Privacy Notice


This privacy notice applies to information I, Martin Bailey, collect from:

Patients.

prospective patients.

former patients.


What is personal data?

Personal data relates to a living individual who can be identified from that data. Examples of personal data we may hold about you include your contact and appointment details.


Special category data is a sub-category of personal data. The special category data I may hold about you, typically relates to your patient notes. Most data I collect does not require direct consent as it falls under the data processing principle of legitimate interest.


How do I process your personal data?

I comply with my obligations under the GDPR, by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data. We use your personal data for the purposes set out below.



1. I use your name, address, telephone number and email address to make and rearrange appointments. I am unable to send or receive encrypted emails so you should be aware that any emails I send or receive may not be protected in transit. I will also monitor any emails sent to us, including file attachments, for viruses or malicious software.


2. I will not send you marketing materials.


3. I keep a permanent paper-based attendance register which records all appointments for patients attending my clinics to keep a record of when you were treated for tax purposes and to secure potential evidence in the event of a criminal prosecution, civil litigation, insurance claim or complaint to my regulatory body, the British Acupuncture Council. Note: no details other than name (for a new customer also the phone number, which is removed from this record after the first attendance and transfer to electronic notes) will be recorded in this register.


4. Names, phone numbers and occasionally emails are also stored in a password protected phone.

5. I may use your date of birth to help identify patients with the same name to avoid mistakes being made as to safe and appropriate treatment.


6. Other than a paper-based appointment register, all other patient data is kept digitally and securely on a password protected computer. Patient notes are additionally password protected. An electronic backup of my patient notes is also kept on a separate hard drive, but also in a password encrypted state.

7. I use your presenting complaint, symptoms and any relevant medical and family history reported by you, for the purposes of making a full traditional diagnosis, formulating treatment strategy and treatment planning.


8. I keep a record of any treatment given and details of progress of your case, including reviews of treatment planning to enable me to: review the full traditional diagnosis, treatment strategy and planning. 

9. I may use your GP’s name and address in the event that I need to contact your GP with your permission, or in the event of an emergency.

10. I record and use any information and advice that I have given, especially when referring patients to any other health professional, to help you to receive the most appropriate treatment.


11. I will record any decisions made in conjunction with you to help you to receive the most appropriate treatment.


12. I keep accident records for any patients, visitors or staff who are involved in accidents at our clinic in accordance with UK Health and Safety legislation including the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations (RIDDOR) to comply with the law and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint. 


13. In the event of an adverse incident occurring to any of my patients, I report the matter to the British Acupuncture Council and to my insurance company. This enables the insurance company to deal with any potential claims and to help the British Acupuncture Council to develop its safe practice guidelines, as well as providing research data and information for the BAcC’s insurers and other interested parties. 


14. At the initial consultation I explain what acupuncture involves, any risks and ask questions related to the patient’s suitability for acupuncture therapy, for safety reasons. I then record this in your notes for the purposes of informed consent.



15. When I receive a complaint from a person I make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint.

I will only use the personal information I collect to process the complaint and to check on the level of service I provide. If a complainant doesn’t want information identifying him or her to be disclosed, I will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis. I may need to provide personal information collected and processed in relation to complaints to the British Acupuncture Council or my insurance company.

Information relating to a complaint will be retained for two years from closure. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.

16. Data relating to any of the above points, may be kept to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint.  

17. My website does not use cookies.

 

18. I use a third-party service, 123-reg, to host my website. 123-reg use analytics to assess footfall on to my website. The information does not relate to the individual identities of website users.



Sharing your personal data

Your personal data will be treated as strictly confidential, and will only be shared:


with named third parties with your explicit consent;

with the relevant authority such as the police or a court, if necessary for compliance with a legal obligation to which we are subject e.g. a court order;

with your doctor or the police if necessary to protect yours or another person’s life;

with the police or a local authority for the purpose of safeguarding a children or vulnerable adults; or

with my regulatory body, the British Acupuncture Council, or my insurance company in the event of a complaint or insurance claim being brought against me; or

my solicitor in the event of any investigation or legal proceedings being brought against me.


For further details about the situations when information about you might be shared please see the Information Commissioner’s website at https://ico.org.uk/for-the-public/personal-information/sharing-my-info/


How long do I keep your personal data?

I keep your personal data for no longer than reasonably necessary.

I keep patient records for a period of 7 years in accordance with the British Acupuncture Code of Professional Conduct https://www.acupuncture.org.uk/public-content/effective-practice/bacc-professional-codes.html


At any time you may request that changes are made to your contact details.


Your rights and your personal data

Unless subject to an exemption under the GDPR, you have certain rights with respect to your personal data as set out below.


The right to request a copy of your personal data which we hold about you.

The right to request that we correct any personal data if it is found to be inaccurate or out of date.

The right to request your personal data is erased where it is no longer necessary for us to retain such data.

The right to withdraw your consent to the processing at any time. This right does not apply where we are processing information using a lawful purpose other than consent. 

The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable) [This right only applies where the processing is based on consent or is necessary for the performance of a contract with you and in either case the we are processing the data by automated means].

The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing.

The right to object to the processing of personal data, (where applicable) [This right only applies where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics].

The right to be informed if your data is lost. We shall also inform the Information Commissioner’s Office in accordance with the time limits in the GDPR.

The right to lodge a complaint with the Information Commissioner’s Office.


For further details about these rights please see the Information Commissioner’s website at https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/

You can contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.


END OF PRIVACY NOTICE



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