Privacy policy

1. Introduction

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact us or the UK Information Commissioner's Office (ICO) in the event you have a complaint.

We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation, which applies across the European Union (including in the UK) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.

2. About us

When we say "we" or "us" in this privacy policy, we mean Anglia Orthodontics. You can contact us at:

Address: The Pavilion
Lammas Field
Driftway
Cambridge
CB3 9PA

T: 01223 305526

Email: admin@angliaorthodontics.co.uk

3. Personal information we collect about you

We may collect and use the following personal information about you:

• your full name
• your email and phone number
• your postcode
• information about your appointment with us, including what orthodontic services you have requested
• limited information about your health (such as previous orthodontic work) in connection with your appointment
• information about how you use our website
• information about the device and programmes you are using to use our website such as your browser and operating system

This personal information is required to provide services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing services to you.

4. How your personal information is collected

We collect personal information directly from you, whether via our website or when contacting you about your appointment.

We may also collect personal information from cookies on our website (more information is set out in section 10 below) and from our IT systems (such as appointment logs, automated monitoring of our websites, instant messaging systems) and CCTV.

5. How and why we use your personal information

Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:

• for the performance of our contract with you or to take steps at your request before entering into a contract (such as arranging your first appointment);
• to comply with our legal and/or regulatory obligations;
• for our legitimate interests or those of a third party; or
• where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

If you are interested in booking an appointment with us, we will need to collect personal information from you in order to take steps necessary to process your appointment and to provide you with the services you have requested from us.

The technical information gathered from the use of our website (including through our use of cookies) which may include personal data, is used for our legitimate interest of ensuring that our website is functioning properly and to help us make business decisions about the information to be provided on our website.

6. Marketing Communications

We may use your personal information to send you updates by email, text message, telephone or post about our services, events, news and promotions.

We may send marketing communications to you as an existing customer about similar products we think you may be interested in, however we will always give you the opportunity to opt-out or unsubscribe from these communications if you wish.

We will always treat your personal information with the utmost respect and never share it with other organisations for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by using the "unsubscribe" link in emails or contacting us at the details above.

We may ask you to confirm or update your marketing preferences in the future, or if there are changes in the law, regulation, or the structure of our business.

7. Who we share your personal information with

We routinely share personal information with:

• third parties we use to help deliver our services, e.g. IT and digital service providers, such as our supplier who hosts this website and data collected from it on our behalf and helps us co-ordinate and send marketing communications;
• our professional services advisers (such as lawyers, accountants and auditors)
• Google Analytics: we work with Google Analytics to automatically collect information including: IP address; MAC (Media Access Control) address; unique identifier or other persistent or non-persistent device identifier; device software platform and firmware, mobile phone carrier and geo location data to help us understand your use of our website such as how often you return, what parts of the website you visit, how you use the website and how long you spend on the website. This third party provider is prohibited from using your data for any other purposes. Go to http://www.google.com/analytics/terms/us.html to read the Google Analytics Privacy Policy.
• Sendgrid: this is the system we use to send email notifications from our website, which is needed to ensure that email notifications get to delivered to their intended destination and minimize the chance of them being blocked by spam filters. This includes sending you email confirmations where required or requested; for example, if you have requested to download a guide, we will then send you an email containing the guide, or a link to view the guide. SendGrid does not store the content of the emails, but information such as your email address, and time the email was sent, which is required for it perform its functions.

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers to ensure they can only use your personal information to provide services to us and to you.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

8. How long your personal information will be kept

We will keep your personal information for as long as is necessary:

• to respond to any questions, complaints or claims made by you or on your behalf
• to show that we treated you fairly
• as required by law.

We will not retain personal information for longer than necessary for the purposes set out in this policy. When it is no longer necessary to retain your personal information, we will delete or anonymise it.

Please note that different retention periods apply to different types of personal information held. Further details on this are available on request.

9. Transferring your personal information out of the EEA

It is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g. with our service providers located outside of the EEA.

These transfers are subject to special rules under European and UK data protection law.

These non-EEA countries do not have the same data protection laws as the UK and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. Our standard practice is to ensure that any US-based suppliers are certified under the EU-US Privacy Shield scheme, or alternatively to use standard data protection contract clauses that have been approved by the European Commission.

If you would like further information on international transfers of data, this is available on request.

10. Cookies

A cookie is a small text file which is placed onto your computer (or other electronic device) when you access our website. We use cookies on our website to:

• recognise you whenever you visit our website (this speeds up your access to the website as you do not have to log in each time);
• obtain information about your preferences, online movements and use of the internet;
• carry out research and statistical analysis to help improve our content; and
• make your online experience more efficient and enjoyable.

In most cases we will need your consent in order to use cookies on this website. The exception is where the cookie is essential in order for us to provide you with a service you have requested.

If you visit our website when your browser is set to accept cookies, we will interpret this as an indication that you consent to our use of cookies and other similar technologies as described in this policy. If you change your mind in the future about letting us use cookies, you can modify the settings of your browser to reject cookies or disable cookies completely.

The table below provides some information on the cookies which we use on our website:

If you do not want to accept cookies, you can change your browser settings so that cookies are not accepted. If you do this, please be aware that you may lose some of the functionality of our website. For further information about cookies and how to disable them please go to the ICO’s webpage on cookies: https://ico.org.uk/for-the-public/online/cookies/.

11. Your Privacy Rights

Data protection laws give you a number of rights as set out below. If you would like to exercise any of your rights, please contact us in writing.

• Access: you may request access to a copy of your personal information.
• Withdraw Consent: where our processing of your personal information is based on your consent, you can withdraw your consent at any time.
• Rectification: you may ask us to rectify any inaccurate information we hold about you.
• Erasure: you may ask us to delete the personal information we hold about you, where there is no reason for us to continue to hold your information.
• Portability: you may ask us to provide you with the personal information that we hold about you in a structured, commonly used, machine readable format, or you can ask us to send your information in this format to another controller.
• Object: you may object to our processing of your personal information.
• Restriction: you can ask us to restrict the personal information we use about you where you have asked for it to be erased or where you have objected to our use of it.

If you are not happy with the way in which we process your personal information, or the way in which we handle any request by you to exercise your privacy rights, you may make a complaint to the ICO by visiting their website at https://ico.org.uk/concerns/ or on 0303 123 1113.

12. Keeping your personal information secure

We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

13. Changes to this privacy policy

This privacy policy was last updated on 25/5/2018.

We may change this privacy policy from time to time—when we do we will inform you via an announcement on our website.

 

Data Opt-Out Policy

How the NHS and care services use your information

Anglia Orthodontics is one of many organisations working in the health and care system to improve care for patients and the public. Whenever you use a health or care service, such as attending Accident & Emergency or using Community Care services, important information about you is collected in a patient record for that service. Collecting this information helps to ensure you get the best possible care and treatment. The information collected about you when you use these services can also be used and provided to other organisations for purposes beyond your individual care, for instance to help with:

• Improving the quality and standards of care provided
• Research into the development of new treatments
• Preventing illness and diseases
• Monitoring safety
• Planning services

This may only take place when there is a clear legal basis to use this information. All these uses help to provide better health and care for you, your family and future generations. Confidential patient information about your health and care is only used like this where allowed by law.

Most of the time, anonymised data is used for research and planning so that you cannot be identified in which case your confidential patient information isn’t needed.

You have a choice about whether you want your confidential patient information to be used in this way. If you are happy with this use of information you do not need to do anything. If you do choose to opt out your confidential patient information will still be used to support your individual care. To find out more or to register your choice to opt out, please visit www.nhs.uk/your-nhs-data-matters. On this web page you will:

• See what is meant by confidential patient information
• Find examples of when confidential patient information is used for individual care and examples of when it is used for purposes beyond individual care
• Find out more about the benefits of sharing data
• Understand more about who uses the data
• Find out how your data is protected
• Be able to access the system to view, set or change your opt-out setting
• Find the contact telephone number if you want to know any more or to set/change your opt-out by phone
• See the situations where the opt-out will not apply

You can also find out more about how patient information is used at: https://www.hra.nhs.uk/information-about-patients/ (which covers health and care research); and https://understandingpatientdata.org.uk/what-you-need-know (which covers how and why patient information is used, the safeguards and how decisions are made)

You can change your mind about your choice at any time.

Data being used or shared for purposes beyond individual care does not include your data being shared with insurance companies or used for marketing purposes and data would only be used in this way with your specific agreement.

Our practice only uses your personal health data to provide individualised care to you and does not disclose your data for any other purposes. The national data opt-out does not apply to our usage of your data and we are compliant with the policy.

Processing of Staff and Candidates’ Information

This section explains how Anglia Orthodontics processes the information of staff and applicants for job roles within the practice.

What data do we have?

So that we can provide a safe and professional service, we need to keep certain records about our team members. We may record the following types of data:

• Your basic details and contact information e.g. your name, address, date of birth, National Insurance number and next of kin
• Your financial details e.g. details so that we can pay you, insurance, pension and tax details
• Your training records

We also record the following data which is classified as “special category”:

• Health and social care data about you, which might include both your physical and mental health data – we will only collect this if it is necessary for us to know as your employer, e.g. fit notes or in order for you to claim statutory maternity/paternity pay
• We may also, with your permission, record data about your race, ethnic origin, sexual orientation, or religion

As part of your engagement with the practice, you may be required to undergo a Criminal Record Check. This information is not kept for longer than is necessary—usually not more than 6 months following the recruitment decision, unless a dispute is raised or, in exceptional circumstances.

Why do we have this data?

We require this data so that we can contact you, pay you and make sure you receive the training and support you need to perform your job. By law, we need to have a lawful basis for processing your personal data.

We process your data because:

• We have a legal obligation under UK employment law
• We have a legitimate interest in processing your data – for example, for administration of training or learning course or emergency planning etc. These legitimate interests will be customary, or necessary for operational, administrative, HR and recruitment purposes and to otherwise manage employment relationship and interaction between employees
• We are required to provide data to our regulator, [CQC/NHS/RQIA/HIS/HIW], as part of our public interest obligations
• We are required to do so in our performance of another public task
• We process your special category data because It is necessary for us to process requests for sick pay or maternity pay
• If we request your criminal records data it is because we have a legal obligation to do this due to the type of work you do. This is set out in the Data Protection Act 2018 and the Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975
• We may also process your data with your consent. If we need to ask for your permission, we will offer you a clear choice and ask that you confirm to us that you consent. We will also explain clearly to you what we need the data for and how you can withdraw your consent

Where do we collect your data from?

As your employer we need to receive specific data about you. This is collected from or shared with:

• You or your legal representative(s)
• Third parties – for example this could include references from your previous job

We do this face to face, via phone, via email, via our website, via post, via application forms, via apps

How do we share your data?

Third parties are organisations we have a legal reason to share your data with. These include:

• HMRC
• Our pension and healthcare schemes - NEST
• QUARTZ manage our payroll
• DBS checks using SWIFT
• Organisations we have a legal obligation to share information with i.e. for safeguarding, the CQC
• The police or other law enforcement agencies if we have to by law or court order

How long do we hold your data?

The retention period for staff records is 6 years, however, certain information relating to team members may lawfully be kept for longer. Team members should refer to Record Retention (M 215) for further details on how this practice keeps and deposes of staff data. Application forms and interview notes for unsuccessful candidates are kept for one year.

Your rights

As an individual you have certain rights regarding our processing of your personal data, including a right to lodge a complaint with the Information Commissioner’s Office (ICO) as the relevant supervisory authority. For more information on your personal data rights, you can access information and advice on the ICO’s website.

You can request a copy of your personal file by contacting the [Information Governance Lead].