— Your Privacy
Privacy Policy
Shifnal Chiropratic Clinic Customer Privacy Notice
This privacy notice tells you what to expect us to do with your personal information.
- Contact details
- What information we collect, use, and why
- Lawful bases and data protection rights
- Where we get personal information from
- How long we keep information
- Who we share information with
- Sharing information outside the UK
- How to complain
Contact details
Post: 5 Dyas Close, Shifnal, Shropshire, TF11 9BQ, GB
Telephone: 01952 460947
Email: laurakate.cunningham@gmail.com
What information we collect, use, and why
We collect or use the following information to provide patient care and services:
- Name, address and contact details
- Pronoun preferences
- Date of birth
- Health information (including medical conditions, allergies, medical requirements and medical history)
- Payment details (including card or bank information for transfers and direct debits)
- Records of meetings and decisions
We also collect the following special category information to provide patient care. This information is subject to additional protection due to its sensitive nature:
- Health information
We collect or use the following personal information for patient app or portal functionality:
- Names and contact details
- Payment details
We collect or use the following personal information to comply with legal requirements:
- Name
- Contact information
- Any other personal information required to comply with legal obligations
We also collect the following special category information to comply with legal requirements. This information is subject to additional protection due to its sensitive nature:
- Health information
We collect or use the following personal information for information updates, marketing or market research purposes:
- Names and contact details
- Marketing preferences
We collect or use the following personal information for dealing with queries, complaints or claims:
- Names and contact details
- Financial transaction information
- Correspondence
- Patient health records
We also collect the following special category information for dealing with queries, complaints or claims. This information is subject to additional protection due to its sensitive nature:
- Health information
Lawful bases and data protection rights
Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:
- Your right of access – You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.
- Your right to rectification – You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.
- Your right to erasure – You have the right to ask us to delete your personal information. Read more about the right to erasure.
- Your right to restriction of processing – You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.
- Your right to object to processing – You have the right to object to the processing of your personal data. Read more about the right to object to processing.
- Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability.
- Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.
If you make a request, we must respond to you without undue delay and in any event within one month.
To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.
Our lawful bases for the collection and use of your data
Our lawful bases for collecting or using personal information to provide patient care, services, pharmaceutical products and other goods are:
- Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
- Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
- Ensuring accurate and complete health records so that any care provided is as safe and beneficial for the patient, as stipulated by the General Chiropractic Council. Ensuring those records can be correctly identified as belonging to an individual.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Our lawful bases for collecting or using personal information for patient app or portal functionality are:
- Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
- Booking portal – allowing patients to book appointments either online or by telephone/email. Payment details are required to pay a deposit to secure appointments.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Our lawful bases for collecting or using personal information to comply with legal requirements are:
- Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
- Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability.
Our lawful bases for collecting or using personal information for information updates, marketing or market research purposes are:
- Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
- Information updates – contact patients in the case of appointments changing or being cancelled, clinic being closed for any reason or other necessary communications such as appointment reminders.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:
- Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
- Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
- Where they relate to the care a patient has received in the clinic, to identify the correct records and ensure all responses are accurate to the situation.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Where we get personal information from
- Directly from you
How long we keep information
Health records are kept for 7 years, and will then be securely destroyed both in physical and digital formats. Payment details are collected but not retained by the Clinic, and are therefore subject to SumUp/Goldie app retention schedules.
For more information on how long we store your personal information or the criteria we use to determine this please contact us using the details provided above.
Who we share information with
Data processors
Goldie: This data processor is our booking platform, and also provides a payment service for patients paying a deposit to secure their appointment.
SumUp: This data processor processes card payments in the clinic.
Others we share personal information with
- Other health providers (e.g. GPs and consultants)
- Insurance companies, brokers and other intermediaries
- Organisations we need to share information with for safeguarding reasons
- Emergency services
- External auditors or inspectors
Duty of confidentiality
We are subject to a common law duty of confidentiality. However, there are circumstances where we will share relevant health and care information. These are where:
- You’ve provided us with your consent (we have taken it as implied to provide you with care, or you have given it explicitly for other uses);
- We have a legal requirement (including court orders) to collect, share or use the data;
- On a case-by-case basis, the public interest to collect, share and use the data overrides the public interest served by protecting the duty of confidentiality (for example sharing information with the police to support the detection or prevention of serious crime);
- If in England or Wales – the requirements of The Health Service (Control of Patient Information) Regulations 2002 are satisfied; or
- If in Scotland – we have the authority to share provided by the Chief Medical Officer for Scotland, the Chief Executive of NHS Scotland, the Public Benefit and Privacy Panel for Health and Social Care or other similar governance and scrutiny process.
Sharing information outside the UK
Where necessary, our data processors may share personal information outside of the UK. When doing so, they comply with the UK GDPR, making sure appropriate safeguards are in place.
For further information or to obtain a copy of the appropriate safeguard for any of the transfers below, please contact us using the contact information provided above.
- Organisation name: Goldie
- Category of recipient: Booking and payment app
- Country the personal information is sent to: USA
- How the transfer complies with UK data protection law: Goldie are fully compliant with EU GDPR regulations and therefore all data transfers performed by them are compliant with UK data protection law.
How to complain
If you have any concerns about our use of your personal information, you can make a data protection complaint to us:
Email: laurakate.cunningham@gmail.com
Post: 5 Dyas Close, Shifnal, TF11 9BQ
If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
Website: https://www.ico.org.uk/make-a-complaint