Data Protection Policy

(Why we collect your personal data and what we do with it)

When you supply your personal details to this clinic they are stored and processed for 4 reasons (the bits in bold are the relevant terms used in the Data protection Act 2018, which includes the General Data Protection Regulation – ie the law):

1. We need to collect personal information about your health in order to provide you with the best possible treatment. Your requesting treatment and our agreement to provide that care constitutes a contract. You can, of course, refuse to provide the information, but if you were to do that we would not be able to provide treatment.
2. We have a “Legitimate Interest” in collecting that information, because without it we couldn’t do our job effectively and safely.
3. We also think that it is important that we can contact you in order to confirm your appointments with us or to update you on matters related to your treatment. This again constitutes “Legitimate Interest”, but this time it is your legitimate interest.
4. Provided we have your consent, we may occasionally send you general health information in the form of articles, advice or newsletters. You may withdraw this consent at any time – just let us know by any convenient method.

We have a legal obligation to retain your records for 8 years after your most recent appointment (or age 25, if this is longer), but after this period you can ask us to delete your records if you wish. Otherwise, we will retain your records indefinitely in order that we can provide you with the best possible care should you need to see us at some future date.
Your records are stored on paper, in locked filing cabinets, and the offices are always locked out of working hours. Should you order Chinese Herbal Medicine it will be necessary to share your data with the herbal provider. This provider has given us their assurances that they are fully compliant with the General Data Protection Regulations. This information is shared via email or by an online order form which only the practitioner and the supplier has access to. Access to this data is password protected, and the passwords are changed regularly on our computers. These are password-protected, backed up regularly, and the office are locked away out of working hours.

We will never share your data with anyone who does not need access without your written consent. Only the following people/agencies will have routine access to your data:
• Your practitioner(s) in order that they can provide you with treatment
• Centre staff, because they collect attendance numbers for services operating in the centre (they do not have access to your medical history or sensitive personal information)
• Our bookkeeper when reviewing financial records. They will not have access to your medical notes, just your name and amounts paid for treatments.
• Dispensary staff when ordering Chinese Herbal Medicine to ensure that the correct herbal formula is matched, where possible a code system is used containing initials and the date ordered. There is no access to medical records or sensitive information.

From time to time, we may have to employ consultants to perform tasks which might give them access to your personal data (but not your medical notes). We will ensure that they are fully aware that they must treat that information as confidential, and we will ensure that they sign a non-disclosure agreement.
You have the right to see what personal data of yours we hold, and you can also ask us to correct any factual errors. Provided the legal minimum period has elapsed, you can also ask us to erase your records.

We want you to be absolutely confident that we are treating your personal data responsibly, and that we are doing everything we can to make sure that the only people who can access that data have a genuine need to do so.

Of course, if you feel that we are mishandling your personal data in some way, you have the right to complain. Complaints need to be sent to what is referred to in the jargon as the “Data Controller”. Here are the details you need for that:
Philip Trubshaw
The Angel Centre
1 St Philip’s Place
M3 6FA

If you are not satisfied with our response, then you have the right to raise the matter with the Information Commissioner’s Office.