Privacy Policy

The practice aims to meet the requirements of the Data Protection Act 2018, the United Kingdom General Data Protection Regulation (UK GDPR), the guidelines on the Information Commissioner's (ICO) website as well as our professional guidelines and requirements.

The data controller is Sandip Sanghera and the Information Governance Lead

This Privacy Notice is available by calling 01242 259960 or visiting the surgery.

You will be asked to provide personal information when joining the practice. The purpose of processing your personal data is to provide you with optimum dental health care and prevention.

The categories and examples of data we process are:

Personal data for the provision of dental health care
Personal data for the purposes of providing treatment plans, recall appointments, reminders or estimates
Personal data such as details of family members for the provision of healthcare to children, or for emergency contact details
Personal data for the purposes of employed and self-employed team members' employment and engagement respective
Personal data for the purposes of direct mail/email to inform you of important announcements or about new treatments or services
Personal data - IP addresses so that we can understand our patients better and inform our marketing approach as well as improve the website experience
Special category data including health records for the purposes of the delivery of healthcare and meeting our legal obligations. Special category data including health records
Special category data to meet the requirements of the Equality Act 2010
Special category data details of criminal record checks for employees and contracted team members

We minimise the data that we keep, and do not keep it for longer than necessary.

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. Your data will be shared with the NHS if you are having NHS treatment.

NHS treatment:

Personal data is stored in the UK whether in digital or hard copy format
Personal data is stored outside of the UK and/or EU in digital format when suitable safeguards have been put in place to allow personal data to be transferred
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.

We have established the following lawful bases for processing your data:

Our lawful bases for processing personal data:

The legitimate interests of the dental practice
Processing is necessary for the performance of a contract with the data subject or to take steps to enter into a contract
Consent of the data subject
To comply with our legal obligations

Our Article 9 conditions for processing special category data:

Processing is necessary for health care purposes
Processing necessary for identifying or keeping under review the existence or absence of equality of opportunity or treatment between groups of people with the view to enabling such equality to be promoted or maintained
We obtain consent of the data subject to process criminal record checks

The reasons we process the data include:

To maintain your contemporaneous clinical records
To provide you with dental treatment, prevention, and oral health advice
To carry out financial transactions with you
To manage your NHS dental care treatment
To send your personal data to the General Dental Council or other authority as required by law
To communicate with you as and when required, including appointment reminders, treatment plans, estimates, and other communications about your treatment or the practice
To communicate with your next of kin in an emergency
If a parent or carer, to communicate with you about the person you parent or care for
To refer you to other dentists or doctors and health professionals as required
To obtain criminal record disclosures for team members
For debt recovery
To continually improve the care and service you receive from us

The personal data we process includes:

Your name, address, gender, date of birth, NHS number, medical history, dental history, family medical history, family contact details, marital status financial details for processing payment, your doctor's details and details of treatment at the practice. We may process more sensitive special category data including ethnicity, race, religion, or sexual orientation so that we can meet our obligations under the Equality Act 2010, or for example to modify treatment to suit your religion and to meet NHS obligations.

The retention period for special data in patient records is a minimum of 11 years and may be longer for complex records or to meet our legal requirements. The retention period for other personal data is 2 years after it was last processed. Details of retention periods are available in the Record Retention (M215) procedure available from the practice.

We obtain your personal details when you enquire about our care and service, when you join the practice, when you subscribe to our newsletter or register online, when you complete a registration or medical history form, and when another practitioner refers you for treatment at our practice. Occasionally, patients are referred to us from other official sources such as NHS clinics or hospitals.

You have the following personal data rights:

The right to be informed about the collection and use of your personal data
The right of access - to have a copy of the data we hold about you. Generally, we will not charge for this service
The right to rectification - to correct the data we have if it is inaccurate or incomplete
The right to deletion of your personal data (clinical records must be retained for a certain time period)
The right to restrict processing of your personal data
The right to data portability - to have your data transferred to someone else
The right to object to the processing of your personal data
Rights in relation to automated decision making and profiling

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 in Sensitive Information Map, PIA and Risk Assessment (M 217Q), 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 (M 217M) and Information Governance Procedures (M 217C).

Comments, suggestions and complaints

Please contact the IG Lead at the practice for a comment, suggestion or a complaint about your data processing by writing to or visiting the practice at Gratton House, Gratton Street, Cheltenham, Gloucestershire, GL50 2AS. We take complaints very seriously.

If you are unhappy with our response, 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.

Related practice procedures

You can also use these contact details to request copies of the following practice policies or procedures:

Data Protection and Information Security Policy (M 233-DPT), Consent Policy (M 233-CNS)
Sensitive Information Map, PIA and Risk Assessment (M 217Q), Information Governance
Procedures (M 217C), Record Retention (M 215)

If you have an enquiry or a request, please contact the Information Governance Lead

Thank you.

‍

Our practice only uses your personal health data to provide individualised care to you and does not disclose your data for any other purposes. The national data opt-out does not apply to our usage of your data and we are compliant with the policy.