Privacy Policy
Welcome to our Privacy Notice
This notice sets out how we handle your personal information
Who are ‘we’?
Crowthorne Health is the data controller – Toni Hennings, Crowthorne Health, Lower Wokingham Road, Crowthorne, RG45 6DB. This means we decide how your personal data is processed and for what purposes.
Whose information does this privacy notice apply to?
This privacy notice applies to information we collect from:
- patients;
- prospective patients;
- former patients;
- people who subscribe to any newsletters;
- visitors to our website;
- visitors of the booking system;
- users of the payment system;
What is personal data?
Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. Examples of personal data we may hold about you include your contact and appointment details.
Special category data is a sub-category of personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. Examples of special category data we may hold about you include your patient notes.
How do we process your personal data?
We comply with our obligations under the GDPR by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data. We use your personal data for the purposes set out below.
Sections 1 – 15 apply to our patients, prospective patients, former patients and visitors to the clinic
- We use your name, address, telephone number and email address to make and rearrange appointments. We are unable to send or receive encrypted emails so you should be aware that any emails we send or receive may not be protected in transit. We will also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send us is within the bounds of the law.
- We use your name, address, telephone number and email address, only if we have your explicit consent, to send you marketing materials. We are unable to send or receive encrypted emails so you should be aware that any emails we send or receive may not be protected in transit. We will also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send us is within the bounds of the law.
- Some patients and prospective patients return pre- 1stappointment questionnaires or tell us about their medical conditions and medication by email or online enquiry forms. We are unable to send or receive encrypted emails so you should be aware that any emails we send or receive may not be protected in transit. We will also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send us is within the bounds of the law.
- We keep a permanent online booking and attendance register which records all appointments for patients attending our clinic to keep a record of when you were treated for tax purposes and to secure potential evidence in the event of a criminal prosecution, civil litigation, insurance claim or complaint to my regulatory body, the British Acupuncture Council. The online booking and scheduling provider used is Acuity Scheduling.
- We may use your date of birth to help identify patients with the same name to avoid mistakes being made as to safe and appropriate treatment, for identification purposes if referring a patient to another health practitioner, and for identification purposes if writing to a registered medical practitioner so that they correctly identify the patient. This information is stored electronically and is protected by security and access controls including username and password.
- We use your presenting complaint and symptoms reported by you for the purposes of making a full traditional diagnosis, formulating treatment strategy and treatment planning. This information is stored electronically and is protected by security and access controls including username and password.
- We use any relevant medical and family history you have told us for making a full traditional diagnosis, formulating treatment strategy and treatment planning. This information is stored electronically and is protected by security and access controls including username and password.
- We use your GP’s name and address in the event that we need to contact your GP including in an emergency and because it is a mandatory requirement in the British Acupuncture Code of Professional Conduct. This information is stored electronically and is protected by security and access controls including username and password.
- We use our clinical findings about your health and wellbeing for making a full traditional diagnosis, and formulating treatment strategy and treatment planning. This information is stored electronically and is protected by security and access controls including username and password.
- We keep a record of and refer to that record of any treatment given and details of progress of your case, including reviews of treatment planning to enable us to: review the full traditional diagnosis, treatment strategy and planning; and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint. This information is stored electronically and is protected by security and access controls including username and password.
- We record and use any information and advice that we have given, especially when referring patients to any other health professional, to help you to receive the most appropriate treatment and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint. This information is stored electronically and is protected by security and access controls including username and password .
- We record any decisions made in conjunction with you to help you to receive the most appropriate treatment and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint. This information is stored electronically and is protected by security and access controls including username and password.
- We keep accident records for any patients, visitors or staff who are involved in accidents at our clinic in accordance with UK Health and Safety legislation including the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations (RIDDOR) to comply with the law and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint. This information is stored electronically and is protected by security and access controls including username and password, and where appropriate hardcopies made and stored in a locked secure location.
- In the event of an adverse incident occurring to any of our patients we report the matter to the British Acupuncture Council and our insurance company to enable the insurance company to deal with any potential claims and to help the British Acupuncture Council to develop its safe practice guidelines, as well as providing research data and information for the BAcC’s insurers and other interested parties.
- Where relevant we maintain records of the patient’s consent to treatment, or the consent of their next-of-kin in order to be able to prove that the patient (and/or parent/guardian/next of kin) has given informed consent to treatment to secure evidence in the event of a civil claim, criminal prosecution, insurance claim or complaint. This information is stored electronically and is protected by security and access controls including username and password, and as a hardcopy, stored in a locked secure location.
Section 16 applies to those who complain about our services
- When we receive a complaint from a person we make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint.
We will only use the personal information we collect to process the complaint and to check on the level of service we provide. We usually have to disclose the complainant’s identity to whoever the complaint is about. If a complainant doesn’t want information identifying him or her to be disclosed, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis. We may need to provide personal information collected and processed in relation to complaints to the British Acupuncture Council or our insurance company.
We will keep personal information contained in complaint files in line with our retention policy. This means that information relating to a complaint will be retained for two years from closure. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.
Similarly, where enquiries are submitted to us we will only use the information supplied to us to deal with the enquiry and any subsequent issues and to check on the level of service we provide.
Sections 17 and 18 apply to subscribers to our newsletters
- We maintain and use records of subscribers to our newsletters, only with their consent, for marketing purposes.
- We use email to deliver our e-newsletters.
Sections 19 – 22 apply to our website users and third-party services
19. When someone visits our website we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.
20. We use website cookies to improve user experience of our website by enabling our website to ‘remember’ users, either for the duration of their visit – using a ‘session cookie’ – or for repeat visits – using a ‘persistent cookie’.
21 .When someone visits the link to the booking Website, we use a online service, Acuity Scheduling, In order to protect your information, we take care where possible to work with subcontractors and service providers who we believe maintain an acceptable standard of data security compliance.
22. Use of the payment services is through an online service, Squareup. In order to protect your information, we take care where possible to work with subcontractors and service providers who we believe maintain an acceptable standard of data security compliance.
How long we keep your information
We retain your information for as long as necessary to provide the services to you and to comply with our legal obligations and the Professional Body, Code of Professional Conduct for our legitimate interests, to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce the terms of service and take other actions permitted by law. The information we retain will be handled in accordance with this Privacy Policy.
If you have any questions about our privacy practices or the way in which we have been managing your personal information, please contact our Data Controller, Toni Hennings, toni@crowthornehealth.co.uk