Privacy Notice:
Why we collect your data and what we do with it.
Welcome to Health House Limited’s Privacy Policy:
Intro:
Health House Ltd trades under the name of Health House Osteopathy and Wellness Clinic. We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website and clinic (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review, and we may make changes to it from time to time. This version was last updated on 19th February 2023. Historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with osteopathic or other types of treatment). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Medical Data by filling in forms or by corresponding with us by post, phone, email, in person or otherwise. This includes personal data you provide when you:
apply for our goods or services;
Verbally give us your data in person during a consultation
fill in a form on our website;
contact us to enquire about or discuss our goods or services;
subscribe to our service or publications;
request marketing to be sent to you;
enter a competition, promotion or survey; or
give us feedback or contact us.
When you supply your personal details to this clinic they are stored and processed for 4 reasons (the bits in bold are the relevant terms used in the Data protection Act 2018, which includes the General Data Protection Regulation – ie the law):
1. We need to collect personal information about your health in order to provide you with the best possible treatment. Your requesting treatment and our agreement to provide that care constitutes a contract. You can, of course, refuse to provide the information, but if you were to do that we would not be able to provide treatment.
2. We have a “Legitimate Interest” in collecting that information, because without it we couldn’t do our job effectively and safely.
3. We also think that it is important that we can contact you in order to confirm your appointments with us or to update you on matters related to your medical care. This again constitutes “Legitimate Interest”, but this time it is your legitimate interest.
4. Provided we have your consent, we may occasionally send you general health information in the form of articles, advice or newsletters. You may withdraw this consent at any time – just let us know by any convenient method.
We have a legal obligation to retain your records for 8 years after your most recent appointment (or age 25, if this is longer), but after this period you can ask us to delete your records if you wish. Otherwise, we will retain your records indefinitely in order that we can provide you with the best possible care should you need to see us at some future date.
Your records are stored:
On paper, in locked filing cabinets, and the offices are always locked out of working hours.
Electronically (“in the cloud”), using a specialist medical records service. This provider has given us their assurances that they are fully compliant with the General Data Protection Regulations. Access to this data is password protected, and the passwords are changed regularly.
On our clinic computers. These are password-protected, backed up regularly, and the office(s) are locked and alarmed out of working hours.
Only the following people/agencies will have routine access to your data:
The medical records service who store and process our files
Your practitioner(s) in order that they can provide you with treatment
Our reception staff, because they organise our practitioners’ diaries, and coordinate appointments and reminders (but they do not have access to your medical history or sensitive personal information)
Other administrative staff, such as our bookkeeper. Again, administrative staff will not have access to your medical notes, just your essential contact details.
We also use Mailchimp to coordinate our messages, so your name and email address may be saved on their server.
From time to time, we may have to employ consultants to perform tasks which might give them access to your personal data. We will ensure that they are fully aware that they must treat that information as confidential, and we will ensure that they sign a non-disclosure agreement.
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
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 third parties who have a business need to know. 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.
Your legal rights
You have the right to see what personal data of yours we hold, and you can also ask us to correct any factual errors. Provided the legal minimum period has elapsed, you can also ask us to erase your records. This section explains more about your rights.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Details of these rights are as follows:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it;
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us;
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request;
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
If you want us to establish the data’s accuracy;
Where our use of the data is unlawful but you do not want us to erase it;
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you; and
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We want you to be absolutely confident that we are treating your personal data responsibly, and that we are doing everything we can to make sure that the only people who can access that data have a genuine need to do so.
Of course, if you feel that we are mishandling your personal data in some way, you have the right to complain. Complaints need to be sent to what is referred to in the jargon as the “Data Controller”.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Data Controller:
Rosie Russell
HealthHouseLtd@gmail.com
01392 401260
Health House
The Old Stables
Barrack Rd
Exeter
EX2 5ED
If you are not satisfied with our response, then you have the right to raise the matter with the Information Commissioner’s Office.