1. Important information
Lisa Greaney, BDS (Hons.), MFDS RCS, MBBS, FRCS OMFS
Email address: email@example.com / firstname.lastname@example.org
Telephone number: 07562 508986
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). I would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact me in the first instance.
It is important that the personal data I hold about you is accurate and current. Please keep me informed if your personal data changes during your relationship with me.
2. The data I may collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
I may collect, use, store and transfer different kinds of personal data which I have grouped together as follows:
- Identity Data including your, first name, maiden name, last name, title, passport number, NHS number, marital status, nationality, date of birth, gender and occupation.
- Contact Data of yourself and your emergency contacts including address, email address and telephone numbers.
- Medical Data about you including notes and reports about your health (which may include images of you, x-rays and/or scans) and any treatment or care you have received (including from third parties) and/or need, including about clinic and hospital visits and medicines administered.
- Financial Data including your bank account and payment card details and insurance details.
- Transaction Data including correspondence with you, details about quotes, payments to and from you and other details of services you have purchased from me.
- Profile Data including your treatment outcome information, your preferences, feedback, complaints, incidents and survey responses.
- Marketing and Communications Data includes your preferences in receiving marketing from me and your communication preferences.
I will only collect special categories of personal data about you, such as your Medical Data, with your consent.
If you fail to provide personal data
Where I need to collect personal data by law, or under the terms of a contract I have with you, and you fail to provide that data when requested, I may not be able to perform the contract (for example, to provide you with my services). In this case, I may have to cancel a service for you but I will notify you if this is the case at the time.
3. How is your personal data collected?
I use different methods to collect data from and about you including through:
- Direct interactions. You may give me your Identity, Contact, Medical, Financial and Profile Data by filling in forms or by corresponding with me by post, phone, email or otherwise. This includes personal data you provide when you:
- make an enquiry for my services;
- pay for my services;
- request marketing to be sent to you;
- complete a survey;
- make a complaint; or
- give me feedback.
- Third parties. I may receive personal data about you from various third parties as set out below:
- Contact, Identity and Medical Data in relation to a referral for treatment from a third party (such as another doctor, dentist or consultant or your employer);
- Contact, Identity and Medical Data from an insurance company in relation to your treatment by me; and/or
- Contact, Identity and Medical Data from diagnostic centres and private companies who provide scans and test results to me in relation to your treatment.
4. How I use your personal data
I will only use your personal data when the law allows me to. Most commonly, I will use your personal data in the following circumstances:
- Where you have consented to your Medical Data being used by me in order for me to provide my services
- Where I need to perform the contract I am about to enter into or have entered into with you.
- Where it is necessary for my legitimate interests and your interests and fundamental rights do not override those interests.
- Where I need to comply with a legal obligation.
I will only process Medical Data and other special categories of personal data about you with your consent. When you submit any Medical Data or other special categories of personal data to me, you are consenting to me processing it in accordance with this policy.
You have the right to withdraw your consent, including in relation to received marketing from me at any time by contacting me.
Purposes for which I will use your personal data
I have set out below, in a table format, a description of all the ways I plan to use your personal data, and which of the legal bases I rely on to do so. I have also identified what my legitimate interests are where appropriate.
Note that I may process your personal data for more than one lawful ground depending on the specific purpose for which I am using your data. Please contact me if you need details about the specific legal ground I am relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new patient||(a) Identity |
|(a) Performance of a contract with you |
To deliver my services and any treatment to you including:
(a) managing payments
(b) collecting and recovering money owed to me
(c) obtaining diagnostic results in relation to your treatment
(d) referring you to a third party for further treatment
|(a) Identity |
|(a) Performance of a contract with you |
(c) Necessary for my legitimate interests (to recover debts due to me)
(d) Marketing and Communications
|(a) Performance of a contract with you |
(b) Necessary to comply with a legal obligation
(d) Necessary for my legitimate interests (to keep my records updated)
|To provide emergency medical treatment to you||(a) Identity |
|Protecting your vital interests|
|To assess the quality of care you have received||(a) Identity |
(d) Marketing and Communications
|(a) Performance of a contract with you |
(b) Necessary for my legitimate interests
(to understand how to improve my services and grow my business)
|To share details of your treatment with your GP||(a) Identity |
|To make suggestions and recommendations to you about services that may be of interest to you||(a) Identity |
(f) Marketing and Communications
|Necessary for my legitimate interests (to grow my business)|
Marketing from me
You will receive marketing communications from me if you have requested information from me or been a patient of mine and you have not opted out of receiving that marketing.
You can ask me to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting me at any time.
Where you opt out of receiving these marketing messages, this will not apply to communications I need to send to you in relation to your treatment.
I do not used cookies on this website.
Change of purpose
I will only use your personal data for the purposes for which I collected it, unless I reasonably consider that I need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact me.
If I need to use your personal data for an unrelated purpose, I will notify you and will explain the legal basis which allows me to do so.
Please note that I may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
I may share your personal data with the parties set out below for the purposes set out in the table above.
- Employees, independent consultants and contractors who work with me including other medical professionals.
- My IT system service providers.
- Professional advisers including lawyers, insurers and accountants who provide legal, insurance and accounting services to me.
- HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
- Your Contact, Identity and Medical Data may be shared with the following third parties to the extent necessary in relation to your treatment:
- Your insurer (where they are paying for your treatment)
- Your GP (where you consent to this)
- The NHS (where you are referred to me by them or in a medical emergency)
- Diagnostic companies
- Medical regulators
- External practitioners (where I refer you to them)
I require all third parties to respect the security of your personal data and to treat it in accordance with the law. I do not allow third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with my instructions.
6. International transfers
Due to the locations of my IT system service providers, your personal data may be processed outside of the UK when I use these systems. I may also transfer your data outside of the UK where you are an overseas patient and I need to correspond with third parties outside the UK in relation to your treatment or where I need to use the services of third parties located outside the UK where this is necessary in relation to your treatment.
Whenever I transfer your personal data out of the UK, unless the transfer is necessary in relation to your treatment or you have explicitly consented to the transfer, I will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- I will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
- Where I use certain service providers, I may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
Please contact me if you want further information on the specific mechanism used by me when transferring your personal data out of the UK.
7. Data security
I 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, I limit access to your personal data to those individuals or third parties who have a business need to know. They will only process your personal data on my instructions and they are subject to a duty of confidentiality. I will notify you and any applicable regulator of any personal data breach where I am legally required to do so.
8. Data retention
How long will you use my personal data for?
I will only retain your personal data for as long as reasonably necessary to fulfil the purposes it was collected for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. I may retain your personal data for a longer period in the event of a complaint or if I reasonably believe there is a prospect of litigation in respect to my relationship with you .
To determine the appropriate retention period for personal data, where the retention period is not mandated by applicable laws, I 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 I process your personal data and whether I can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances you can ask me to delete your data: see below for further information.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
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 I hold about you and to check that I am lawfully processing it.
Request correction of the personal data that I hold about you. This enables you to have any incomplete or inaccurate data I hold about you corrected, though I may need to verify the accuracy of the new data you provide to me.
Request erasure of your personal data. This enables you to ask me to delete or remove personal data where there is no good reason for me continuing to process it. You also have the right to ask me to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where I may have processed your information unlawfully or where I am required to erase your personal data to comply with local law. Note, however, that I 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 I am 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 I am processing your personal data for direct marketing purposes. In some cases, I may demonstrate that I 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 me to suspend the processing of your personal data in the following scenarios:
- If you want me to establish the data’s accuracy.
- Where my use of the data is unlawful but you do not want me to erase it.
- Where you need me to hold the data even if I no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to my use of your data but I need to verify whether I have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. I 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 me to use or where I used the information to perform a contract with you.
Withdraw consent at any time where I am 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, I may not be able to provide certain services to you. I 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 me.
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, I may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, I could refuse to comply with your request in these circumstances.
What I may need from you
I may need to request specific information from you to help me 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. I may also contact you to ask you for further information in relation to your request to speed up my response.
Time limit to respond
I try to respond to all legitimate requests within one month. Occasionally it could take me longer than a month if your request is particularly complex or you have made a number of requests. In this case, I will notify you and keep you updated.