The Practice, Green Arbor Dental Practice Ltd, aims to meet the requirements of the General Data Protection Regulation (GDPR) 2018, the guidelines on the Information Commissioner’s website as well as our professional guidelines and requirements. This means that we will ensure that your information is processed fairly and lawfully.
The data controller is Monika Redding of Green Arbor Dental Practice Ltd. Monika Redding is the Information Governance Lead and Confidentiality and Data Protection Act Lead, supported by Leanne Mace & Rosemary Cooper.
What personal data do we hold?
So that we can provide you with a high standard of dental care and attention, we need to hold personal information about you. You will be asked to provide personal information when joining the practice. The purpose of us processing this data is to provide optimum health care to you.
This personal data comprises:
- Your past and current medical and dental condition; personal details such as your age, national insurance number/NHS number (only relevant to NHS practices), address, telephone number and your general medical practitioner
- Radiographs, clinical photographs and study models
- Information about the treatment that we have provided or propose to provide and its cost
- Notes of conversations/incidents that might occur for which a record needs to be kept
- Records of consent to treatment
- Any correspondence relating to you with other health care professionals, for example in the hospital or community services.
The categories of data we process are:
- Personal data for the purposes of staff and self-employed team member management
- Personal data for the purposes of [direct mail/email/text/other] marketing
- Special category data including health records for the purposes of the delivery of health care
- Special category data including health records and details of criminal record checks for managing employees and contracted team members
Why do we hold information about you?
We need to keep comprehensive and accurate personal data about our patients in order to provide them with safe and appropriate dental care. We will ask you yearly to update your medical history and contact details.
We never pass your personal details to a third party unless we have a contract for them to process data on our behalf and will otherwise keep it confidential. If we intend to refer a patient to another practitioner or to secondary care such as a hospital we will gain the individual’s permission before the referral is made and the personal data is shared.
- Personal data is stored in the EU whether in digital or hard copy format
- Personal data is stored in the US in digital format when the data storage company is certified with the EU-US Privacy Shield
- Personal data is obtained when a patient joins the practice, when a patient is referred to the practice and when a patient subscribes to an email list.
The lawful basis for processing special category data such as patients’ and employees’ health data is:
- Processing is necessary for the purposes of preventative or occupational medicine, for assessing the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or management of health or social care systems and services on the basis of Union or Member State law or a contract with a health professional
- The lawful basis of processing personal data such as name, address, email or phone number is:
- Consent of the data subject
- Processing is necessary for the performance of a contract with the data subject or to take steps to enter into a contract.
We will process personal data that we hold about you in the following way:
We will retain your dental records and any study models and casts while you are a practice patient and after you cease to be a patient, for at least 10 years, or for children until age 25, whichever is the longer. The retention periods for other personal data is 2 years after it was last processed. The retention period for staff records is 6 years. Details of other retention periods are available in the Record Retention Procedure available from the practice.
You have the following personal data rights:
- The right to be informed
- The right of access
- The right to rectification
- The right to erasure (clinical records must be retained for a certain time period)
- The right to restrict processing
- The right to data portability
- The right to object
Further details of these rights can be seen in our Information Governance Procedures or at the Information Commissioner’s website. Here are some practical examples of your rights:
If you are a patient of the practice you have the right to withdraw consent for important notifications, newsletters, surveys or marketing. You can inform us to correct errors in your personal details or withdraw consent from communication methods such as telephone, email or text. You have the right to obtain a free copy of your patient records within one month.
If you are not a patient of the practice you have the right to withdraw consent for processing personal data, to have a free copy of it within one month, to correct errors in it or to ask us to delete it. You can also withdraw consent from communication methods such as telephone, email or text.
We have carried out a Privacy Impact Assessment and you can request a copy from the details below. The details of how we ensure security of personal data is in our Security Risk Assessment and Information Governance Procedures.
Security of information
Personal data about you is held in the practice’s computer system and/or in a manual filing system. The information is not accessible to the public and only authorised members of staff have access to it. Our computer system has secure audit trails and we back up information routinely.
Disclosure of information
In order to provide proper and safe dental care, we may need to disclose personal information about you to:
- your general medical practitioner
- the hospital or community dental services
- other health professionals caring for you
- NHS payment authorities (only applicable for NHS Practices)
- the Inland Revenue
- the Benefits Agency, where you are claiming exemption or remission from NHS charges (only applicable for NHS Practices)
- private dental schemes of which you are a member.
Disclosure will take place on the ‘need-to-know’ basis, so that only these individuals/ organizations who need to know in order to provide care to you and for proper administration of Government will be given the information. Only that information that the recipient needs to know will be disclosed.
In very limited circumstances or when required by law or a court order, personal data may have to be disclosed to a third party not connected with your health care. In all other situations, disclosure that is not covered by this Code of Practice will only occur when we have your specific consent. Where possible you will be informed of these requests for disclosure.
Subject Access Request
You have the right to access information held about you. Your right of access can be exercised in accordance with the Regulations. Access may be obtained by making a request in writing. We will provide a copy of your records within 30 days of receipt of the request. There is no charge, however, where the request is manifestly unfounded or excessive, taking a minimum of 1 hr to retrieve and assemble your info, Green Arbor Dental Practice may charge a reasonable fee of £50 for the administrative costs of complying with the request.
Green Arbor Dental Practice can also charge a reasonable fee (based on administrative costs) if an individual requests further copies of their data following a request.
If you do not agree
If you do not wish personal data that we hold about you to be disclosed or used in the way that is described in this Code of Practice please discuss the matter with your dentist. You have the right to object, but this may affect our ability to provide you with dental care.
Comments, suggestions and complaints
Please contact Monika Redding at the practice for a comment, suggestion or a complaint about your data processing at firstname.lastname@example.org or calling on 01903 742693, or by writing to or visiting the practice at Green Arbor Dental Practice, Green Arbor, Rectory Road, Storrington. RH20 4EF.
We take complaints very seriously. If you are unhappy with the response you receive from us or if you need any advice you should contact the Information Commissioner’s Office (ICO). Their telephone number is 0303 123 1113, you can also chat online with an advisor. The ICO can investigate your claim and take action against anyone who’s misused personal data. You can also visit their website for information on how to make a data protection complaint.