GDPR 2018 – PRIVACY and CONFIDENTIALITY NOTICE
This document refers to personal data, which is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain.
The General Data Protection Regulation (GDPR) which is EU wide and far more extensive than its predecessor the Data Protection Act, along with the Privacy and Electronic Communications Regulations (PECR), seek to protect and enhance the rights of EU data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of
personal data within the EU and its storage within the EEA.
The dental practice, cksuperdent Ltd, based at 1st Floor, 11 Welbeck Street, London W!G 9XZ, which hereafter for the purposes of this Privacy Notice will be referred to as cksuperdent Ltd is pleased to provide the following information:
• cksuperdent Ltd provides dental care and is ICO compliant, ICO reg: Z9315780.
• We are committed to protecting your privacy when dealing with your personal information. This privacy notice provides details about the information we collect about you, how we use it and how we protect it. It also provides information about your rights.
• We are committed to ensuring your information is secure. In order to prevent unauthorised access or
disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and
secure the information we collect.
a) For the purposes of providing dental treatment cksuperdent may require in addition to your personal information (name, address, date of birth, contact details) a detailed medical information. We will only collect what is relevant and necessary for your treatment. When you visit our practice we will make notes which may include details concerning your medication and other issues affecting your health. This data is always held securely, is not shared with anyone not involved in your treatment, although for data storage purposes it may be handled by pre-vetted staff who have all signed an integrity and confidentiality agreement. To be able to process your personal data it is a condition of any treatment that you give your explicit consent to allow cksuperdent Ltd to document and process your personal medical data. Contact details provided by you such as telephone numbers, email addresses, postal addresses may be used to remind you of future appointments and provide information concerning your treatment. As part of our obligations as healthcare practitioners there may be circumstances related to your treatment that will require the sharing of your medical records with other healthcare practitioners e.g. GPs, consultants and/ or medical insurance companies. Where this is required we will always inform you first unless we are under a legal obligation to comply.
b) For marketing purposes, cksuperdent Ltd may also use the contact details provided by you to respond to your enquiries, including making telephone contact and emailing information to you which the practice believes may be of interest to you. c) In making initial contact with the practice you consent to cksuperdent Ltd maintaining a marketing dialogue with you until you either opt out (which you can do at any time) or we decide to desist in promoting our services. cksuperdent Ltd do not broker your data and you can ask to be removed from our marketing
database by emailing or phoning the practice using the contact details provided at the end of this Privacy Notice.
d) Some basic personal data may be collected about you from the marketing forms you complete, from records of our correspondence and phone calls and details of your visits to our website, including but not limited to, personally identifying information like internet Protocol (IP) addresses.
e) cksuperdent Ltd will only collect the information needed so that we can provide you with the services you require, the business does not sell or broker your data.
Legal basis for processing any personal data:
To meet our contractual obligations obtained from explicit Patient Consent and legitimate interest to respond to enquiries concerning the services provided.
We process your personal information for a number of legitimate interests:
To promote dental care. To manage all aspects of our relationship with you. To provide healthcare services. For marketing as allowed by law and to show you information that is of interest to you based on our understanding of your preferences. To help us improve our services and products, keep our records up todate and in order to exercise our rights or handle claims.
Through agreeing to this privacy notice you are consenting to cksuperdent Ltd processing your personal data for the purposes outlined. You can withdraw consent at any time by using the postal, email address or telephone number provided at the end of this Privacy Notice.
cksuperdent Ltd will keep your personal information safe and secure, only staff engaged in providing your treatment will have access to your patient records, although our administration team will have access to your contact details so they can make appointments, deal with enquiries and manage invoices. cksuperdent Ltd will not disclose your Personal information unless compelled to, in order to meet legal obligations,
regulations or valid government requests.
cksuperdent will process personal data during the duration of any treatment and will continue to store only the personal data needed for the periods set by law or recommended by professional bodies, regulators or associations. Currently 12 years after last attended for treatment, or to the age of 25 years for a minor.
All data is held in the UK. cksuperdent Ltd does not store personal data outside the EEA.
Your right as a data subject:
At any point whilst cksuperdent Ltd are in possession of, or processing your personal data, all data subjects have the following rights:
a) Right of access – you have the right to request a copy of the information that we hold about you.
b) Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
c) Right to be forgotten – in certain circumstances you have the right to withdraw consent and can ask for the data we hold about you to be erased from our records.
d) Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.
e) Right of portability – you have the right to have the data we hold about you transferred to another organisation.
f) Right to object – you have the right to object to certain types of processing such as direct marketing.
g) Right to object to automated processing, including profiling, you also have the right not to be subject to the legal effects of automated processing or profiling.
In the event that cksuperdent Ltd refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge. At your request cksuperdent can confirm what information it holds about you and how it is processed.
You can request the following information:
a) Identity and the contact details of the person/cksuperdent Ltd that has determined how and why to process your data.
b) Contact details of the data protection officer, where applicable.
c) The purpose of the processing as well as the legal basis for processing.
d) If the processing is based on the legitimate interests of cksuperdent Ltd and information about these.
e) The categories of personal data collected, stored and processed.
f) Recipient/categories of recipients that the data is/will be disclosed to.
g) How long the data will be stored.
h) Details of your rights to correct, erase, restrict or object to such processing.
i) How to lodge a complaint with the supervisory authority (ICO).
j) Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
k) The source of personal data if it wasn’t collected directly from you.
l) Any details and information of automated decision making, such as profiling, and any meaningful information about logic involved, as well as the significance and expected consequences of such processing.
To access what personal data is held, identification will be required.
cksuperdent Ltd will accept the following forms of identification (ID) when information on your personal data is requested: a copy of your birth certificate, passport, driving licence and a utility bill not older than 3 months. A minimum of one piece of photo ID listed above and a supporting document is required. All requests should be made to cksuperdent Ltd – contact details below.
In the event that you wish to make a complaint about how your personal data is being processed by cksuperdent Ltd you have the right to complain to us. If you do not get a response within 30 days you can complain to ICO – contact details below. Dr Christina A. Kyrkou cksuperdent Ltd
11 Welbeck Street
London W!G 9XZ
Tel: 0207 486 0266
Wilmslow SK9 5AF
Tel: 0303 123 1113