GDPR Privacy Notice
Why we collect your personal data and what we do with it…
When you supply your personal details to this clinic they are stored and processed for 4 reasons (the bits in bold are the relevant terms used in the Data protection Act 2018, which includes the General Data Protection Regulation – ie the law):
1. We need to collect personal information about your health in order to provide you with the best possible treatment. Your requesting treatment and our agreement to provide that care constitutes a contract. You can, of course, refuse to provide the information, but if you were to do that we would not be able to provide treatment.
2. We have a “Legitimate Interest” in collecting that information, because without it we couldn’t do our job effectively and safely.
3. We also think that it is important that we can contact you in order to confirm your appointments with us or to update you on matters related to your medical care. This again constitutes “Legitimate Interest”, but this time it is your legitimate interest.
4. Provided we have your consent, we may occasionally send you general health information in the form of articles, advice or newsletters. You may withdraw this consent at any time – just let us know by any convenient method.
Data Retention
We have a legal obligation to retain your records for 8 years after your most recent appointment (or age 25, if this is longer), but after this period you can ask us to delete your records if you wish. Otherwise, we will retain your records indefinitely in order that we can provide you with the best possible care should you need to see us at some future date.
Data Storage
Your personal contact details, appointments, osteopathic and medical records, and payments records are stored electronically (“in the cloud”), using a specialist medical records service at the clinic location you attended (BodyMed – Clontarf, Riley Osteopathy – Baggot Street and Clonmel Osteopaths). The service provider for BodyMed and RIley Osteopathy is based in Canada, so your data is leaving the European Economic Area (EEA), but they have given us their assurances that they are fully compliant with the General Data Protection Regulations. Access to this data is password protected. Some osteopathic and medical records which have historically been collected on paper are currently held in paper files in a locked filing cabinet in a locked room. These will be progressively scanned and stored electronically (“in the cloud”), using a specialist medical records service to hold. All future patient osteopathic and medical records from BodyMed and Riley Osteopathy will be centralised using the Riley Osteopathy electronic medical record service and this information will only be shared with other practitioners at the BodyMed clinic with the express consent of the patient or the patients guardian.
Data Access
We will never share your data with anyone who does not need access without your written consent. Only the following people/agencies will have routine access to your data:
• The medical records service who store and process our files
• Your practitioner(s) in order that they can provide you with treatment
• Reception staff, because they organise our practitioners’ diaries, and coordinate appointments and reminders (but they do not have access to your medical history or sensitive personal information, only your essential contact details)
From time to time, we may have to employ consultants (such as an accountant) to perform tasks which might give them access to your personal data (but not your medical notes). We will ensure that they are fully aware that they must treat that information as confidential, and we will ensure that they sign a non-disclosure agreement. We want you to be absolutely confident that we are treating your personal data responsibly, and that we are doing everything we can to make sure that the only people who can access that data have a genuine need to do so.
Your Rights
You have the right to see what personal data of yours we hold, and you can also ask us to correct any factual errors. Provided the legal minimum period has elapsed, you can also ask us to erase your records.
Complaints
Of course, if you feel that we are mishandling your personal data in some way, you have the right to complain. Complaints need to be sent to what is referred to in the jargon as the “Data Controller”. Here are the details you need for that:
Riley Osteopathy, 65 Casino Road, Marino, Dublin 3.
Email: info@rileyosteopathy.com
Phone: 086 348 3410
If you are not satisfied with our response, then you have the right to raise the matter with the Data Protection Commissioner.
Data Protection Commissioner, 21 Fitzwilliam Square, Dublin 2, Ireland D02 RD28
Email: info@dataprotection.ie