GDPR: DATA PRIVACY NOTICE FOR CLIENTS AND SUPPLIERS

The Cloisters Physiotherapy Ltd ("We") are committed to protecting and respecting your privacy.

This policy (together with our Terms of Use and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).

1. Definitions

Data controller - A controller determines the purposes and means of processing personal data.

Data processor - A processor is responsible for processing personal data on behalf of a controller.

Data subject – Natural person.

Categories of data: Personal data and special categories of personal data

Personal data - The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.

Special categories personal data - The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.

Processing - means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Third party - means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

2. Who are we?

The Cloisters Physiotherapy Ltd is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details can be found HERE. For all data matters, please contact the Practice Manager.

3. The purpose(s) of processing your personal data

We use your personal data for the following purposes:
Consent, Legal Obligations, Contractual, Legitimate Interests. To Maintain Our Own Accounts & Records

4. The categories of personal data concerned

With reference to the categories of personal data described in the definitions section, we process the following categories of your data:

We have obtained your personal data from yourself either by phone, email, website contact form or completion of a New Patient Form.

5. What is our legal basis for processing your personal data?

a) Personal data (article 6 of GDPR)

Our lawful basis for processing your general personal data:

Consent of the data subject; Consent has been given freely by the patient of personal details for identification purposes and for legitimate business uses.
Processing necessary for the performance of a contract with the data subject or to take steps to enter into a contract New Patient Form – basic information collected in order to identify and create a Patient Record
Processing necessary for compliance with a legal obligation Keeping medical files on record in accordance with government legislation
Processing necessary for the purposes of the legitimate interests of the data controller or a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of the data subject Eg Keeping Medical Records to be referred to for diagnosis and treatment

6. Sharing your personal data

Your personal data will be treated as strictly confidential, and will be shared only with your GP / Consultant where necessary and consent has been given (New Patient Form / Patient Information Record)

7. How long do we keep your personal data?

We keep your personal data for no longer than reasonably in order to comply with our legal obligations for medical record storage.

8. Providing us with your personal data

You are under an obligation to provide your personal data to us as a statutory requirement for medical records. If you fail to adhere to this request we shall be unable to treat you.

9. Your rights and your personal data

Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:

10. Transfer of Data Abroad

We do not transfer personal data outside the EEA.

11. Automated Decision Making

We do not use any form of automated decision making in our business.

12. Further processing

If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.

13. Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy. This policy was last updated on 22nd May 2018.

14. How to make a complaint

To exercise all relevant rights, queries or complaints please in the first instance contact our Data Protection Officer (Practice Manager). Contact details can be found HERE.

If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioner's Office on 03031 231 113, via this contact form or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.

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