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 Spa Dental Wotton LLP, the Information Governance Lead is Jade Hedges who is also the Data Protection Officer.
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:
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.
For full details or where your data is stored, please ask to see Information Governance Procedures (M 217C).
We have established the following lawful bases for processing your data:
Our lawful bases for processing personal data:
Our Article 9 conditions for processing special category data:
The reasons we process the data include:
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 (M 215) 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:
Further details of these rights can be seen in our Information Governance Procedures (M 217C) or at the Information Commissioner’s website. Here are some practical examples of your rights:
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 at firstname.lastname@example.org, or 01453 844428 or by writing to or visiting the practice at 43-45 Long Street, Wotton-Under-Edge, Gloucestershire, GL12 7BX. 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:
If you have an enquiry or a request, please contact the Information Governance Lead: Jade Hedges
Wotton Dental & Implant Clinic, 43-45 Long Street, Wotton-Under-Edge, Gloucestershire, GL12 7BX
Phone: 01453 844428
Data Opt-Out Policy
How the NHS and care services use your information
Wotton Dental & Implant Clinic is one of many organisations working in the health and care system to improve care for patients and the public. Whenever you use a health or care service, such as attending Accident & Emergency or using Community Care services, important information about you is collected in a patient record for that service. Collecting this information helps to ensure you get the best possible care and treatment. The information collected about you when you use these services can also be used and provided to other organisations for purposes beyond your individual care, for instance to help with:
This may only take place when there is a clear legal basis to use this information. All these uses help to provide better health and care for you, your family and future generations. Confidential patient information about your health and care is only used like this where allowed by law.
Most of the time, anonymised data is used for research and planning so that you cannot be identified in which case your confidential patient information isn’t needed.
You have a choice about whether you want your confidential patient information to be used in this way. If you are happy with this use of information you do not need to do anything. If you do choose to opt out your confidential patient information will still be used to support your individual care. To find out more or to register your choice to opt out, please visit www.nhs.uk/your-nhs-data-matters. On this web page you will:
You can also find out more about how patient information is used at:
https://www.hra.nhs.uk/information-about-patients/ (which covers health and care research); and
https://understandingpatientdata.org.uk/what-you-need-know (which covers how and why patient information is used, the safeguards and how decisions are made)
You can change your mind about your choice at any time.
Data being used or shared for purposes beyond individual care does not include your data being shared with insurance companies or used for marketing purposes and data would only be used in this way with your specific agreement.
NHS Health and care organisations must have systems and processes in place so they can be compliant with the national data opt-out and apply your choice to any confidential patient information they use or share for purposes beyond your individual care.
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.
Processing of Staff and Candidates’ Information
This section explains how Wotton Dental & Implant Clinic processes the information of staff and applicants for job roles within the practice.
What data do we have?
So that we can provide a safe and professional service, we need to keep certain records about our team members. We may record the following types of data:
We also record the following data which is classified as “special category”:
As part of your engagement with the practice, you may be required to undergo a Criminal Record Check. This information is not kept for longer than is necessary—usually not more than 6 months following the recruitment decision, unless a dispute is raised or, in exceptional circumstances.
Why do we have this data?
We require this data so that we can contact you, pay you and make sure you receive the training and support you need to perform your job. By law, we need to have a lawful basis for processing your personal data.
We process your data because:
We do this face to face, via phone, via email, via our website, via post, via application forms, via apps [delete or insert as appropriate all of the methods you use to communicate with your team members]
How do we share your data?
How long do we hold your data?
The retention period for staff records is 6 years, however, certain information relating to team members may lawfully be kept for longer. Team members should refer to Record Retention (M 215) for further details on how this practice keeps and deposes of staff data. Application forms and interview notes for unsuccessful candidates are kept for one year.
As an individual you have certain rights regarding our processing of your personal data, including a right to lodge a complaint with the Information Commissioner’s Office (ICO) as the relevant supervisory authority. For more information on your personal data rights, you can access information and advice on the ICO’s website.
You can request a copy of your personal file by contacting the Information Governance Lead.