Preserving patient/customer privacy is key to running a trustworthy business. And, if you’re a business based in Europe, it’s the law.
When running a business, it’s important to respect patients’/customers’ privacy rights and follow data protection laws. As a business owner and a podiatrist, we receive certain personal information about patients/customers when they attend an appointment or purchase something or contact us with a query, such as name, postal address, email address, phone number and medical information. The European General Data Protection Regulation (GDPR) and other local data protection laws guard how this kind of personal information is collected and used, and protect the privacy rights of the public. Under these laws, patients/customers are entitled to certain information, including when, why, how, by whom, and for what purpose personal information is collected, used, and shared.
1. Personal information you collect
To aid your treatment or as part of purchasing something from my business you will normally provide me with certain information, such as your name, email address, postal address, medical information and payment information. I will store you information on an electronic patient record and diary system which is fully password protected.
2. The legal bases I rely on to collect, use, and share personal information
Why I Need Your Information and How I Use It
I rely on a number of legal bases to collect, use, and share your information, including:
where it is necessary for the purposes of the provision of health care as needed to provide my services, such as when I use your information to fulfil your podiatry assessment and treatment, or to provide customer support;
when you have provided your affirmative consent, which you may revoke at any time, such as by signing up for my mailing list;
if necessary to comply with a legal obligation or court order or in connection with a legal claim, such as retaining information about your purchases if required by tax law;
3. Marketing I undertake for my business
From time to time I may wish to send you direct marketing material which may include product offers and newsletters. If you are happy for me to do this please indicate in what forms you would like to receive this information on our patient health questionnaire form.
4. The third parties with whom you share personal information
Information Sharing and Disclosure
Information about my patients/customers is important to my business. I share your personal information for very limited reasons and in limited circumstances, as follows:
Medical professionals. With your consent I will share information with medical professionals such as your GP or consultant to allow continuity of care.
Service providers. I engage certain trusted third parties to perform functions and provide services to my business, such as orthotic prescriptions. I will share your personal information with these third parties, but only to the extent necessary to perform these services.
Business transfers. If I sell or merge my business, I may disclose your information as part of that transaction, only to the extent permitted by law and with your knowledge.
Compliance with laws. I may collect, use, retain, and share your information if I am legally required to.
5. The length of time you keep personal information
6. If transferring personal information outside of Europe, how the transfer will be handled
Transfers of Personal Information Outside the EU
I may store and process your information through third-party hosting services in the US and other jurisdictions. As a result, I may transfer your personal information to a jurisdiction with different data protection and government surveillance laws than your jurisdiction. If I am deemed to transfer information about you outside of the EU, I rely on Privacy Shield as the legal basis for the transfer, as X Cloud is Privacy Shield certified.
7. Your patients’/customers’ rights regarding your use of their personal information and your contact details
You have a number of rights in relation to your personal information. While some of these rights apply generally, certain rights apply only in certain limited cases. I describe these rights below:
Access. You have the right to access and receive a copy of the personal information I hold about you by contacting me using the contact information below.
Change, restrict, delete. You may also have rights to change, restrict my use of, or delete your personal information. In the case of health records these are normally exempt from change and deletion requests.
Object. You can object to (i) my processing of some of your information based on my legitimate interests and (ii) receiving marketing messages from me after providing your express consent to receive them. In such cases, I will delete your personal information unless I have compelling and legitimate grounds to continue using that information or if it is needed for legal reasons.
Complain. If you wish to raise a concern about my use of your information (and without prejudice to any other rights you may have), you have the right to do so with the Information Commissioner www.ico.org.uk
How to Contact Me
For purposes of the GDPR, I, (Jasmine Maddison), am the data controller of your personal information. If you have any questions or concerns, you may contact me (email@example.com). Alternately, you may mail me at: 1 Manvers Street, Trowbridge, BA14 8EH