OSTEOHEALTH LTD PRIVACY NOTICE 2018
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.
We diagnose, treat, rehabilitate, manage and optimise of injury recovery and health conditions, as well as enhancement of fitness and physical performance (Services).
- What data do we collect about you.
Personal data means any information capable of identifying an individual. It does not include anonymised data. We may process certain types of personal data about you as follows:
- Identity Data may include your first name, maiden name, last name, username, marital status, title, date of birth, gender, membership number.
- Medical data may be details concerning your medication, injuries, medical history, treatment and other issues affecting your health, fitness and/or performance
- Contact Data may include your address, email address and telephone numbers, emergency contact details.
- Transaction Data may include details about appointments, payments between us including charges, block payments, membership and event payments by you. Appointments and some payments may utilize a third-party system and data may be stored on those systems. We have confirmed that they will keep that data secure and confidential to us or those authorized by us.
- Technical Data may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.
- Profile Data may include your membership status, sports clubs and associations, payment status, your interests, preferences, feedback and survey responses.
- Marketing and Communications Data may include your preferences in receiving marketing communications from us and our third parties and your communication preferences.
We may also process Aggregated Data from your personal and profile data, but this data does not reveal your identity and as such in itself is not personal data.
We do not collect any other Special Category Data (previously known as Sensitive Data under previous Data Protection Act)
3. Personal Data
a) For the purposes of providing Services, we need Identity and Medical data about you, including detailed medical information, as well as Contact, Transaction and other data. We will collect what is relevant and necessary for your Services. When you visit our practice, we will make notes which may include details concerning your medication, treatment and other issues affecting your health, fitness and/or performance. This data is held securely, is not shared with anyone outside our Organisation except as consented to by you and as required and set out below. It may be handled by pre-vetted staff who have all signed an integrity and confidentiality agreement. To enable us to process your data to provide Services it is a condition of any Service that you have thereby granted us your explicit consent to allow us to document and process your data, including 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 reports or other information concerning Services. As part of our obligations as primary healthcare practitioners there may be circumstances related to your Services, on-going care or medical diagnosis that will require the sharing of your medical records with other healthcare practitioners and entities e.g GPs, consultants, surgeons and/or medical insurance companies. Where this is required we will discuss this with you unless we are under a legal obligation to comply.
b) For information and marketing purposes, we 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 us you consent to us 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. We may occasionally also act on behalf of our clients in the capacity of data processor, when we may promote other practitioners based at our premises, who may not be employed by us. We 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 and surveys 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.
f) Website information – We do not store any of your browsing history when you are viewing our website, however we may use third party services such as Google Analytics to improve your experience on our site. These third party sites may collect information about your mobile phone, computer or other device from which you access the website. Such information may include your domain name and IP address, details of your computer operating system and browser and unique number identifiers that are automatically generated by our systems when you visit our website. Some of this information is retained in “cookie” files on your computer.
g) We will collect the information needed so that we can provide you with the Services you require; we do not sell or broker your data.
4 – Legal basis for processing any personal data
We can process personal data on various legal bases:
- Performance of our contract with you to provide the Services and related products
- Our care and management of you and Services for you
- Liaising with third parties in connection with services, for example with a consultant physician, hospital, insurance company or service provider
- For processing operations for which we obtain your consent, for example, purchase of block sessions or consent to marketing emails
- Promote treatments and Services
- Processing inquiries concerning our products or services
- Compliance with UK laws and guidance provided by UK regulatory bodies and where we are subject to a legal obligation by which processing of personal data is required
- Necessary for our legitimate interests to monitor payments, recover debts owed to us and to pay third parties
- Processing operations (eg as provided in Article 6(1)(f) of the GDPR): in specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests
- Legitimate interests in operating the Organisation, provision of administration and IT services, network security, to prevent fraud and in the context of liaising with related people and entities.
- Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other parties who have a need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
The Organisation will not disclose your Personal Information unless compelled to, in order to meet legal obligations, regulations or valid governmental requests. The practice may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of its staff.
- Retention Policy
We will process and retain your data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, contractual, accounting, tax or reporting requirements. As a general rule we will retain most data for about 8 years. To determine the appropriate retention period for personal data, 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. Records concerning minors who have received treatment will be retained until the child has reached the age of 25.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
- Your rights as a data subject
At any point whilst the Organisation are in possession of, or processing your personal data, all data subjects have the following rights:
- Right of access – you have the right to request a copy of certain the information that we hold about you.
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
- Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.
- Right of portability – you have the right to have the data we hold about you transferred to another organisation.
- Right to object – you have the right to object to certain types of processing such as direct marketing.
- 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.
You can see more about these rights at:
If you wish to exercise any of the rights set out above, please email us at firstname.lastname@example.org. You may be requested to pay a fee to access your personal data (or to exercise any of the other rights), particularly if your request is clearly unfounded, repetitive, unduly onerous or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
- You can request the following information:
- Identity and the contact details of the person or the Organisation that has determined how and why to process your data.
- Contact details of the data protection officer, where applicable.
- The purpose of the processing as well as the legal basis for processing.
- If the processing is based on the legitimate interests of the Organisation and information about these interests.
- The categories of personal data collected, stored and processed.
- Recipient(s) or categories of recipients that the data is/will be disclosed to.
- How long the data will be stored.
- Details of your rights to correct, erasure, restrict or object to such processing.
- Information about your right to withdraw consent at any time.
- How to lodge a complaint with the supervisory authority (ICO).
- 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.
- The source of personal data if it wasn’t collected directly from you.
- Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
Requests should be made to: email@example.com
The Organisation will accept the following forms of identification (ID) when information on your personal data is requested: a copy of your driving licence, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If the Organisation is dissatisfied with the quality, further information may be sought before personal data can be released. All requests should be made to firstname.lastname@example.org or by phoning +44 (0) 2077209644 or writing to us at the address further below.
In the event that you wish to make a complaint about how your personal data is being processed by the Organisation you have the right to complain to us at email@example.com. If you do not get a response within 30 days, you can complain to the ICO (see above).
When we provide services, we want to make them easy, useful and reliable. This sometimes involves placing small amounts of information on your computer. These are called ‘cookies’. These cookies cannot be used to identify you personally and are used to improve services for you, for example through:
- Letting you navigate between pages efficiently
- Enabling a service to recognise your computer so you don’t have to give the same information during one task
- Recognising that you have already given a username and password so you don’t need to enter it for every web page requested
- Measuring how many people are using services, so they can be made easier to use and that there is enough capacity to ensure they are fast
To learn more about cookies, see:
Users typically have the opportunity to set their browser to accept all or some cookies, to notify them when a cookie is issued, or not to receive cookies at any time. The last of these options, of course, means that personalised services cannot be provided and the user may not be able to take full advantage of all of a website’s features. Refer to your browser’s Help section for specific guidance on how it allows you to manage cookies and how you may delete cookies you wish to remove from your computer. Multiple cookies may be found in a single file depending on which browser you use.
The cookies used on this website have been categorised based on the categories found in the ICC UK Cookie guide, as follows: Category 1: strictly necessary cookies. These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies services you have asked for, like shopping baskets or e-billing, cannot be provided.