Aisling Lalor Dental-Skin (ALDS)
WHAT IS THE PURPOSE OF THIS POLICY?
Aisling Lalor Dental-Skin (ALDS) is committed to protecting the privacy and security of your personal information.
This privacy notice describes how we collect and use personal information about patients during and after any treatment with us, in accordance with the General Data Protection Regulation (GDPR).
ALDS is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you as a patient. We are required under data protection legislation to notify you of the information contained in this privacy notice.
This notice applies to all patients of ALDS. This notice does not form part of any contract to provide services. We may update this notice at any time.
It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information. A copy of the full GDPR Policy and Procedure is available at reception.
Data Protection Law:
Data protection law says that the personal information we hold about you must be:
-Used lawfully, fairly and in a transparent way.
-Collected for the relevant purposes that have been clearly explained to you and not used in any way that is incompatible with those purposes.
-The information must be correct and up to date.
-Kept only for the purposes that we have told you about and kept as long as is necessary for those purposes.
- stored securely.
What kind of information do we hold about you?
Personal data or personal information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed, i.e. anonymous data.
“Special categories” refers to more sensitive data, which requires a higher level of protection.
We will collect, store and use the following categories of patient data:
Personal contact details such as; name, title, addresses, telephone numbers, email addresses, date of birth, gender, marital status, dependents, next of kin.
Emergency contact information,
National Insurance number
Bank account details
Medical history and dental health information.
Date of registration with ALDS,
Details of appointments as regards attended, cancelled or failed to attend.
How is your personal information collected?
We collect personal information about patients, either directly from you or it may be provided by third parties.
We will collect additional personal information in the course of marketing activities carried out by ALDS.
How will we use your information?
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
1. Where we need to perform the contract we have entered into with you.
2. Where we will need to comply with legal obligations .
3. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those rights.
We may also use your personal information in the following situations, which are likely to be rare:
1.Where we need to protect your interests (or someone else’s interests).
2.Where it is needed in the public interest or for official purposes,
3.Archiving your sensitive personal date data for use in the public interest or for scientific interest. Also, this data may be used for historical and statistical purposes.
Situations where we may use your personal information
We need all the categories of information in the list above primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below.
Administering the terms and conditions we have entered into with you.
Administering our Dental Plan Membership Scheme,
Failure to provide personal information
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as providing dental services). This may be prevented from complying with our legal obligations (such as health and safety).
Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your information for an unrelated purpose, we will notify you and we will explain the basis on which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
How we use particularly sensitive personal information
“Special categories” of particularly sensitive information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place an appropriate policy document and safeguards, which we are required by law to maintain when processing such data. We may process special categories of personal information in the following circumstances:
- 1. In limited circumstances, with your explicit written consent.
- 2. Where we need to carry out our legal obligations or exercise rights in connection with providing our services.
- 3. Where it is needed in the public interest, such as for Government Department monitoring.
Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public. We may also process such information about patients or former patients in the course of legitimate business activities with the appropriate safeguards.
Details regarding your personal identification for example, your physical condition. This includes x-ray imaging, genetic data and biometric data. Information concerning your medical history, including physical and/or mental health and your oral health or condition.
Information about discussions undertaken and agreements reached on treatment options, including costs of any proposed treatment. Information about the treatment that is planned, being undertaken or has been provided.
Information about family members and personal circumstances supplied by you or others. The amount that was paid for treatment, the amount owing, or the fact that the patient is a debtor to ALDS.
Do we need your consent?
We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of health and safety law.
In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.
Automated decision making
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:
1.Where we have notified you of the decision and given you 21 days to request a re-consideration.
2. Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights.
3. In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.
If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.
We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.
We may have to share your data with third parties, including third-party service providers and other entities in the group. We require third parties to respect the security of your data and to treat it in accordance with the law. We may transfer your personal information outside the EU.
If we do, you can expect a similar degree of protection in respect of your personal information.
Which third party service providers process my personal information?
“Third parties” includes third party service providers. These may include:
Dental Membership Plan administrators
Regulatory Services e.g.: GDC and the RQIA.
Fraud prevention agencies
Local Authorities and designated agencies
The British Dental Association (BDA)
Other agencies within our group
How secure is my information with Third-Party service providers?
All third party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third party service providers to use your personal data for their own purposes. We only permit them to process your data for specified purposes and in accordance with our instructions.
When might we share your personal information with other entities in the group?
We will share your information with other entities in the group as part of our regular reporting activities on ALDS performance, in the context of business activities such as system maintenance support and hosting of data.
What about other Third Parties?
We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of ALDS. We may also need to share your personal information with a regulator or to otherwise comply with the law.
We have put in place measures to protect the security of your information. Details of these measures are available upon request at reception or on the internet at www.lalordental.co.uk
Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure. We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized manner, altered or disclosed. In addition, we limit access to your personal information by other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with suspected data security breach and we will notify you and any applicable regulator of such a suspected breach where we are legally required to do so.
How long will my information be retained?
We will only retain your personal information as long as is necessary to fulfill the purposes of your contract, including any legal purposes, accounting, or reporting requirements. Patient data is retained for 11 years, or for children until they are 25 yrs. old or whichever is longer.
To determine the appropriate retention period we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we achieve those purposes through other means and the applicable legal requirements.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use information without further notice to you.
Rights of: access, correction, erasure and restriction.
Your duty to inform us:
It is important that the personal information we hold about you is accurate and correct. Please keep us informed of any changes during your relationship with us.
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
“data subject access request”. You may seek a copy of your personal information upon written request.
This enables you to have any incomplete or inaccurate information we hold about you corrected.
This enables you to ask us to delete or remove personal information where there isn’t
a good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
-Object to processing
Objection to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to the processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
-Request the restriction of processing
of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
-Request the transfer
of your information to another party. If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact ALDS in writing.
No Fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you.
We may need to request specific information from you to help us to confirm your identity and to ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent please contact Dr. Aisling Lalor. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Data Protection Officer
We have appointed Dr. Aisling Lalor as our Data Protection Officer to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the Data Protection Officer. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.
Changes to this Privacy Notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
Issue Date: 17-10-18