Privacy notice for Toddington Osteopathic Medicine Clinic – TOMClinic patients:

Your personal information – General Data Protection Regulation (GDPR)

GDPR is bringing in new legal protection for personal information from May 2018. This tells you what personal information we hold and why, and what your rights are.

Toddington Osteopathic Medicine Clinic – TOMClinic, The Old Forge, Market Square, Toddington, LU5 6BP; 01525 875474; 07376124619; info@tomclinic.com

Data Controllers: Toddington Osteopathic Medicine Clinic osteopaths, sports therapists, massage therapists, practice manager and the Cliniko management system.

The purpose of processing client data:
In order to give professional osteopathic, sports therapy and massage treatments our osteopaths, sports therapists and massage therapists will need to gather and retain potentially sensitive information about your health. We will only use this information for informing osteopathic treatments, sports therapy treatments and massage treatments and associated recommendations concerning aspects of health and wellbeing which we offer you.

Lawful basis for holding and using client information:
As full members of the General Osteopathic Council, our osteopaths abide by the GosC code of practice and ethics. The lawful basis under which we hold and use your information is our osteopath’s, sports therapist’s and massage therapists legitimate interests i.e. our requirement to retain the information in order to provide you with the best possible treatment options and advice.

As we hold special category data (i.e. health related information), the additional condition under which we hold and use this information is for our osteopaths to fulfill their role as health care practitioners bound under the GosC confidentiality as defined in the GosC code of practice and ethics.

What information we hold and what we do with it:
In order to give professional osteopathic, sports therapy and massage treatments, we will need to ask for and keep information about your health. We only use this information for informing osteopathy, sports therapy and massage treatments and any advice we give as a result of your treatment. The information held is:
* Medical history and other health-related information which is taken from you at first consultation
* Treatment details and related notes which are taken at every treatment

*Contact details and content of messages where appropriate on TOMClinic phone, email, WhatsApp, text to ensure an accurate record of communications

We will not share your information with anyone else other than within the practice, or as required for a legal process without explaining why it is necessary, and getting your explicit consent.

How long we retain your information for:
WE will keep your information for the following period of 8 years in line with the lawful basis listed above and with CNHC requirements to retain information for 8 years.

Our practice management system is Cliniko, our data is held on Cliniko servers in the U.K which comply with the EEA GDPR guidelines.

The data on your consent forms taken at your first consultation will not be transferred outside the EU without your consent.

Protecting your personal data:
We are committed to ensuring that your personal data is secure. In order to prevent unauthorised access or disclosure, we have put in place appropriate technical, physical and managerial procedures to safeguard and secure the information we collect from you.

We will contact you using the contact preferences you give us in relation to:
Appointment times, policies and procedures
Osteopathic, sports therapy and massage information or information related to your health

Your rights:
GDPR gives you the following rights:
• The right to be informed:
To know how your information will be held and used (this notice).
• The right of access:
To see your osteopathic, sports therapy and massage records of your personal information, so you know what is held about you and can verify it.
• The right to recitification:
To tell your osteopath, sports therapist or massage therapist to make changes to your personal information if it is incorrect or incomplete.
• The right to erasure (also called ‘the right to be forgotten’):
For you to request your osteopath, sports therapist or massage therapist to erase any information we hold about you.
• The right to restrict processing of personal data:
You have the right to request limits on how we use your personal information.
• The right to data portability: under certain circumstances you can request a copy of persobal information held electronically so you can reuse it in other systems.
• The right to object:
To be able to tell your osteopath, sports therapist or massage therapist you don’t want them to use certain parts of your information, or only to use it for certain purposes.
• Rights in relation to automated decision-making and profiling.
• The right to lodge a complaint with the information commissioner’s office:
To be able to complain to the ICO if you feel your details are not correct, if they are not being used in a way that you have given permission for, or if they are being stored when they don’t have to be.

Full details of your rights can be found at http://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/ If you wish to exercise any of these rights, please use the contact details given above.

If you are dissatisfied with the response you can complain to the information commissioner’s office; their contact details are at: www.ico.org.uk

Osteopaths, sports therapists and massage therapists rights:
Please note –
• If you don’t agree to Toddington Osteopathic Medicine Clinic keeping records of information about you and your treatments, or if you don’t allow us to use the information in the way they need to for treatments, our osteopaths, sports therapists and massage therapists will not be able to treat you.

• We have to keep your records of treatment for a certain period as described above, which may mean that even if you ask to erase any details about you, they might have to keep these details until after that period has passed.

• We can move your records between our computer systems as long as your details are protected from being seen by others without your permission.