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 Antonia Salzl, the information Governance Lead and the Data Protection Officer is Kerry Thresher.
What personal data do we hold?
In order to provide you with a high standard of dental care and attention, we need to hold personal information about you. 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.
This personal data comprises:
- your past and current medical and dental condition; personal details such as your age, national insurance number/NHS number, address, telephone number and your general medical practitioner
- radiographs, clinical photographs and study models
- information about the treatment that we have provided or propose to provide and its cost
- notes of conversations/incidents that might occur for which a record needs to be kept
- records of consent to treatment
- any correspondence relating to you with other health care professionals, for example in the hospital or community services.
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
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
Why do we hold information about you?
We need to keep comprehensive and accurate personal data about our patients in order to provide them with safe and appropriate dental care. We also need to process personal data about you in order to provide care under NHS arrangements and to ensure the proper management and administration of the NHS.
We will process personal data that we hold about you in the following way:
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 (M 215) procedure available from the practice.
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 (M 217C) 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 of request.
- 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 (M 217S) 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 (M 217M) and Information Governance Procedures (M 217C).
Security of information
Personal data about you is held in the practice’s computer system and/or in a manual filing system. The information is not accessible to the public and only authorised members of staff have access to it. Our computer system has secure audit trails and we back up information routinely.
Disclosure of information
In order to provide proper and safe dental care, we may need to disclose personal information about you to:
- your general medical practitioner
- the hospital or community dental services
- other health professionals caring for you
- NHS payment authorities
- the Inland Revenue
- the Benefits Agency, where you are claiming exemption or remission from NHS charges
- private dental schemes of which you are a member.
Comments, suggestions and complaints
Please contact Kerry Thresher at the practice for a comment, suggestion or a complaint about your data processing at firstname.lastname@example.org or 02392 8281 93 or by writing to or visiting the practice at 27 Highland Road, Southsea, Portsmouth, PO4 9DA. 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 (M 233-DPT), Consent Policy (M 233-CNS)
- Privacy Impact Assessment (M 217S), Information Governance Procedures (M 217C)