Privacy Policy

We are a Data Controller under the terms of the Data Protection Act 2017 and the requirements of the EU General Data Protection Regulation.

This Privacy Notice explains what Personal Data the practice holds, why we hold and process it, who we might share it with, and your rights and freedoms under the Law.

Types of Personal Data

The practice holds personal data in the following categories:

1. Patient clinical and health data and correspondence.
2. Staff employment data.
3. Contractors’ data.

Why we process Personal Data (what is the “purpose”)

“Process” means we obtain, store, update and archive data.

1. Patient data is held for the purpose of providing patients with appropriate, high quality, safe and effective dental care and treatment.
2. Staff employment data is held in accordance with Employment, Taxation and Pensions law.
3. Contractors’ data is held for the purpose of managing their contracts.

What is the Lawful Basis for processing Personal Data?

The Law says we must tell you this:

1. We hold patients’ data because it is in our Legitimate Interest to do so. Without holding the data we cannot work effectively.
2. We hold staff employment data because it is a Legal Obligation for us to do so.
3. We hold contractors’ data because it is needed to Fulfil a Contract with us.

Who might we share your data with?

We can only share data if it is done securely and it is necessary to do so.

1. Patient data may be shared with other healthcare professionals who need to be involved in your care (for example if we refer you to a specialist or need laboratory work undertaken).
2. Patient data is also stored for back-up purposes with our Software back-up provider “Harrogate IT”. This data is stored in the cloud on servers located within the EU and protected with the following methods:
   1. Client-side-encryption of the contents of files with customer-controlled encryption keys
   2. Server-side-encryption with AES256 to encrypt the data at rest in cloud storage
   3. Filename encryption for local and cloud storage
   4. Secure, encrypted connections between the backup service and cloud storage

Employment data will be shared with government agencies such as HMRC.

Your Rights

You have the right to:

1. Be informed about the personal data we hold and why we hold it.
2. Access a copy of your data that we hold by contacting us directly: we will acknowledge your request and supply a response within one month or sooner.
3. Check the information we hold about you is correct and to make corrections if not
4. Have your data erased in certain circumstances.
5. Transfer your data to someone else if you tell us to do so and it is safe and legal to do so.
6. Tell us not to actively process or update your data in certain circumstances.

How long is the Personal Data stored for?

1. We will store patient data for as long as we are providing care, treatment or recalling patients for further care. We will archive (that is, store it without further action) for as long as is required for legal purposes as recommended by the NHS or other trusted experts recommend.
2. We must store employment data for six years after an employee has left.
3. We must store contractors’ data for seven years after the contract is ended.

What if you are not happy or wish to raise a concern about our data processing?

You can complain in the first instance to our Data protection Officer, who is Michael Spong and we will do our best to resolve the matter. If this fails, you can complain to the Information Commissioner at www.ico.org.uk/concerns or by calling 0303 123 1113.