Last updated: 6th October 23
Appointed person with responsibility for data protection: Ting Yi Yang on behalf of Centre for Complementary Health Ltd
Registered with the Information Commissioner’s Office: YES
Clinic Privacy Notice
Here at the Centre for Complementary Health, we’re committed to respecting and protecting your privacy. Any reference to ‘We’, ‘Us’ and ‘Our’ is to the Centre for Complementary Health as an organisation. Any reference to ‘Our website’ is to www.centreforcomphealth.co.uk. Any reference to ‘You’ and ‘Your’ is to you as an individual user of our websites and applications.
This notice explains when and why we collect personal information about you and how we use it, the circumstances under which we may disclose it to others, how we keep it secure and how we dispose of it. It also describes your rights in relation to your personal data.
We may change this notice from time to time and without prior notice to you. We need to do this to reflect our data protection practises. We tell you at the top of this notice when it was most recently updated. We recommend that you visit our Clinic Privacy Notice page whenever you visit our website so that you are aware of any changes.
If you have any questions about this statement and our privacy practises, please email firstname.lastname@example.org, telephone us on 01480 455221 or write to us at: The Centre for Complementary Health, 6 Cambridge Road, Godmanchester, Cambridgeshire, PE29 2BW.
Who we are
We’re a small clinic based in Cambridgeshire dedicated to meeting the needs of the local community. We aim to supplement health care in the area with our flexible approach and by building close partnerships with GPs, consultants and other health care professionals. We promote prevention injuries for many clinical conditions. We are committed to active continuous professional development for our practitioners and other like-minded professionals.
We are made up of a range of practitioners including osteopaths, physiotherapists, acupuncturists, podiatrists and an alexander technique teacher.
Treatments are carried out to the standards set by the governing and/or professional bodies of our practitioners. Please ask us if you want to know more.
Our Promise to you
Your privacy is very important to us, which is why we aim to make sure you are always in control of what we do with your personal information.
• We will never pass on your personal details to anyone outside The Centre For Complementary Health for them to use for their own marketing purposes.
• We will ensure that we obtain your express consent before we contact you by any method for any purpose.
• We will make sure our contact with you is relevant.
• You can change your mind about contact at any time by contacting us at email@example.com, telephone us on 01480 455221 or write to us at: The Centre for Complementary Health, 6 Cambridge Road, Godmanchester, Cambridgeshire, PE29 2BW. Remember, you may miss out on important news and promotions from us.
• Your personal information will be stored safely and will remain secure at all times.
• No personal information will be kept any longer than necessary in order to fulfil the purpose it was collected for.
• In certain circumstances you can ask for the data we hold about you to be erased from our records.
• We will always comply with the General Data Protection Regulation 2018. This regulation supersedes the Data Protection Act 1998 and all other applicable laws and EU Directives.
• Please let us know if your details change so that we can keep it up to date and keep in touch.
The information we collect about you
We need to collect information about you so we can provide you with the best possible experience of using our services and in order to provide you with the most appropriate healthcare.
We only collect what is relevant and necessary for administering and providing your treatment.
The lawful basis on which we collect your notes ensures we fulfil our legal obligation to collect sufficient information for the legitimate purpose of making informed clinical decisions, in order that we may promote treatment for a variety of health problems indicated for osteopathy, physiotherapy, podiatry, acupuncture and alexander technique. Such information comes under the special category of provision for health under article 9 2.(h) for sensitive data with the Information Commissioner’s Office.
In order to make appointments and for administrative purposes we will collect information about you. We will initially ask you for: patient name, address, email address, phone numbers. This data will be collected by our reception staff or practitioners when you contact us to make an appointment.
In order to provide you with health care treatment our practitioners may require detailed medical information. We will only collect what is relevant and necessary for your treatment. This is likely to include: date of birth, GP details, reason for your visit, past medical history, family medical history and current health status will be collected at clinic on arrival. All information is given by you or your carer, parent or legal guardian. This data will be collected through completing a pre-consultation form as part of our registration process before you see a practitioner for the first time. Your practitioner may collect further clinically relevant information in your appointment.
We want to protect the privacy of children aged 16 or under. If you are 16 or under you must ensure you have the permission of your parent / guardian before you provide us with any personal information.
How we store the information we collect about you
None of your personal information will be kept for any longer than is necessary in order to fulfil the purpose for which it was collected. You have the right to ask us to amend our records and in certain circumstances you can ask for the data we hold about you to be erased from our records.
Your clinical records cannot be deleted before statutory requirements for data retention – 8 years or up to 25 years of age for children aged 16 or under.
Clinical records are archived after one year
How secure is your data?
Access to your clinical records is restricted to practitioners and administration staff who have signed a confidentiality agreement.
All electronic data is password protected and access to information is restricted. Systems are kept updated.
Passwords are changed regularly.
How do we dispose of it?
Your paper clinical records will be destroyed by secure shredding after 8 years or 25 years of age for children under the age of 16.
Your electronic records will be deleted from our system after 8 years or 25 years of age for children under the age of 16.
Your communication choices and changing your personal details
Your privacy is very important to us, which is why we make sure you are always in control of what we do with your personal information.
We want to keep you up to date about news, advice, services we provide, promotional offers and other information that may be of interest to you.
We will only do this if you have given us consent to use your email address for this purpose. You be asked for your marketing preferences on your first visit. We check patients still want to receive communications on a regular basis.
If you have given us consent to use your email address for this purpose, your email address will be stored on our secure password protected marketing database, Mailchimp (based in the US but signed up to the US Privacy Shield in order to protect your data). This is used solely for the purpose of the Centre (i.e. monthly newsletter). Our emails are managed (with prior agreement and on behalf of the Centre) by DesignItWright, who have signed our Confidentiality agreement. This data is not sold. We will never pass your personal details to anyone outside The Centre For Complementary Health for them to use for their own marketing purposes.
You can unsubscribe from this service and update your personal information at any time by:
clicking the unsubscribe link on any promotional email you receive from us
contacting us by email at firstname.lastname@example.org
telephoning us on 01480 455221
Writing to us at: The Centre for Complementary Health, 6 Cambridge Road, Godmanchester, Cambridgeshire, PE29 2BW
If you unsubscribe from our marketing database you will automatically be removed and not contacted again.
Parents must give permission for communication with children aged 16 and under.
Your clinical records are only shared with other persons with your permission. This would usually be with other health professionals, and only with your explicit consent. Data would extremely rarely be shared without consent if there was a legal order or in cases of serious safety risks.
We check a small percentage of our active patient’s data records to make sure they are accurate annually.
When a patient returns for treatment after a period of a year or more we always check their patient data is still correct and up to date.
You have the right to ask for your data to be updated at any time.
Your rights as a data subject
At any point while the Centre is in possession of, or processing your personal data, you have the following rights:
• Right of access – you have the right to request a copy of the information we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.
In the event that we refuse your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge. At your request we can confirm what information we hold about you and how it is processed.
Making a Subject Access Request
All staff know that subject access requests must be responded to within a month and no charge can be made.
You can request the following information:
• Identity and the contact details of the person or organisation (practitioner) that has determined how and why to process your data.
• Contact details of the data protection officer, where applicable.
• The purpose of the processing as well as the legal basis for processing.
• The categories of personal data collected, stored and processed.
• Recipient(s) or categories of recipients that the data is/will be disclosed to.
• How long the data will be stored.
• Details of your rights to correct, erasure, restrict or object to such processing.
• Information about your right to withdraw consent at any time.
• How to lodge a complaint with the supervisory authority (ICO).
• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
• The source of personal data if it wasn’t collected directly from you.
• Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
We will only release your personal information on receipt of a signed request form with photo ID and supporting documents from you, (or your guardian if applicable) or in exceptional circumstances to comply with legal obligations, regulations or valid governmental requests. Any data sharing is detailed in the your clinical record. A Data Subject Access Request form is available on request.
Your right to make a complaint:
In the event that you wish to make a complaint about how your personal data is being processed by the Centre you have the right to complain to us. Our staff will provide you with a complaint form. If you do not get a response within 30 days, you can complain to the ICO.
The details for each of these contacts are:
Ting Yi Yang
Centre For Complementary Health, Ltd 6 Cambridge Road, Godmanchester, Cambs, PE292BW.
Tel no. +44 1480 455 221
Information Commissioners Office:
Wycliffe House, Water Lane, Wimslow SK9 5AF
Tel no: +44 (0) 303 123 1113