
    • Give us feedback or contact us.
  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy here for further details.
  • Third parties or publicly available sources. We will receive personal data about you from various third parties [and public sources] as set out below:
    • Technical Data from the following parties:
    1. analytics providers such as Google based outside the EU;
    2. advertising network; and
    3. search information providers based inside or outside the EU.
    • Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
    • Identity and Contact Data from Gappt Limited.
    • Health Data from the NHS or other private medical practices.
  1. WHY DO WE PROCESS YOUR PERSONAL DATA?

We will only use your personal data when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

  1. Where we need to perform the contract we have entered into with you.
  2. Where we need to comply with a legal obligation.
  3. Where it is necessary for legitimate interests pursued by us or a third party and your interests and fundamental rights do not override those interests.

We may also use your personal information in the following situations, which are likely to be rare:

  1. Where we need to protect your interests (or someone else’s interests).
  2. Where it is needed in the public interest or for official purposes.

We will ask for your consent before sending third party marketing communications to you via email or text message or before we take any photos of you or of your teeth or jaw. You can withdraw your consent at any time. This won’t affect the lawfulness of any processing we carried out prior to you withdrawing your consent.

MARKETING – OPTING OUT

If you wish to have your Contact Data removed from our marketing database or if you do not want us to contact you for marketing purposes, please let us know by clicking the “Unsubscribe” option in any email we send to you, and providing the details requested, or by contacting us via the above webpage. We will take steps to ensure that this information is deleted as soon as reasonably practicable.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.

Note that 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 contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new patient (a) Identity

(b) Contact

(c) Medical

Performance of a contract with you
To provide our products and services and manage our relationship with you which will include:

(a) Notifying you about changes to our terms or Privacy Policy

(b) Asking you to leave a review or take a survey

(c) Manage payments, fees and charges

(d) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Profile

(f) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated, to study how patients use our products/services and to recover debts due to us)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity

(b) Contact

(c) Technical

(a) 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)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how patients use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, patient relationships and experiences (a) Technical

(b) Usage

Necessary for our legitimate interests (to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

Necessary for our legitimate interests (to develop our products/services and grow our business)

HOW WE USE PARTICULARLY SENSITIVE PERSONAL INFORMATION

We will only process sensitive personal information about you if it is necessary for the provision of health care or treatment, or where there may be other reasons for processing, such as it is in the public interest to do so or you have given us your consent. We will use your Health Data in order to provide appropriate dental care or treatment.

Do we need your consent?

We do not need your consent if we use special categories of your personal information in accordance with our written policy to provide health care or treatment. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. It is not a condition of your contract with us that you agree to any request for consent from us, but if you choose not to consent, we may not be able to provide you with the necessary treatment.

  1. WHO WILL RECEIVE YOUR PERSONAL DATA?

We may share your personal data for the purposes set out above to the following parties:

  • Business partners, suppliers and sub-contractors such as SurveyMonkey and Mailchimp, which we use to manage email marketing subscriber lists and send emails to you.
  • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • The NHS, HM Revenue & Customs, regulators and other authorities who require the reporting of processing activities in certain circumstances.
  • Third parties to whom we may choose to sell, transfer or merge parts or all of our business or assets.

HEALTH DATA

We may share your Health Data with the NHS or other medical health professionals. Responsibility for disclosure of Health Data rests with your clinician only. Under no circumstances will any other member of our staff make such a decision.

Unless it is an emergency, we will obtain your consent first and make sure you understand what information is being released, why and any likely consequences. We will release the minimum required. We will be prepared to justify our decisions and follow on action.

We may wish to use your personal information (eg. radiographs, study models) for teaching or marketing purposes. In such a case we will ask for your consent and ensure you cannot be identified from the information released unless we have received consent from you to do otherwise.

INTERNATIONAL TRANSFERS

We do not transfer your personal data outside of the European Economic Area.

  1. HOW LONG WILL WE KEEP YOUR PERSONAL DATA?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes for which we collected it.

We will retain your Technical and Usage Data for 2 years.

We will retain other personal data for 10 years following the guidelines set out in the Records Management Code of Practice for Health and Social Care 2016. We retain your information for this period in case any issues arise or in case you have any queries. Your information will be kept securely at all times.

Following the end of the 10 year period, your files and personal data we hold about you will be reviewed to determine whether the records should be retained for a further period or deleted. If we are required to obtain your consent to process your personal data, any information we use for this purpose will be kept until you withdraw your consent, unless we are entitled to retain the personal data on the basis of other grounds set out in the Data Protection Legislation.

In some circumstances we will 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.

  1. HOW DO WE PROTECT YOUR PERSONAL DATA?

We are required by Data Protection Legislation to ensure that your personal data is properly protected. We have put in place appropriate security measures to prevent your personal data from being lost, used or accessed in an unauthorised way.

We have also 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.

  1. WHAT ARE YOUR RIGHTS?

You benefit from a number of rights in respect of the personal data we hold about you. We have summarised the rights which may be available to you below, depending on the grounds on which we process your data. More information is available from the Information Commissioner’s Office website (https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation- gdpr/individual-rights/ ). These rights apply for the period in which we process your data.

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these 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 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.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it could 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.

Right to request access to your data

You have the right to ask us to confirm that we process your personal data, as well as having the right to request access to/copies of your personal data. You can also ask us to provide a range of information, although most of that information corresponds to the information set out in this fair processing notice.

A request to see records or for a copy will be referred to your clinician first.

Right to request rectification of your data

If you believe personal data we hold about you is inaccurate or incomplete, you can ask us to rectify that information. If we don’t feel it is appropriate, we will let you know why.

Right to be forgotten

In some circumstances, you have the right to ask us to delete personal data we hold about you. This right is available to you:

  • Where we no longer need your personal data for the purpose for which we collected it
  • Where we have collected your personal data on the grounds of consent and you withdraw that consent
  • Where you object to the processing and we don’t have any overriding legitimate interests to continue processing the data;
  • Where we have unlawfully processed your personal data (i.e. we have failed to comply with the Data Protection Legislation); and
  • Where the personal data has to be deleted to comply with a legal obligation

There are certain scenarios in which we are entitled to refuse to comply with a request. If any of those apply, we will let you know.

Right to request restriction of processing

In some circumstances, you are entitled to ask us to suppress processing of your personal data. This means we will stop actively processing your personal data but we don’t have to delete it. This right is available to you:

  • If you believe the personal data we hold isn’t accurate – we will cease processing it until we can verify its accuracy;
  • If you have objected to us processing the data – we will cease processing it until we have determined whether our legitimate interests override your objection;
  • If the processing is unlawful; or
  • If we no longer need the data but you would like us to keep it because you need it to establish, exercise or defend a legal claim.

Right to data portability

You have the right to ask us to provide your personal data in a structured, commonly used and machine-readable format so that you are able to transmit the personal data to another data controller. This right only applies to personal data you provide to us:

  • Where processing is based on your consent or for performance of a contract (i.e. the right does not apply if we process your personal data on the grounds of legitimate interests); and
  • Where we carry out the processing by automated means.

Right to object to processing

You are entitled to object to us processing your personal data:

  • If the processing is based on a legitimate interest (or those of a third party) or is necessary for the performance of a task in the public interest or in the exercise of official authority vested in us, and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your rights and freedoms; and/or
  • For direct marketing purposes (including profiling). This is an absolute right; and/or
  • For the purposes of scientific or historical research and statistics, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

We will stop processing your data unless we can demonstrate in some cases that we have compelling legitimate grounds to process your information which override your interests, rights and freedoms.

Right to withdraw consent at any time

You have the right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Right to complain about our processing

If you think we have processed your personal data unlawfully or that we have not complied with GDPR, you can report your concerns to the supervisory authority in your jurisdiction. The supervisory authority in the UK is the Information Commissioner’s Office (“ICO”).    You can call the ICO on 0303 123 1113 or get in touch via other means, as set out on the ICO website – https://ico.org.uk/concerns/.

  1. ANY QUESTIONS?

If you wish to make a request regarding any of the above rights, please contact us via the following webpage: https://thedentalsurgery.co.uk/contact-us/.

If you have any questions or would like more information about the ways in which we process your data, please contact our DPO as follows:

Bridget McGrade

Practice Manager

feedback@thedentalsurgery.co.uk

02076801800

Last Updated: December 2018

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