Chichester Physiotherapy and Pilates Privacy Policy

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Chichester Physiotherapy & Pilates is committed to protecting and respecting your privacy.

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To this end we comply fully with the data protection law in force in the UK (“Data Protection Laws”) and with all applicable clinical confidentiality guidelines including those published from time to time by the General Medical Council (GMC).

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This Privacy Policy sets out the basis on which we collect and process personal data about you including our practices regarding the collection, use, storage and disclosure of personal data that we collect from you and/or hold about you, and your rights in relation to that data.

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Please read the following carefully to understand how we process your personal data. By providing your personal data to us or by using our services, website or other online or digital platform(s) you are accepting or consenting to the practices as described or referred to in this Privacy Policy.

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For the purpose of Data Protection Laws, the data controller is Chichester Physiotherapy & Pilates, 3 City Business Centre, Basin Road, Chichester, BN18 0UU

When we refer to ‘we’, ‘us’ and ‘our’, we mean Chichester Physiotherapy and Pilates.

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What personal data may we collect from you?

When we refer to personal data in this policy, we mean information that can or has the potential to identify you as an individual.

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Accordingly, we may hold and use personal data about you as a customer, a patient or in any other capacity, for example, when you visit one of our websites, complete a form, access our services or speak to us.

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Personal data we collect from you may include the following:

• Information that you give us when you enquire or become a customer or patient of us including name, address, contact details (including email address and phone number)

• The name and contact details (including phone number) of your next of kin

• Details of referrals, quotes and other contact and correspondence we may have had with you

• Details of services and/or treatment you have received from us or which have been received from a third party and referred on to us

• Information obtained from surveys, promotions or competitions that you have taken part in

• Notes and reports about your health and any treatment and care you have received and/or need

• Patient feedback and treatment outcome information you provide

• Information about complaints and incidents

• Information you give us when you make a payment to us, such as financial or credit card information

• Other information received from other sources, including from your use of websites and other digital platforms we operate or the other services we provide, information from business partners, advertising networks, analytics providers, or information provided by other companies who have obtained your permission to share information about you.

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Where you have named someone as your next of kin and provided us with personal data about that individual, it is your responsibility to ensure that that individual is aware of and accepts the terms of this Privacy Policy.

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Where you use any of our websites, we may automatically collect personal data about you including:

• Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform,

• Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page.;

• We carry out work on behalf of the NHS and for the continuity of your care we may be passed medical information usually in the form of a referral for the purposes of your treatment.

• Chichester Physiotherapy and Pilates uses the services of independent consultants who carry out procedures at our clinic. Consultants may need to share your personal data and medical records with us.

• Insurance providers will pass us personal data of patients who have commenced a claim and require medical treatment with us. This will normally be in the form of a referral and may consist of basic details e.g full name, date of birth, address, contact number and email address and the type of procedure/treatment they require.

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How do we lawfully process your personal data?

Your personal data will be kept confidential and secure and will only be used for the purpose(s) for which it was collected and in accordance with this Privacy Policy, applicable Data Protection Laws, clinical records retention periods and clinical confidentiality guidelines.

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Set out below are some of the ways in which we process personal data although to do so lawfully we need to have a legal ground for doing so. We normally process personal data if it is:

• Necessary to provide you with our services - to enable us to carry out our obligations to you arising from any contract entered into between us and you including relating to the provision by us of services or treatments to you and related matter such as billing, accounting and audit, credit or other payment card verification and anti-fraud screening

• Required or allowed by any applicable law

• With your explicit consent for example: direct consumer marketing communications.

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Generally, we will only ask for your consent to processing if there is no other legal grounds to process. In these circumstances, we will always aim to be clear and transparent about why we need your consent and what we are asking it for. Where we are relying on consent to process personal data you have the right to withdraw your consent at any time by contacting us using the details below and we will stop the processing for which consent was obtained.

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To process special category data we rely on additional legal grounds and generally, they are as follows:

• With your explicit consent

• It is necessary for the purposes of preventive or occupational medicine, to assess whether you are able to work, medical diagnosis, to provide health or social care treatment, or to manage health or social care systems and services. This may also include monitoring whether the quality of our services or treatment is meeting expectations

• It is necessary to establish, make or defend legal claims or court action

• It is necessary for a public interest purpose in line with any laws that are applicable. This should assist in protecting the public against dishonesty, malpractice or other seriously improper behaviour for example, investigating complaints, clinical concerns, regulatory breaches or investigations e.g the Care Quality Commission or Health Professions Council.

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Processing of personal data which you have made public:

• As stated above, one of the legal grounds for processing data is where it is in our legitimate interest to do so, taking into account your interest's rights and freedoms. This allows us to manage the relationship that exists between you and us and can include the following reasons:

• provide you with information, products or services that you request from us

• managing all aspects of our relationship with you, our products and services and any third parties who may provide products or services on our behalf

• allow you to participate in interactive features of our services, when you choose to do so

• notify you about changes to our products or services

• keep our records up to date

• respond to requests where we have a legal or regulatory obligation to do so

• check the accuracy of information about you and the quality of your treatment or care, including auditing medical and billing information for insurance claims as well as part of any claims or litigation process

• support your doctor, or other healthcare professional

• assess the quality and/or type of care you have received (including giving you the opportunity to complete customer satisfaction surveys) and any concerns or complaints you may raise, so that these can be properly investigated

• to conduct and analyse market research

• to ensure that content from any of our websites is presented in the most effective manner for you and for your computer

• to allow us to enforce our website terms of use, our policy terms and conditions or other contracts, or to protect our or other's rights, property or safety

• to share your personal information with people or organisations in order to run our business or comply with any legal and/or regulatory obligations including to defend ourselves from claims, exercise our rights and adhere to laws and regulations that apply to us and the third parties we work with

• to take part in, or be the subject of, any sale, purchase, merger or takeover of all or part our business

• to administer your account on our Digital Wellbeing Platform and allow you to login into it, including your Healthy U account, if you have one

• to personalise the marketing emails we send you, where you have consented to us doing so

• to administer your membership to a Chichester Physiotherapy & Pilates service

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The security of your personal data

We protect all personal data we hold about you by ensuring that we have appropriate organisational and technical security measures in place to prevent unauthorised access or unlawful processing of personal data and to prevent personal data being lost, destroyed or damaged. We conduct assessments to ensure the ongoing security of our information systems.

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Any personal data you provide will be held for as long as is necessary having regard to the purpose for which it was collected and in accordance with all applicable UK laws.

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All information you provide to us is stored securely. Any payment transactions on our website will be processed securely by third party payment processors. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our website, you are responsible for keeping that password confidential. We ask you not to share a password with anyone.

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The transmission of information via the internet cannot be guaranteed as completely secure. However, we ensure that any information transferred to our websites is via an encrypted connection. Once we have received your information, we will use strict procedures and security features to minimise the risk of unauthorised access.

At your request, we may occasionally transfer personal information to you via email, or you may choose to transfer information to us via email. Email is not a secure method of information transmission; if you choose to send or receive such information via email, you do so understanding the risks associated with doing so.

How long do we retain your personal data?

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Unless we explain otherwise to you, we will retain your personal data on the basis of the following guidelines:

• for as long as we have a reasonable business need, such as managing our relationship with you and managing our business

• for as long as we provide services and/or treatment to you and then for as long as someone could bring a claim against us (in general this is a period of 8 years); and/or

• in line with legal and regulatory requirements or guidance.

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Disclosure of your personal data to third parties

In the usual course of our business we may disclose your personal data (which will be limited to the extent reasonably necessary) to certain third party organisations that we use to support the delivery of our services. This may include the following:

• business partners, suppliers and sub-contractors for the performance of any contract we enter into with you,

• organisations providing IT systems support and hosting in relation to the IT systems on which your information is stored,

• third party debt collectors for the purposes of debt collection,

• delivery companies for the purposes of transportation,

• third party service providers for the purposes of storage of information and confidential destruction, third party marketing companies for the purpose of sending marketing emails, subject to having an appropriate lawful basis for such processing.

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Where a third-party data processor is used, we ensure that they operate under contractual restrictions with regard to confidentiality and security, in addition to their obligations under Data Protection Laws.

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We may also disclose your personal data to third parties in the event that we sell or buy any business or assets or where we are required by law to do so.

Special Category/Health information collected during provision of treatment or services

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Special category data (including information relating to your health) will only be disclosed to third parties in accordance with this Privacy Policy. That includes third parties involved with your treatment or care, or in accordance with UK laws and guidelines of appropriate professional bodies. Where applicable, it may be disclosed to any person or organisation who may be responsible for meeting your treatment expenses or their agents. It may also be provided to external service providers and regulatory bodies (unless you object) for the purpose of clinical audit to ensure the highest standards of care and record keeping are maintained.

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External practitioners:

If we refer you externally for treatment, we will share with the person or organisation that we refer you to, the clinical and administrative information we consider necessary for that referral. It will always be clear when we do this.

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Your GP:

If the practitioners treating you believe it to be clinically advisable, we may also share information about your treatment with your GP. You can ask us not to do this, in which case we will respect that request if we are legally permitted to do so, but you should be aware that it can be potentially very dangerous and/or detrimental to your health to deny your GP full information about your medical history, and we strongly advise against it.

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Your insurer:

We share with your medical insurer information about your treatment, its clinical necessity and its cost, only if they are paying for all or part of your treatment with us. We provide only the information to which they are entitled. If you raise a complaint or a claim we may be required to share personal data with your medical insurer for the purposes of investigating any complaint/claim.

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The NHS:

If you are referred to us for treatment by the NHS, we will share the details of your treatment with the part of the NHS that referred you to us, as necessary to perform, process and report back on that treatment.

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Medical regulators:

We may be requested – and in some cases can be required - to share certain information (including personal data and special category data) about you and your care with medical regulators who inspect our clinical facilities and standards. For example, if you make a complaint, or if the conduct of a medical professional involved in your treatment is alleged to have fallen below the appropriate standards, a regulatory body may wish to investigate. Regulatory bodies may include the Health Professions Council. Where access to personal data is granted, we always ensure that we do so within the framework of the law and with due respect for your privacy.

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From time to time we may also make information available on the basis of necessity for the provision of healthcare, but subject always to patient confidentiality.

In an emergency and if you are incapacitated, we may also process your personal data (including special category data) or make personal data available to third parties on the basis of protecting your ‘vital interest’ (i.e. your life or your health).

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We will use your personal data in order to monitor the outcome of your treatment by us and any treatment associated with your care, including any NHS treatment.

We may participate in national audits and initiatives to help ensure that patients are getting the best possible outcomes from their treatment and care. The highest standards of confidentiality will be applied to your personal data in accordance with Data Protection Laws and confidentiality. Any publishing of this data will be in anonymised, statistical form. Anonymous or aggregated data may be used by us, or disclosed to others, for research or statistical purposes.

 

Changes to our Privacy Policy

We keep our Privacy Policy under regular review and as a result it may be amended from time to time without notice. As a result we encourage you to review this Privacy Policy regularly. This Privacy Policy was last updated in April 2020.

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For more information on the conditions we treat and services we offer, or to book an appointment please call 01243 527827 or email us at enquiries@chichesterphysiotherapy.com