The Centre for Positive Health Privacy Policy   

The Centre for Positive Health (C4PH) is aware of its obligations under the General Data Protection Regulation (GDPR) and is committed to protecting the privacy and security of your personal information. This privacy notice describes, in line with GDPR, how we collect and use personal data about you during and after your time as a patient of this clinic. It also sets out how we use that information, how long we keep it for and other relevant information about your data.

This notice applies to current and former patients.

 

Data Controller details

The Clinic is a data controller, meaning that it determines the processes to be used when using your personal data. Our contact details are as follows: The Centre for Positive Health, 13 Whitchurch Road, Wellington, Telford, TF1 3DS, 01952 242596, dataprotection@c4ph.co.uk

Data protection principles

In relation to your personal data, we will comply with data protection law. This says that the personal information we hold about you must be:

• processed fairly, lawfully and in a clear, transparent way
• collected only for valid reasons that we find proper for the course of your time as a patient and not used in any way that is incompatible with those purposes
• only used in the way that we have told you about
• accurate and up to date
• kept only as long as is necessary for the purposes we outline 
• process it in a way that ensures it will not be used for anything that you are not aware of or have consented to (as appropriate), lost or destroyed 
• kept securely

Types of information we hold about you

Personal data or 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.

We hold many types of data about you, including:

• your personal details including your name, address, date of birth, email address, phone numbers
• banking or financial information
• gender 
• marital status
• next of kin and their contact numbers 
• personal medical or health information, including past medical history
• information concerning examination and treatment at your first and subsequent visits
• letters of referral to or from the clinic regarding your treatment with us.

 

Special categories of data

There are “special categories” of more sensitive personal data which require a higher level of protection, such as information about a person’s health or sexual orientation. 

We will use your special category data:

• to ensure the care you receive at the clinic is appropriate to your condition
• to determine reasonable adjustments that should be made for access to the clinic or to treatment.

We must process special categories of data in accordance with more stringent guidelines. We will process special categories of data when the following applies:

• you have given explicit consent to the processing (on our consent form)
• we must process the data in order to carry out our legal obligations 
• we must process data for reasons of substantial public interest

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

As with all cases of seeking consent from you, you will have full control over your decision to give or withhold consent and there will be no consequences where consent is withheld. Consent, once given, may be withdrawn at any time. There will be no consequences where consent is withdrawn.

How we collect your data

We collect data about you in a variety of ways and this will usually start when you make an enquiry to the clinic and continue when you attend your first and subsequent appointments. At this clinic, we keep paper and electronic records. Information we write down on paper may be transferred to our electronic system. We may receive information about you from your GP or other health care provider regarding your referral or, with your permission, additional information that will help us continue with your treatment. We may also hold the results of tests that you have undertaken and that are relevant to your treatment with the clinic.

Why we process your data (How we will use information about you)

The law on data protection allows us to process your data for certain reasons only, these are classified as legitimate interests. Most commonly, we will use your personal information in the following circumstances:

• in order for us to carry out our contract with you (your requesting treatment and our agreement to provide it constitutes a contract) which will include confirming appointments, informing you of changes to appointments or clinic arrangements, changes to facilities or services at the clinic.
• in order to provide you with the best possible treatment by recording health and treatment information which would be in your best interest.
• in order to carry out legally required duties such as those required by me by my government appointed regulator
• where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests

 

We may use your personal information in these rare situations:

• where we need to protect your or someone else’s interests
• where it is needed in the public interest or for official purposes

 

Situations in which we will use your personal information

We need all the categories of information to primarily allow us to perform our contract of treatment with you and to enable us to comply with legal obligations. 

If you do not provide your data to us

One of the reasons for processing your data is to allow us to carry out our duties in line with your contract of care with us. If you do not provide us with the data needed to do this, we will be unable to perform that care to ensure your best interests are being maintained. We may also be prevented from continuing with your treatment with us due to our legal obligations. 

 

Change of purpose

We will only use your personal information for the purposes for which we 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 information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. 

 

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

Automated decision making

No decision will be made about you solely on the basis of automated decision making (where a decision is taken about you using an electronic system without human involvement) which has a significant impact on you.

Sharing your data

Your data will be shared with colleagues within the Clinic but only where it is necessary for them to undertake their duties. This includes, for example, other chiropractors working for, at or on behalf of the clinic, reception and administration staff and other therapist who we may employ at time to time.

We may share your data with third parties in order to facilitate a referral to another healthcare practitioner, investigation or to keep your GP informed about your progress with treatment 

We may also share your data with third parties as part of a Clinic sale or restructure, or for other reasons to comply with a legal obligation upon us. We would always keep you informed of these situations.

Transferring information outside the EU 

We may share your data with bodies outside of the European Economic Area should the need arise. It is likely that this situation would be to share information regarding your treatment or ongoing care with healthcare practitioners in these countries in accordance with your wishes. However, we would not transfer your data unless we were assured that the country in question had data security and protection laws of equivalence to those of the UK and the European Economic Area.

Data Security – Protecting your data

We have put in place measures to protect the security of your information against accidental loss or disclosure, alteration, unauthorised access, destruction or abuse. We have implemented processes to guard against such. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. 

Where we share your data with third parties, we will ensure that your data are held securely and in line with GDPR requirements. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.

How long we keep your data for

In line with data protection principles, we only keep your data for as long as we need it for, which will be at least for the duration of you being a patient with us and we are legally required, by the Chiropractic regulator, to keep this data for eight years after your time as a patient has ended. To determine the any appropriate retention period for personal data beyond eight years 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. 

Once we no longer have a lawful use for retaining your information, we will dispose of it in a secure manner that maintains data security. 

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. 

 

Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your time as a patient with us.

 

Your rights in relation to your data

The law on data protection gives you certain rights in relation to the data we hold on you. 

• the right of access. You have the right to access the data that we hold on you. To do so, you should make a subject access request. Find out how to do this from 
• the right for any inaccuracies to be corrected. If any data that we hold about you is incomplete or inaccurate, you can require us to correct it. 
• the right to be informed. This means that we must tell you how we use your data, and this is the purpose of this privacy notice. We also must inform you of any changes to how we use your data.
• the right to have information deleted. If you would like us to stop processing your data, you have the right to ask us to delete it from our systems where you believe there is no reason for us to continue processing it.
• the right to restrict the processing of the data. For example, if you believe the data we hold is incorrect, we will stop processing the data (whilst still holding it) until we have ensured that the data is correct.
• the right to portability. You may request to transfer the data that we hold on you for your own purposes.

If you want to access your data, review, verify or correct your data, request we erase your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact The Data Controller, The Centre for Positive Health, 13 Whitchurch Road, Wellington, Telford, TF1 3DS, in writing.

 

Fees

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee for a second or subsequent copy of information or if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such 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 the information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

 

Right to withdraw consent

Where you have provided consent to the collection, processing and transfer of your data, you have the right to withdraw that consent at any time. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to use the data where so permitted by having a legitimate legal reason for doing so.

To withdraw consent, contact The Data Controller, The Centre for Positive Health, 13 Whitchurch Road, Wellington, Telford, TF1 3DS. dataprotection@c4ph.co.uk

Making a complaint

If you have any questions about this Privacy Notice or how we handle your information, please contact the Clinic’s The Data Controller, The Centre for Positive Health, 13 Whitchurch Road, Wellington, Telford, TF1 3DS. dataprotection@c4ph.co.uk

You have the right to make a complaint at any time to the supervisory authority in the UK for data protection matters, the Information Commissioner’s Office (ICO). 

CCTV policy

Centre for Positive Health Ltd (C4PH), uses closed circuit television (CCTV) images to provide a safe and secure environment for employees and for visitors to our premises, such as clients, contractors and suppliers, and to protect our property. 

This policy sets out the use and management of the CCTV equipment, images and recordings.

 

Purposes of CCTV

The purposes of installing and using CCTV include:

• To ensure the safety of clients and staff 
• To monitor the security of the business premises 

 

Location of cameras

Cameras are located at strategic points throughout the premises.  Cameras are positioned so that they cover communal or public areas outside the building together with the Reception area and they have been sited so that they provide clear images. 

 

All cameras are clearly visible

Appropriate signs are displayed so that employees, clients, and other visitors are aware they are entering an area covered by CCTV.

 

Recording and retention of images

Images produced by the CCTV equipment are intended to be as clear as possible so that they are effective for the purposes set out above. Maintenance checks of the equipment are undertaken on a regular basis to ensure it is working properly and that the media is producing high quality images.

Images are recorded in constant real-time (24 hours a day throughout the year)

As the recording system records digital images, any CCTV images that are held on the hard drive of a computer or server are deleted and overwritten on a recycling basis and, in any event, are not held for more than four weeks. Once a hard drive has reached the end of its use, it will be erased prior to disposal.
Images that are stored on, or transferred on-to, removable media such as CDs or pen drives are erased or destroyed once the purpose of the recording is no longer relevant. In normal circumstances, this will be a period of six weeks. However, where a law enforcement agency is investigating a crime, images may need to be retained for a longer period.

 

Access to and disclosure of audio and images

Access to, and disclosure of, images recorded on CCTV is restricted. This ensures that the rights of individuals are retained. Images can only be disclosed in accordance with the purposes for which they were originally collected.

The images that are filmed are recorded centrally and held in a secure location. Access to recorded images is restricted to the operators of the CCTV system and to those staff members who are authorised to view them in accordance with the purposes of the system. Viewing of recorded images will take place in a restricted area.

If media on which images are recorded are removed for viewing purposes, this will be documented.

Disclosure of images to other third parties will only be made in accordance with the purposes for which the system is used and will be limited to:

• The police and other law enforcement agencies, where the images recorded could assist in the prevention or detection of a crime or the identification and prosecution of an offender or the identification of a victim or witness. 
• Prosecution agencies, such as the Crown Prosecution Service. 
• Relevant legal representatives. 
• Individuals whose images have been recorded and retained (unless disclosure would prejudice the prevention or detection of crime or the apprehension or prosecution of offenders). 

Directors of C4PH are the only people permitted to authorise disclosure of images to external third parties such as law enforcement agencies.

All requests for disclosure and access to images will be documented, including the date of the disclosure, to whom the images have been provided and the reasons why they are required. If disclosure is denied, the reason will be recorded.

 

Individuals’ access rights

You have the right on request to receive a copy of the personal data that the C4PH holds about you, including CCTV images if you are recognisable from the image.

If you wish to access any audio or CCTV images relating to you, you must make a written request to the C4PH. Your request must include the date and approximate time when the images were recorded and the location of the CCTV camera, so that the images can be easily located, and your identity can be established as the person in the images. We will respond promptly and in any case within 30 calendar days of receiving the request.

We will first determine whether disclosure of your images will reveal third party information as you have no right to access CCTV images relating to other people. In this case, the images of third parties may need to be obscured if it would otherwise involve an unfair intrusion into their privacy.

If we are unable to comply with your request because access could prejudice the prevention or detection of crime or the apprehension or prosecution of offenders, you will be advised accordingly.

 

Staff training

We will ensure that all employees handling CCTV images are trained in the operation and administration of the systems.

 

Implementation

The Directors are responsible for the implementation of and compliance with this policy and the operation of the CCTV system and they will conduct a regular review of our use of CCTV.  Any complaints or enquiries about the operation of our CCTV system should be emailed to: cctv@c4ph.co.uk

 

Contact
If you have any questions, comments and requests regarding this policy please contact us at cctv@c4ph.co.uk