General Data Protection Regulation
HALTON PHYSIOTHERAPY ("We") is committed to protecting and respecting your privacy.
This policy (together with our terms and conditions 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”).
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?
HALTON PHYSIOTHERAPY (including all therapists working for and with the company) is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are: Halton Physiotherapy, Halton Tennis Centre, Chestnut End, Halton Village, AYLESBURY, Buckinghamshire, HP22 5PD. For all data matters contact Mr David Hudson at the named address or on 01296 622007.
3. The purpose(s) of processing your personal data
We use your personal data for the following purposes:
To record and keep an accurate record of your episode-of-care.
To ensure accurate communication with you during and after an episode-of-care.
To ensure accurate communication with other Health Professionals, with your knowledge and consent.
To keep you informed of Halton Physiotherapy developments, including current offers or staff changes.
To maintain our own accounts and records.
We do not sell or pass on your details to anyone outside of Halton Physiotherapy.
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:
Personal & Family details (Name, Address, e-mail address, contact telephone numbers)
Lifestyle and social circumstances (Occupation, Leisure Activities)
Goods and services used within Halton Physiotherapy
Financial details (i.e. Financial History with Halton Physiotherapy, Merchant Card receipts)
Special Categories of Data:
We also process sensitive classes of information that include:
Physical or Mental Health Details
Medical History Details
Results of investigations, Xray’s, scans, etc.
We will have obtained your personal data from yourself either through direct face-to-face contact at the time of an appointment, during a telephone conversation, an electronic form of communication (i.e. email/text etc.), or from an online form from our website – www.halton-physiotherapy.co.uk
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:
☐ Explicit consent by the data subject;
As part of your initial consultation you will have been required to give your consent to the taking and storage of your data, either through written confirmation or through an electronic form. A copy of the explicit consent is kept on file.
b) Special categories of personal data (article 9 of GDPR)
Our lawful basis for processing your special categories of data:
☐ Processing necessary for reasons of preventative or occupational medicine, for assessing the working capacity of an employee, medical diagnosis, the provision of health or social care or treatment or management of health or social care systems and services on the basis of EU or Member State law or a contract with a health professional.
We are obliged by law and our standards of professional practice to maintain and hold your treatment records for a minimum of 8 years, or until a client is 25 years old if a child is under the age of 16 when seen.
6. Sharing your personal data
Your personal data will be treated as strictly confidential and will be shared only with other Health Professionals or relevant parties that you have given permission to be contacted.
7. How long do we keep your personal data?
We keep your personal data for no longer than reasonably necessary for a period of 10 years from the date you were last seen in order to comply with national standards and clinic policy:
All records are to be retained in archives for a minimum of 10 years after the conclusion of treatment. This will ensure all children/young people (15 years and over) will have their records retained until the patient’s 25th birthday or 8 years after the last entry.
All records of children/young people under the age of 15 years must have their records retained until the patient’s 25th birthday.
Obstetric records are retained for 25 years.
Examples include: in case of any legal claims/complaints; for safeguarding purposes etc.
8. Providing us with your personal data
We require your personal data as it is a requirement to ensure a high standard of therapy is achieved and maintained, whilst you are under the care of Halton Physiotherapy.
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:
The right to request a copy of the 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 to retain such data;
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 i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes 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 i.e. 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).
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.
14. How to make a complaint
To exercise all relevant rights, queries or complaints please in the first instance contact our DATA PROTECTION OFFICER - David Hudson on 01296 622007.
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 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, England.