Privacy Policy

Poole Earwax Clinic Limited 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

214A Lower Blandford Road, , , BROADSTONE, Dorset, BH18 8DX, GB

Telephone

01202 985288

Email

john@pooleearwaxclinic.co.uk

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

· Gender

· 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, services, pharmaceutical products and other goods. This information is subject to additional protection due to its sensitive nature:

· Health information

We collect or use the following information for safeguarding or public protection reasons:

· Name, address and contact details

· Health information (including medical conditions, allergies, medical requirements and medical history)

· Relevant information from previous investigations

We also collect the following special category information for safeguarding or public protection reasons. This information is subject to additional protection due to its sensitive nature:

· Health information

We collect or use the following personnel information to comply with legal requirements:

· Name

· Contact information

· Identification documents

· Health and safety information

· Any other personal information required to comply with legal obligations

· Right to work

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 dealing with queries, complaints or claims:

· Names and contact details

· Addresses

· Payment details

· Purchase or service history

· Customer or client accounts and records

· Information relating to health and safety (including incident investigation details and reports and accident book records)

· Correspondence

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:

· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

· 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.

· Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

Our lawful bases for collecting or using personal information for safeguarding or public protection reasons are:

· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

· Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

Our lawful bases for collecting or using personal information to comply with legal requirements are:

· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

· Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:

· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

· 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.

· Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

· Public task – we have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All of your data protection rights may apply, except the right to erasure and the right to portability.

Where we get personal information from

· Directly from you

· Family members or carers

How long we keep information

In line with other medical information the data will be held for 7 years after you were last seen. The data is stored on secure servers owned by a company called Cliniko through which we run our clinic management software.

Who we share information with

Data processors

Cliniko

This data processor does the following activities for us: As the processor of your data, Cliniko helps us to meet your needs as a controller—They provide us with the tools needed to comply with your patients\' requests. Below is a list of requirements related to our use of Cliniko, and how they help us comply with those requirements: 

Remove patients from marketing-related communications. 

Modify patients\' personal details.

Provide patients with a copy of all their personal information.

Delete all of a patient\'s information from Cliniko. 

Record whether or not a patient has consented to your clinic\'s privacy policy. 

Let patients consent to your privacy policy when booking online.

Others we share personal information with

· Current employees

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: Cliniko

Category of recipient: Data Processor

Country the personal information is sent to: Australia

How the transfer complies with UK data protection law: The country or sector has been assessed as providing adequate protection to data subjects (also known as Adequacy Regulations or UK data bridge)

How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

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