Northwest Orthodontics Privacy Policy

Northwest Orthodontics – Privacy Notice for our patients.

The purpose of this Notice

When we provide our dental care and treatment services to you, we will collect personal information about you and your health.

We want to be open and transparent with you as to the types of information we collect about you, why we collect it, how we use it and who we may share it with.

The Data Controller of your personal information is NORTHWEST ORTHODONTICS, of 25 CLARENDON STREET, DERRY, BT48 7EP, who is registered with the General Dental Council and the Regulation and Quality Improvement Authority.

As part of our services include the provision of NHS care, we are required to appoint a Data Protection Officer who oversees our data protection compliance programmes in accordance with the relevant law and in particular the General Data Protection Regulation.

If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the bottom of this Notice in the ‘How to contact us’ section.

You also have the right to contact the Regulator at the Information Commissioner’s Office and these details are also contained in the “Contacting the Regulator” section.

How we collect patient information?

We may ask you to provide personal information by filling in hard copy forms and documents, and also during the course of our personal consultations with you or by corresponding with us by phone, letter or electronic communications to include email or SMS text messaging.

Those who have access to your information within our practice include dentists, other dental care professionals involved in your treatment; e.g.: therapists, nursing staff and reception staff responsible for the administration and smooth running of the practice.

What type of personal information will be processed and why?

Types of personal information	Why we collect it
Identity details including your name and date of birth, National Insurance Number, NHS number, address.	To carry out appropriate checks for your eligibility for treatment. We only seek to use copies of identity documents for this purpose. We collect and process this personal information in order to comply with our legal and regulatory requirements.
Your contact details including your name, postal address, phone number/s and email address/s and other personal details about you including your title, and date of birth.	To contact you in order for us to manage, administer and provide our treatment services to you. To respond to any correspondence and service-related enquiries you send to us in respect of our treatment services. To discuss products or services which you may be interested in. To communicate any updates to you including any changes to our services, the terms and conditions of any services which we have provided to you, any changes to this Notice and to our website. To contact you in order to receive your feedback on our treatment services and to participate in related surveys.

Details of your dependents (name, address and date of birth)	To enable us to provide you with services that you have requested that would involve treatment, or have an impact on, your dependents (who may be vulnerable adults or minors).
Details of contact that we have had with you such as consultations with you, discussions about your care and treatment-plans, recommendations, referrals and quotes.	To allow us to provide a professional service to you and to contact you with information about other treatment services of ours that we think you may be interested in.

Patient experience and other feedback and information you provide to us.	To review your feedback and experience with us so that we can improve our services for you and for our other patients. As required by statutory independent healthcare regulations
Information about complaints and incidents.

All of the personal information described above.	To comply with our legal duty of care and statutory independent healthcare obligations relating to the quality of care we provide to you. We may disclose your personal information to third parties where we are required to do so to comply with applicable laws and regulatory requirements including in circumstances where we are required to do so by a court Order, regulatory authority or any other third party with the lawful right to request and receive the personal information we hold about you. We may also use your personal information where it is necessary for us to take legal advice in order to establish our legal rights, to bring a claim against you or any related parties or to defend a claim from you or any related parties. We collect and process this personal information for our legitimate business interests including to carry out our own internal business planning, compliance, training, audit and quality assurance purposes.

Depending upon the types of products and services you require, we may also need to collect information from and about you which the law considers to be sensitive, such as data about your physical or mental health, which we refer to as “special category personal data”. The special category personal data that we may ask you to provide, and the reasons why we ask you to provide it, are as follows:

Types of special category personal data

Why we collect it

Information about your physical or mental health or condition; to include medical histories, clinical records, x-rays, clinical photographs, digital scans, study models, treatment plans correspondence with other health professionals

Specifically, in order for us to advise you and provide treatment services, we will need to collect information relating to your physical and mental health, to obtain accurate information to help us diagnose and to advise on the suitability of treatment. We will usually collect this information in the course offace to face consultations with you and also on specific questionnaires to develop individual clinical records and subsequent treatment plans.

We will only process the special category personal data listed above to provide appropriate dental health care and treatment to you.

In some circumstances, we may receive information about you from third parties. In particular, we may receive information about you from your own dentist who refer you to us. This may include details of the data above and will help us make the best possible assessment of your situation before we decide whether we can provide you with our professional services and/or recommend any specific treatment services. It is in our legal duty to process your personal information for this purpose.

When we record communications

We may record and/or monitor communications (including telephone conversations over landlines and emails) between our staff and you. We only record communications between us in order to comply with our legal and regulatory requirements where this relates to our treatment services provided to you.

With whom could your personal information be shared with?

We may disclose your personal information to the following categories of recipients:

Other providers of health services, insurance services in respect of whom you request us to process applications on your behalf and to receive updates from such providers in order for us to provide our services to you throughout the lifetime of our relationship with you; for e.g. NHS, your dentist or GP
Our suppliers and partners in order for them to help us provide our services to you, this includes:

Our IT systems providers to assist us with providing you with an efficient, modern and professional service.
Our suppliers of audit and regulatory compliance support services who may review our records containing your personal information in order to audit and report to us on our compliance with applicable laws and regulatory requirements; e.g. NHS payment authorities or relevant government department where exemption or remission from NS charge is claimed by you
our solicitors, professional insurers to take advice and establish our legal rights
If used suppliers of research services designed to improve our service to you.

Regulatory bodies with whom information is shared for checking eligibility for treatment purposes; for e.g.; NHS bodies

Any national and/or international regulatory, enforcement body, government agency or court where we believe disclosure is necessary

as a matter of applicable law or regulation,
to exercise, establish or defend our legal rights, or
to protect your vital interests of those of any other person; and

Any other person with your consent to the disclosure or where we are permitted to do so by law.

Our legal basis for processing personal information

Our legal basis for collecting and using your personal information will depend on the personal information concerned and the specific context in which we collect it. In respect of the personal information and the purposes for which we may process your personal information which are set out in this Notice, we have confirmed the legal basis upon which we collect and process your personal information in the ‘what type of personal information will be processed and why?’ section above.

If we ask you to provide personal information to comply with a legal requirement, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

Similarly, if we collect and use your personal information in reliance on our legitimate interests, we will make clear to you at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “How to contact us” heading below

Your data protection rights

You have the following data protection rights:

If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the “How to contact us” heading below;
In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the “How to contact us” heading below.
You have the right to opt-out of any marketing communications that we may send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing), then please contact us using the contact details provided under the “How to contact us” heading below.
Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please see “Contacting the Regulator” section below.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

Data retention

We retain personal information we collect from you where we are legally obliged to do so or if we consider that we have an ongoing legitimate need to do so, for example:

to provide you with a product or service you have requested us to provide,
to perform our contractual obligations to you;
to comply with applicable legislation
all relevant tax or accounting requirements;
to defend or manage any claims or complaints between us, you and any relevant third party including taking legal advice in respect of such claims in order to establish, exercise or defend our legal rights or such claims. This would include complaints and claims which you may bring against us or which are submitted to a court, regulatory authority or professional body.

When we have no ongoing legitimate need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Updates to this Notice

We may change or update this Notice in order to maintain our compliance with applicable law and regulation or following an update to our internal practices. When we update our Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make.

How to contact us

If you would like to contact us in relation to this Notice or if you have any other questions in respect of our processing of your personal information, please contact Mr Paul Mc Cusker BDS, MFDS, MScD, M Orth (Edin) Principal Orthodontist, at Northwest Orthodontics, 25 Clarendon Street, Derry, BT48 7EP. Tel:- 028 7136 9050.

Contacting the Regulator

If you feel that your personal data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

You can contact them by telephoning 0303 123 1113.

You can also go online to www.ico.org.uk/concerns . (We are not responsible for the content of external websites).

Northwest Orthodontics Privacy Policy

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