The processing of personal data is governed by the General Data Protection Regulation 2016/679 (the GDPR). We respect and value the privacy of all or our clients. We understand that your privacy is important to you and that you care about how your personal data is used. This privacy notice provides you with details of how we collect and process your personal data that is consistent with our obligations and your rights under the law.
Information About Us
Main addresses :
North West London Physiotherapy Centre 100 Colindeep Lane NW9 2HB
Hollickwood Avenue, N12 0LT
Data Protection Officer: Colette Assor, Founder of Acupuncture Works
Email address: firstname.lastname@example.org
Telephone number: 0208 368 1130
Postal address: North West London Physiotherapy Centre, 100 Colindeep Lane, Hendon NW9.
We are on the data protection register held by the ICO.
Whose information does this privacy notice apply to?
This privacy notice applies to information we collect from:
- prospective patients;
- former patients;
- people who subscribe to our newsletters;
- visitors to our website;
- job applicants and our current and former employees.
What is personal data?
Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. 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 revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. Examples of special category data we may hold about you include your patient notes.
How do we process your personal data?
We comply with our 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.
Sections 1 – 12 apply to our patients, prospective patients, former patients and visitors to our clinic
- We use your name, address, telephone number and email address to make and rearrange appointments. We will also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send us is within the bounds of the law.We use your name, address, telephone number and email address, only if we have your explicit consent, to send you marketing materials. We will also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send us is within the bounds of the law
- Some patients and prospective patients return pre- 1st appointment questionnaires or tell us about their medical conditions and medication by email or online enquiry forms. We will also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send us is within the bounds of the law.
- We keep a permanent attendance register which records all appointments for patients attending our clinic 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.
- We use your presenting complaint and symptoms reported by you for the purposes of making a full traditional diagnosis, formulating treatment strategy and treatment planning.
- We 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, for identification purposes if referring a patient to another health practitioner, and for identification purposes if writing to a registered medical practitioner so that they correctly identify the patient.
- We use any relevant medical and family history you have told us for making a full traditional diagnosis, formulating treatment strategy and treatment planning.
- We use your GP’s name and address in the event that we need to contact your GP including in an emergency and because it is a mandatory requirement in the British Acupuncture Code of Professional Conduct.
- We use our clinical findings about your health and well being for making a full traditional diagnosis, and formulating treatment strategy and treatment planning.
- We keep a record of and refer to that record of any treatment given and details of progress of your case, including reviews of treatment planning to enable us to: review the full traditional diagnosis, treatment strategy and planning; and to secure evidence in the event of criminal proceedings, civil liitagation, an insurance claim or a complaint.
- We record and use any information and advice that we have given, especially when referring patients to any other health professional, to help you receive the most appropriate treatment and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint.
- We 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. Diseases and dangerous occurrences Regulations to comply with the law and to secure evidence in the event of criminal proceedings, civil litigation an insurance claim or complaint.
- In the event of an adverse incident occurring to any of our patients we report the matter to the British Acupuncture Council and to our insurance company.
The next section apply to job applicants, current and former employees
We are the data controller for the information job applicants provide during the process.
- All of the information you provide during the process will only be used for the purpose of progressing your application, or to fulfil legal or regulatory requirements if necessary.
- We will not share any of the information you provide during the recruitment process with any third parties for marketing purposes or store any of your information outside of the European Economic Area. The information you provide will be held securely by us whether the information is in electronic or physical format.
- We will use the contact details you provide to us to contact you to progress your application. We will use the other information you provide to assess your suitability for the role you have applied for.
- We do not collect more information than we need to fulfil our stated purposes and will not retain it for longer than is necessary.
- The information we ask for is used to assess your suitability for employment. You don’t have to provide what we ask for but it might affect your application if you don’t.
- We ask you for your personal details including name and contact details. We will also ask you about your previous experience, education, referees and for answers to questions relevant to the role you have applied for.
- We shortlist applications for interview.If we make a conditional offer of employment we will ask you for information so that we can carry out pre-employment checks. You must successfully complete pre-employment checks to progress to a final offer. We are required to confirm the identity of our staff, their right to work in the United Kingdom and seek assurance as to their trustworthiness, integrity and reliability.
You will therefore be required to provide:
- Proof of your identity – you will be asked to attend our clinic with original documents, we will take copies.
- Proof of your qualifications – you will be asked to attend our clinic with original documents, we will take copies.
- You will be asked to complete a criminal records declaration to declare any unspent convictions.
- We will contact your referees, using the details you provide in your application, directly to obtain references.
- If we make a final offer, we will also ask you for the following:
- Bank details – to process salary payments
- Emergency contact details – so we know who to contact in case you have an emergency at work.
- If you are successful, the information you provide during the application process will be retained by us as part of your employee file for the duration of your employment plus 6 years following the end of your employment. This includes your criminal records declaration, fitness to work, records of any references.
If you are unsuccessful at any stage of the process, the information you have provided until that point will be retained for 6 months from the closure of the recruitment process.
Information generated throughout the assessment process, for example interview notes, is retained by us for 6 months following the closure of the recruitment process.
- All of the information gathered during the application process is taken into account to make final recruitment decisions.
- You are able to ask about decisions made about your application by speaking to (insert name) or by emailing (insert email address).
Sharing your personal data
Your personal data will be treated as strictly confidential, and will 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/
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way. Special attention is taken to protection of clinical data. Most of your clinical notes are kept in written format according to British Acupuncture Council guidelines. All notes are securely locked. Any information that is in electronic format is securely protected.
How long do we keep your personal data?
We keep your personal data for no longer than reasonably necessary.
We 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/
If we wish to use your personal data for a new purpose, not covered by this 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. Where and whenever necessary, we will seek your prior consent to the new processing.
To exercise all relevant rights, queries of complaints please in the first instance contact us at Colette Assor, email@example.com