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 data controller is Andrew Tomalin, the Information Governance Lead is Katriona Page who is also the Data Protection Officer.
This Privacy Notice is available at reception and by email if you contact email@example.com or by calling 020 8399 2376.
You will be asked to provide personal information when joining the practice. The purpose of processing your personal data is to provide you with optimum dental health care and prevention.
The categories and examples of data we process are:
Personal data for the provision of dental health care
Personal data for the purposes of providing treatment plans, recall appointments, reminders or estimates.
Personal data such as details of family members for the provision of health care to children or for emergency contact details.
Personal data for the purposes of employed and self-employed team members employment and engagement respectively.
Personal data for the purposes of direct mail/email/text/other to inform you of important announcements or about new treatments or services.
Personal data – IP addresses so that we can understand our patients better and inform our marketing approach as well as improve the web site experience.
Special category data including health records for the purposes of the delivery of health care and meeting our legal obligations.
Special category data including health records.
Special category data to meet the requirements of the Equality Act 2010.
Special category data details of criminal record checks for employees and contracted team members.
We minimise the data that we keep, and do not keep it for longer than necessary.
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 a secondary care such as a hospital we will gain the individual’s permission before the referral is made and the personal data is shared. Your data will be shared with the NHS if you are having NHS treatment.
Personal data is stored in the UK or EU whether in digital or hard copy format.
Personal data is stored outside of the UK and/or EU in digital format when suitable safeguards have been put into place to allow personal data to be transferred.
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.
For full details or where your data is stored, please ask to see Information Governance Procedures (M 217C).
We have established the following lawful bases for processing your data:
Our lawful bases for processing personal data:
The legitimate interests of the dental practice
Processing is necessary for the performance of a contract with the data subject or to take steps to enter into a contract.
Consent of the data subject
To comply with our legal obligations.
Our Article 9 conditions for processing special category data:
Processing is necessary for health care purposes
Processing necessary for identifying or keeping under reqiew the existence or absence of equality of opportunity or treatment between groups of people with the view to enabling such equality to be promoted or maintained.
We obtain consent of the data subject to process criminal record checks.
The reasons we process the data include:
To maintain your contemporaneous clinical records
To provide you with dental treatment, prevention and oral health advice
To carry out financial transactions with you
To manage your NHS dental care treatment
To send your personal data to the General Dental Council or other authority as required by law.
To communicate with you as and when required including appointment reminders, treatment plans, estimates and other communications about your treatment or the practice.
To communicate with your next of kin in an emergency
If a parent or carer to communicate with you about the person you parent or care for.
To refer you to other dentists or doctors and health professionals as required.
To obtain criminal record disclosures for team members
For debt recovery
To continually improve the care and service you receive from us.
The personal data we process includes:
Your name, address, gender, date of birth, NHS number, medical history, dental history, family medical history, family contact details, marital status, financial details for processing payment, your doctor’s details and details of treatment at the practice. We may process more sensitive special category data including ethnicity, race, religion, or sexual orientation so that we can meet our obilgations under the Equality Act 2010, or for example to modify treatment to suit your religion and to meet NHS obligations.
The retention period for special data in patient records is a minimum of 11 years and may be longer for complex records or to meet our legal requirements. The retention periods for other personal data is 2 years after it was last processed. Details of retention periods are available in the Record Retention (M 215) procedure available from the practice.
We obtain your personal details when you enquire about our care and service, when you join the practice, when you register online, when you complete a registration or medical history form and when another practitioner refers you for treatment at our practice. Occasionally patients are referred to us from other official sources such as NHS clinics or hospitals.
You have the following personal data rights:
The right to be informed about the collection and use of your personal data
The right of access – to have a copy of the data we hold about you. Generally, we will not charge for this service.
The right to rectification – to correct the data we have if it is inaccurate or incomplete.
The right to deletion of your personal data (clinical records must be retained for a certain time period)
The right to restrict processing of your personal data
The right to data portability – to have your data transferred to someone else
The right to object to the processing of your personal data
Rights in relation to automated decision making and profiling
Further details of these rights can be seen in our Information Governance Procedures (M 217C) or at the Information Commisioner’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 communications 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 communicaiton methods such as telephone, email or text.
We have carried out a Privacy Impact Asssessment in Sensitive Information Map, PIA and Risk Assessment (M217Q) and you can request a copy from the details of how we ensure security of personal data is in our Security Risk Assessment (M217M) and Information Governance Procedures (M217C).
Comments, suggestions and complaints
Please contact the IG Lead at the practice for a comment, suggestion or a complaint about your data processing at firstname.lastname@example.org, or 020 8399 2376 or by writing to or visiting the practice at Stedham House Dental Surgery, 34 Ewell Raod, Surbiton, Surrey, KT6 6HX. 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 clain 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 (M233-DPT), Consent Policy (M 233-CNS)
Sensitive Information Map, PIA and Risk Assessment (M217Q), Information Governance Procedures (M217C), Record Retention (M 215).
If you have an enquiry or a request please contact the Information Governance Lead, Katriona Page, Stedham House Dental Surgery, 34 Ewell Road, Surbiton, Surrey KT6 6HX. Email: email@example.com, Tel: 020 8399 2376. Thank you.
Data Opt- Out Policy
How the NHS and care services use your information
Stedham House Dental Surgery is one of many organisations working in the health and care system to improve care for patients and the public. Whenever you use a health or care service, such as attending Accident and Emergency or using Community Care services, important information about you is collected in a patient record for that service. Collecting this information helps to ensure you get the best possible care and treatment. The information collected about you when you use these services can also be used and provided to other organisations for purposes beyond your individual care, for instance to help with:
Improving the quality and standards of care provided
Research into the develpment of new treatments
Preventing illness and diseases
This may only take place when there is a clear legal basis to use this information. All these uses help to provide better health and care for you, your family and future generations. Confidential patient information about your health and care is only used like this where allowed by law.
Most of the time, anonymised data is used for research and planning so that you cannot be idenified in which case your confidential patient information isn’t needed.
You have a choice about whether you want your confidential patient information to be used in this way. If you are happy with this use of information you do not need to do anything. If you do chose to opt out your confidential patient information will still be used to support your indiviual care. To find out more or to register your choice to opt outm please visit www.nhs.uk/your-nhs-data-matters. On this web page you will:
See what is meant by confidential patient information
Find examples of when confidential patient information is used for individual care and examples of when it is used for purposes beyond individual care
Find out more about the benefits of sharing data
Understand more about who uses the data
Find out how your data is protected
Be able to access the system to view, set or change your opt-out setting
Find the contact telphone number if you want to know any more or to set/change your opt-out by phone
See the situations where the opt-out will not apply
You can also find out more about how patient information is used at:
https://www.hra.nhs.uk/information-about-patients/ (which covers health and care research); and https://understandingpatientdata.org.uk/what-you-need-know (which covers how and why patient information is used, the safeguards and how decisions are made)
You can change your mind about your choice at any time.
Data being used or shared for purposes beyond individual care does not include your data being shared with insurance companies or used for marketing purposes and data would only be used in this way with your specific agreement.
NHS Health and care organisations had until 2020 to put systems and processes in place so they can be compliant with the national data opt-out and apply your choice to any confidential patient information they use of share for purposes beyond your individual care.
Our practice only uses your personal health data to provide individualised care to you and does not disclose your data for any other purposes. The national data opt-out does not apply to our usage of your data and we are compliant with the policy.
Our practice does not take part in research projects where the opt-out could apply. We are compliant with the national data opt-out policy.
Processing of Staff and Candidates’ Information
This section explains how Stedham House Dental Surgery processes the information of staff and applicants for job roles within the practice.
What information do we have?
So that we can provide a safe and professional service, we need to keep certain records about our team members. We may record the following types of data:
- Your basic details and contact information e.g. your name, address, date of birth, National Insurance number and next of kin.
- Your financial details e.g. details so that we can pay you, insurance, pension and tax details
- Your training records
We also record the following data which is classified as “special category”:
- Health and social care data about you, which might include both your physical and mental health data- we will only collect this if it is necessary for us to know as your employer, e.g. fit notes or in order for you to claim statutory maternity/paternity pay
- We may also, with your permission, record data about you race, ethnic origin, sexual orientation or religion.
As part of your engagement with the practice, you may be required to undergo a Criminal Record Check. this information is not kept for longer than is necessary – usually not more than 6 months following the recruitment decision, unless a dispute is raised or, in exceptional circumstances.
Why do we have this data?
We require this data so that we can contact you, pay you and make sure you receive the training and support you need to perform your job. By law, we need to have a lawful basis for processing your personal data.
We process your data because:
- We have a legal obligation under UK employment law
- We have a legitimate interest in processing your data – for example, for administration of training or learning course or emergency planning etc. These legitimate interests will be customary, or necessary for operational, administrative, HR and recruitment purposes and to otherwise manage employment relationship and interation between employees.
- We are required to provide data to our regulator, CQC/NHS, as part of our public interest obligations.
- We are requried to do so in our performance of another public task.
- We process your special category data because it is necessary for us to process requests for sick pay or maternity pay
- If we request your criminal records data it is because we have a legal obligation to do this due to the type of work you do. This is set out in the Data Protection Act 2018 and the Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975
- We may also process you data with your consent. If we need to ask for your permission, we will offer you a clear choice and ask that you confirm to us that you consent. We will also explain clearly to you what we need the data for and how you can withdraw your consent.
Where do we collect your data from?
As your employer we need to receive specific data about you. This is collected from or shared with:
- You or your legal representative(s)
- Third parties – for example this could include references from your previous job.
We do this face to face, via phone, via email, via our website, via post, via application forms, via apps.
How do we share your data?
Third parties are organisations we have a legal reason to share your data with. These include:
- Our pension scheme, NEST
- External payroll provider, Iris Software
- Organisations we have a legal obligation to share information with i.e. for safeguarding, the CQC
- the police or other law enforcement agencies if we have to by law or court order
How long do we hold your data?
The retention period for staff records is 6 years, however, certain information relating to team members may lawfully be kept for longer. Team members should refer to Record Retention (M215) for further details on how this practice keeps and disposes of staff data. Application forms and interview notes for unsuccessful candidate are kept for one year.
As an individual you have certain rights regarding our processing of your personal data, ncluding a right to lodge a complaint with the Information Commissioner’s Office (ICO) as the relevant supervisory authority. For more information on your personal data rights, you can access infromation and advice on the ICO’s website.
You can request a copy of your personal file by contacting the Information Governance Lead.
Privacy Notice for Children
The practice keeps records of your name, address, date of birth and details of any health problems as well as details of your dental treatment and details about you family. We keep this information so that we can provide you with the best dental care. Your personal information is kept very confidentially and securely.
We only use your personal information so we can give you the best dental care and for sending reminders to you.
We only pass you personal information to another dentist, doctor or hospital if you have a problem that needs their special skills and you need to go and see them. We will not give your information to anyone else unless the law allows us to or we have to provide it for legal reasons.
If you leave the practice, we will stop using your information, but will keep it confidentially and securely until you are 25 years old (or 26 years old if you were 17 when your last treatment ended), or for 15 years (NHS patient)/11 years (private patient) after the completion of treatment, whichever is longer.
We will then review if and when we can delete it. You can always ask for a copy of the information we hold for you, we can transfer it to another dentist or doctor at your request and you can ask us to stop using your personal information to send letters or contact you in other ways if you are no longer a patient at the practice.
When you reach 18 years of age the Privacy Notice about how we process you personal information will change to the adult version.
If you would like a copy of the information we hold about you or if you have any other enquiries about it such as to change an error in your information or to provide a copy of your information to somebody else please contact:
The Information Governance Lead, Katriona Page, Stedham House Dental Surgery, 34 Ewell Road, Surbiton, Surrey, KT6 6HX. Email: firstname.lastname@example.org, Tel: 020 8399 2376