Privacy Policy for Patients’ Personal Data(England & Wales)

This information has been prepared exclusively for use in Apolline clients’ practices and as such should not be shared with anyone else.  The information was prepared to reflect our thinking on what is required for UK GDPR.  It is not definitive guidance and Apolline Ltd accepts no responsibility for the validity or correctness of this document or any consequences arising as a result of its use by practices.  Practices should obtain independent legal advice regarding their personal situation should they require definitive advice and guidance.

Notes on obtaining evidence of opt-in consent

Practices should choose how they will evidence that they have obtained opt in consent from their patients in relation to data protection and UK GDPR requirements.

You may choose to ask patients to sign the Privacy Notice for patients to confirm opt in consent or you could use individual consent forms.

If you wish to use the Privacy Notice to obtain opt in consent, you should ensure that you list everything you want consent for and ask the patient to consent to each item, usually by ticking a box and then signing at the end. Practices will need to add this list in themselves and will also need to add a signature line for the patient to sign to signify that they give consent to each item.

Boxes must never be pre-ticked.

You should retain a copy of the signed notice at the practice and also give the patient a copy.

Alternatively, you could use the Apolline draft consent forms or any other suitable method.

Practices must ensure that this policy is tailored specifically for their practice.  Areas that require tailoring are indicated in RED.  Once completed, the RED text should be deleted.

Privacy Policy for Chapel Dental for Patient Data

Chapel Dental takes great care to protect the personal data we hold for our patients in line with the requirements of the Data Protection Act 2018 which is the UK’s implementation of the General Data Protection Regulation (UK GDPR).

The purpose of collecting and storing personal data about our patients is to ensure we can:

• Provide, appropriate, safe and effective dental care, treatment and advice for all our patients.
• Fulfil any contracts we hold in relation to their care.
• For business administration of their care.

Personal data held for our patients

The personal data we process (processing includes obtaining the information, using it, storing it, securing it, disclosing it, and destroying it) for our patients includes:

• Name, address, date of birth.
• Unique identification number.
• Email address.
• Phone numbers.
• GP contact details.
• Occupation.
• Medical history
• Dental care records.
• Photographs.
• Family group.
• Financial information.
• Credit cards receipts.
• Correspondence.
• Details of any complaints received.

We keep an inventory of personal data we hold on our patients and this is available for patients on request. A list of personal information held is also included in our Privacy Notice that is given to all patients.

National Opt-out Policy

At Chapel Dental Practice sensitive personal information relating to our patients is only used to provide dental care for the individual. It is never shared for research purposes or any non-clinical need. The National Opt-out Policy introduced in March 2020 is therefore not operated at our practice on this basis.

Should we change our policy to use information for a non-clinical purpose or a research project, we would then introduce the National Opt-out policy.

Disclosure to third parties

The information we collect and store will not be disclosed to anyone who does not need to see it.

We will share our patients’ personal information with third parties when required by law or to enable us to deliver a service to them or where we have another legitimate reason for doing so. Third parties we may share patients’ personal information with may include:

• Regulatory authorities such as the General Dental Council or the Care Quality Commission
• NHS Local Authorities
• Dental payment plan administrators
• Insurance companies
• Loss assessors
• Fraud prevention agencies
• In the event of a possible sale of the practice at some time in the future.

We may also share personal information where we consider it to be in a patient’s best interest or if we have reason to believe an individual may be at risk of harm or abuse.

Personal privacy rights

Under the UK GDPR and the Data Protection Act 2018, all individuals who have personal information held about them have the following personal privacy rights:

• Right to subject access.
• Right to have inaccuracies deleted.
• Right to have information erased.
• Right to object to direct marketing.
• Right to restrict the processing of their information, including automated decision-making.
• Right to data portability.

Patients who wish to have inaccuracies deleted or to have information erased must speak to the dentist who provided or provides their care.

Legal basis for processing data held about patients

The UK GDPR requires us to state the legal basis upon which we process all personal data for our patients and it requires us to inform our patients of the legal basis on which we process their personal data.  This is clearly stated in our privacy notice that is given to all patients.

The legal bases for recording individual types of data are recorded in our patient personal data inventory.  This is available for all patients to see on request.

Automated decision making

All individuals who have personal data held about them have a right to object to their personal data being subjected to automated decision making.

Patients will always be asked to give specific, informed, verifiable, opt in consent for any processes involving automated decision making.

Consent

Chapel Dental  may need to contact our patients, their families or third-party organisations regarding patients’ appointments, medical histories, and treatment. Where possible, we will obtain prior consent to process and share this information.

Where patients have not previously consented to or have withdrawn their consent for us to contact or share or process their data, we will assess whether the need for processing is proportionate and necessary in relation to the risk to the individual and/or the public if the information is not shared.

Chapel Dental  always obtains specific, unambiguous opt in consent from all patients to whom we send direct marketing information. Asking paitents at the desk and adding to the pop up box on SOE.

We also obtain specific, unambiguous, opt in consent from our patients for photo consemt and the way we use photos.  For a new patient, we obtain consent for these things when the patient first attends the practice.  For an existing patient, we ask the patient for consent when they attend for their recall appointment or for a treatment appointment.  We refresh this consent annually when the patient completes a new medical history proforma.

Retention period

This practice retains dental records and orthodontic study models while you are a patient of our practice and after you cease to be a patient for at least eleven years or for children until age 25, whichever is longer.

Complaints

All individuals who have personal data held about them have a right to complain. All complaints concerning personal data should be made in person or in writing to Rachel Derby.  All complaints will be dealt with in line with the practice complaints policy and procedures.

If you are unhappy with the resolution of your complaint, you have the right to raise your complaint with the Information Commissioner’s Office (ICO).

The ICO can be contacted at https://ico.org.uk/make-a-complaint or you can start a live chat or call the ICO helpline on 0303 123 1113.

Further information on making a complaint to the ICO can be found here: https://ico.org.uk/make-a-complaint/data-protection-complaints/data-protection-complaints

Read our complaints policy.

This Policy was reviewed and implemented on: 20.09.2023

This policy and relevant procedures will be reviewed annually and are due for review on 20.09.2023 or prior to this date in accordance with new guidance or legislative changes.

Document Change Record for Privacy Policy for Patient Data

The table below is used to register all changes to the policy: