GENERAL DATA PROTECTION REGULATION (GDPR)
POLICY STATEMENT
This policy was last updated: 25/02/2017
This policy outlines how Atherton Physiotherapy and Sports Injury Clinic handle the data of individuals.
Atherton Physiotherapy and Sports Injury Clinic (the “Company”) is committed to maintaining robust privacy protections for its users. We will take the necessary steps to ensure that users information is safeguarded and kept in accordance with applicable laws and regulations.
This Policy forms part of our terms and conditions and is designed to help you understand how we collect, use, share and safeguard information we receive from our other organisations and clients.
What information do we collect?
Information provided to us:
From a Data Controller
Data is only held on the grounds that we have a contractual obligation to fulfil.
We undertake to protect all personal and sensitive data that is provided to us and in a manner that is consistent with the requirements of the General Data Protection Regulation (GDPR). We will take reasonable measures to ensure the secure storage of all data, see below.
From clients
All data given by clients is recorded by us in accordance with the client’s preferences and as permitted under the GDPR. Data will be held on one of the following grounds; with a client’s specific consent; where data retention is necessitated by a contractual relationship; and on the grounds of being a legitimate business interest.
Information we get from other sources
From time to time, we may need to obtain information from third parties. This will only apply where it is essential for the provision of our services and as permitted by law. Where applicable we will seek the consent of the client or organisation providing the data.
How we use personal information
Where we act as a Data Processor, we undertake the following obligations in accordance with the GDPR:
we only act under the documented instructions of the Data Controller
To ensure confidentiality, assist with legal compliance of the Data Controller, and respond to requests from data subjects (as instructed by the Data Controller)
Make available all information necessary to demonstrate compliance
To take measures to assist the Data Controller with ensuring security of processing
To treat personal data after processing as directed by the Data Controller.
Client data is not used by us for any marketing purpose, except with the express consent of the client.
Sharing Information
Disclosure
We don’t share, sell, or distribute your data to third parties.
If it is necessary to share data with a subcontractor working on our behalf, the Data Controller will be informed without delay. Any third party must adhere to all data protection laws and regulations.
We may disclose personal information if we are required to do so by law, in connection with any legal proceedings, and in order to establish, exercise or defend our legal rights.
Data Retention
We keep all personal information in accordance with our Data Retention Policy which reflects our needs to provide our services to you as contracted and also to meet legal, statutory and regulatory obligations. We will only retain data that is necessary and this will include data relating to the physiotherapy that we have provided to clients. The need to hold information is regularly reviewed and information/data will be disposed of when no longer required.
All disposal is carried out securely and records will be destroyed so that they are not retrievable.
Data Storage
We use Blue Zinc TM2 to store records such as client notes and diary appointments. All data is password protected and encrypted. Payments are taken by using the First Data card reader and processed via their gateway. You should refer to their privacy policy at https://www.firstdata.com/en_gb/privacy.html. We regularly carry out tests to ensure our compliance with keeping data secure.
In addition, we regularly review our procedures for secure data storage to ensure that all appropriate measures are adopted. In accordance with data protection legislation, data records are stored in a locked cabinet and electronic storage is protected by a user’s password that is individual to the user.
Any information that you supply to us may be stored and processed by servers hosting our website. Data will only be transferred outside EEA countries in accordance with the relevant data protection laws.
Data Subject Rights
As a data processor we understand that we have an obligation under the GDPR to comply with our obligations to the following:
Subject Access Requests
The General Data Protection Regulation (GDPR) gives individuals, known as ‘data subjects’, the right to access personal data that is held by organisations by a subject access request (SAR). We will endeavour to respond quickly to any such requests, which legally require us to respond within one month of receiving the request and necessary information.
Right to Rectification
Data subjects have the right to request that we amend or change personal information that we, that is inaccurate or incorrect. We will act on any request without delay as instructed by you as Data Controller.
Right to erasure
Data subjects have the right to ask us to delete personal information from our systems without giving any reason and at any time. We will act on any request without delay as instructed by you as Data Controller.
Right to restrict processing
Data subjects have the right to rectification or erasure of personal data certain circumstances. We will act on any request without delay as instructed by you as Data Controller
Right to data portability
Data subjects have the right to obtain and transfer their data to different service providers. We will act on any request without delay as instructed by you as Data Controller.
Right to object
Data subjects have the right to object to the processing of data at any time based on their particular situation. This includes objecting to profiling unless it is in the ‘public interest’ or exercised lawfully by an official authority. We will only process data where we can demonstrate lawful grounds for doing so. We will act on any request without delay as instructed by you as Data Controller.
Right not to be subject to decisions based on automated processing
We do not use any automated processing that results in any automated decision based on a data subject’s personal information.
Important Information
Questions and queries
If you have any concerns about how we handle data, you can contact the Data Controller by writing to us at Atherton Physiotherapy and Sports Injury Clinic, Laburnum Street, Atherton, Manchester M46 9FP or by email to athertonphysio@gmail.com.
Changes to this policy
We reserve the right to amend this Statement at any time to meet the requirements of the GDPR and our role as a data processor. Any significant changes will be mutually agreed.
Complaints
If you have a complaint about the use of data by us, you can email us at athertonphysio@gmail.com. Alternatively, you can formally report an issue of concern to the Information Commissioner’s Office, the UK body that governs Data Protection. See https://ico.org.uk
© 2018 Atherton Physiotherapy and Sports Injury Clinic | GDPR Statement