The practice aims to meet the requirements of the Data Protection Act 2018, the General Data Protection Regulation (GDPR], the guidelines on the Information Commissioner’s website as well as our professional guidelines and requirements.
The information Governance Lead is Mrs Alison Page.
The data controller is Dr Tim McDonogh.
You will be asked to provide personal information when joining the practice. The purpose of us processing this data is to provide optimum health care to you.
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.
- 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 a 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.
- [Personal data is stored in the [EU] 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 and [when a patient subscribes to an email list].
The lawful basis for processing special category data such as patients’ and employees’ health data is:
- 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 a contract with a health professional.
The lawful basis of processing personal data such as name, address, email or phone number is:
- Consent of the data subject.
- Processing is necessary for the performance of a contract with the data subject or to take steps to enter into a contract.
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 procedure available from the practice.
Telephone recording policy
The Elegant Smiles Dental Studio has a telephone system that is capable of recording conversations. Like many other organisations, this is standard practice that allows the recording of telephone calls for quality monitoring, training, compliance and security purposes.
All calls received into Elegant Smiles Dental Studio will be recorded and will be retained for a period of 2 months. These recordings will only be used for the purposes specified in this policy.
In order to maintain high standards and protect the public and staff we need to record all telephone calls received into Elegant Smiles Dental Studio and retain them for a limited period of time.
We shall ensure that the use of these recordings is fair and that we comply with the requirements of the relevant legislation.
All calls made to Elegant Smiles Dental Studio will under normal circumstances not be retrieved or monitored unless:
- It is necessary to investigate a complaint.
- It is part of a management ‘spot check’ that customer service standards are being met.
- There is a threat to health and safety to staff or visitors or for the prevention or detection of crime.
- It is necessary to check compliance with regulatory procedures.
- It will aid standards in call handling through use in training and coaching our staff. However, this will only be permitted if the recording is edited so that the caller remains anonymous and the member of staff who was party to the call agrees to its being used in this way.
If it becomes clear that a communication is private or the person making the call says that they do not wish to have their call recorded, the call recording will be stopped.
Personal data collected in the course of recording activities will be processed fairly and lawfully in accordance with data protection law. It will be:
- Adequate, relevant and not excessive.
- Used for the purpose(s) stated in this policy only and not used for any other purpose.
- Accessible only by managerial staff after securing permission from the practice owner or director.
- Treated confidentially.
- Stored securely.
- Not kept for longer than necessary and will be securely destroyed once the issue (s) in question have been resolved.
Where call recording facilities are being used we will inform the caller that their call is being monitored/recorded for quality/training purposes so that they have the opportunity to consent by continuing with the call or hanging up.
You have the following personal data rights:
- The right to be informed.
- The right of access.
- The right to rectification.
- The right to erasure (clinical records must be retained for a certain time period).
- 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 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 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 and Information Governance Procedures.
Comments, suggestions and complaints
Please contact Alison Page at the practice for a comment, suggestion or a complaint about your data processing at firstname.lastname@example.org/elegantsmilesdental, or 020 8660 4365 or by writing to or visiting the practice at: Elegant Smiles Dental Studio, 45 Foxley Lane, Purley, Surrey, CR8 3EH.
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 Consent Policy
- Privacy Impact Assessment, Information Governance Procedures
Phone: 020 8660 4365
Address: Elegant Smiles Dental Studio, 45 Foxley Lane, Purley, Surrey, CR8 3EH