Privacy Policy
INTRODUCTION
1. IB HEALTH Limited (“ib family chiropractic”) are committed to
safeguarding the privacy of our customers, website visitors and service users.
DATA CONTROLLER
2. Ib family chiropractic are data controllers for the purposes of this policy and in compliance with the provisions of the UK Data Protection General Data Protection Regulation, effective from 25 May 2018 (“GDPR”)
3. Ib family Chiropractic are registered with the Information Commissioners Office
DATA PROTECTION OFFICER
4. Ib family Chiropractic have decided that a Data Protection Officer is not required for their activities to be compliant with GDPR
DATA PROCESSING
5. Ib family Chiropractic hold and process data under varying legal basis (See Appendix One; legal basis) Our most common processes are detailed as follows:
5a:Patient Record Cards and Financial Information – Legal Basis
Legal Basis, Retention: 8 years
Specialist data: Record cards, including name, address, phone number, email, medical history, diagnosis, prognosis, treatment information and credit card details. Medical and treatment information shared across team.
Paper documents, shredded after use. Scanned and stored/backed up on
encrypted storage and cloud based storage systems with 2-factor authentication. Maintained via booking system, secured with 2-factor authentication.
JaneApp / https://jane.app/legal/privacy-policy
5b: Booking system; Reminder and Text Emails, Financial Data
Contract basis, Retention, along with record cards: 8 years
Digital, cloud based system, including name, address, phone number, date of birth and medical records.
JaneApp /
5cCard Payments
Consent basis: Stored in line with card company process, no other
processing
Card information (encrypted), email address
JaneApp
5dPhotographs and Testimonials
Consent basis – retained until consent changed or no lawful basis
Online, public domain, clinic literature, Social media, Google, Website
5eGP and Insurance Company Letters / External Referrals
Consent / Vital interests / Legitimate Interests – Annual deletion of emails,
Audit record of decision making and copies kept with record card
Digital/Letter, name, date of birth, email address, sensitive data: medical
information
Legitimate interest grounds to provide adequate sharing of information for
wider interdisciplinary health care or needs. Consent to do so will be
confirmed at clinic onboarding/initial consultation, with ability to opt out.
Ability to share information if vital interest or sufficient legitimate interest
Digital records shall be deleted after a year however printed copies form
record card, above
JaneApp
5fPatient Management Records
Legitimate interest – Annual audit and deletion of information
Name, Medical information
JaneApp /
TESTIMONIALS
6. Ib family Chiropractic may process testimonials and include the full name, company and/or employment details of the author of a testimonial
7. Ib family Chiropractic reserve the right to copy, screen shot and use comments made about Ib family Chiropractic in a public arena, such as on social media
8. Testimonials may be shared on Ib family Chiropractics website, social media, paper and/or digital marketing. They may also be shared with subcontractors, employees and service users
9. Ib family Chiropractic reserve the right to use anonymised testimonials or testimonials without use of identifiable data, where consent is not recorded following provision of a testimonial
SOCIAL MEDIA
10. Communication, engagement and actions taken through external social media platforms that this website and its owners participate on are subject to the terms and conditions as well as the privacy policies held with each social media platform respectively
11. Users are advised to use social media platforms wisely and communicate / engage upon them with due care and caution in regard to their own privacy and personal details. Neither this website nor its owners will ever ask for personal or sensitive information through social media platforms. Users wishing to discuss sensitive details should do so through primary communication channels such as by telephone or email
12. Ib family Chiropractic reserve the right to publish comments, testimonials and posts made on social media in unedited form. We use automated social media walls, social share functions on our website to reflect up to date social media engagement. Website users are reminded that engagement with these functions are at their own risk
PROVIDING YOUR DATA TO OTHERS
13. From time to time Ib family Chiropractic may contact your GP, insurance provider and/or other healthcare professionals about the status of your care. Ib family Chiropractic will gain consent from you that it is satisfactory for us to do this, however we reserve the right to do so should it be considered that there is a legal or vital interest to do so
14. Ib family Chiropractic reserve the right to breach confidentiality and share personal data where there is a public safety, legal obligation or vital interest to do so
15. Ib family Chiropractic may process any personal data identified in this policy for the establishment, exercise or defense of legal claims (whether administrative or out of court) and for the purposes of obtaining or maintaining insurance coverage, managing risks or obtaining professional advice.
16. Ib family Chiropractic might disclose personal data to our subcontractors or employees on your approval. We may also disclose some personal data on your request to other practitioners for referrals.
17. We will share transaction data with any payment services or professional accountants on in so far of processing and refunding payments, dealing with complaints and queries and to satisfy our wider financial and/or insurance
obligations.
YOUR RIGHTS: RETAINING AND DELETING INFORMATION
18. Personal data that we process, for any purpose, shall not be kept for longer than is necessary for that purpose or those purposes
19. Ib family Chiropractic respect your rights under GDPR (See definitions, Your rights). Please contact us at any time to instruct us should you feel that your rights are being infringed or for requests for further information
REQUESTING DATA
20. You have the right to confirmation as to whether or not we process your personal data. purposes of the processing, the categories of personal data concerned and the recipients of the personal data
21. You have the right to request copies of data held by Ib family Chiropractic, providing the rights and freedoms of others are unaffected
22. Requests for copies of data should be made toIb family Chiropractic. We will confirm receipt of your request.
23. The first copy will be provided free of charge. Additional copies may be subject to a reasonable fee. Pursuant to GDPR, Ib family Chiropractic reserve the right to charge for requests that are vexatious or require additional administration.
YOUR RIGHTS TO CORRECT, ERASE, OBJECT TO, RESTRICT DATA AND WITHDRAW CONSENT
24. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed
25. In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.
26. In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest
27. You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims
28. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose
29. You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest
30. If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
31. You have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal
VARIATIONS
32. Ib family Chiropractic reserve the right to change and/or vary our website, services and/or policies at any time. Please check our website to see any latest variation.
OUR DETAILS
33. Ib family Chiropractic is owned and operated by IB HEALTH Limited (Registered Company Address in England and Wales: 55 Kingsclere Road, Basingstoke RG21 6XG, Company number: 10788728)
34. Please contact us via ibfchiropractic@gmail.com or by post at the above address should you need to contact us about anything within this policy.
APPENDIX ONE: DEFINITIONS
DEFINITIONS
1. “ Cookie” – A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
2. Legal Basis – the legal bases of the processing under the GDPR are:
(i) Consent: the individual has given clear consent for you to process their personal data for a specific purpose.
(ii) Contract: the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract.
(iii) Legal obligation: the processing is necessary for you to comply with the law (not including contractual obligations).
(iv) Vital interests: the processing is necessary to protect someone’s life.
(v) Public task: the processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law.
(vi) Legitimate interests: the processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.
3: Your Rights
Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
what is GDPR? do i need to register with them? am i registered? ICO register
information commissioner office