PRIVACY NOTICE (why I collect your personal data and what do I do with it)
This notice is to explain why I collect your personal data, and what I do with it, and to ensure I am working in accordance with the new EU General Data Protection Regulation (GDPR); terms from the regulation are indicated in bold.
When you supply your personal details to me, when we communicate by email, and when I take notes in the clinic, this information is stored and processed for four reasons in line with the GDPR requirements:
1. I need to collect personal information about your health in order to provide you with the best possible treatment. Your requesting treatment and our agreement to provide that care constitutes a contract. You can, of course, refuse to provide the information, but if you were to do that I would not be able to provide treatment.
2. I have a “Legitimate Interest” in collecting that information, because without it I couldn’t do my job effectively and safely.
3. I also think that it is important that I can contact you in order to confirm your appointments with me or to update you on matters related to your medical care. This again constitutes “Legitimate Interest”, but this time it is your legitimate interest.
4. Provided I have your consent, I may occasionally send you general health information in the form of articles, advice or newsletters. You may withdraw this consent at any time – just let me know by any convenient method.
I have a legal obligation to retain your records for 8 years after your most recent appointment (or age 25, if this is longer), but after this period you can ask me to delete your records if you wish. Otherwise, I will retain your records indefinitely in order that I can provide you with the best possible care should you need to see me at some future date.
I will never share your data with anyone who does not need access without your written consent. Only the following people/agencies will have routine access to your data:
• Your practitioner in order that they can provide you with treatment
Your clinical records are stored only on paper, in individual paper files, and in a secure cabinet in my home. They are not left overnight in the clinic. Your emails are stored in my email at startmail.com which is password protected and encrypted. This domain has a very good track record in terms of security, and thus carries a low risk of being vulnerable to a security breach. Highly recommended even by a major privacy whistleblower Edward Snowden.
I also keep a file on my password protected computer at home which stores the invoices which I send out to those people who pay by bank transfer. These invoices mostly record dates of acupuncture appointments and names of clients. Some record addresses of clients only if requested by the client for the purposes of claiming clinic fees on insurance.
I am the only person who has access to your records, invoice files and emails. I will never share your information with anyone who does not have a legal right of access without your written consent.
You have the right to see what personal data of yours I hold, and you can also ask me to correct any factual errors. I am legally required to respond to any request from a client to see their personal data within a timescale of 30 days. However, I would ensure that I responded as soon as I possibly could to any reasonable request for access to personal records.
I want you to be absolutely confident that I am treating your personal data responsibly, and that I will do everything I can to make sure that the only people who can access that data have a genuine need to do so. In the case of my practice this would most likely apply in the situation of me needing to make a referral to another health professional.
Of course, if you feel that I am mishandling your personal data in some way, you have the right to complain. Please first raise your concern with me, as I hope very much I will be able deal with any concerns you might have. However, you can also raise a concern directly with the Information Commissioner’s Office on https://ico.org.uk/concerns/
Milan Skamene May 2018