This document refers to personal data, which is defined as information concerning any living person that is not already in the public domain. We are committed to safeguarding your personal information and we are legally obliged to use your information in line with all laws concerning the protection of personal information.
The General Data Protection Regulation (GDPR) which is EU wide and far more extensive than its predecessor the Data Protection Act, along with the Privacy and Electronic Communications Regulations (PECR), seek to protect and enhance the rights of EU data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU and its storage within the EEA.
2. Who We Are
The Putney Clinic diagnose and treat health conditions. They focus on a biopsychosocial approach to healthcare, providing services to aid patient rehabilitation, prevent injury and generally promote mind-body well-being. Treatments are carried out in accordance with the guidelines and patient charters of its practitioners’ affiliated professional bodies, where they exist. Putney Clinic also provide a range of other treatments and services, including classes provided through our affiliated company Yoga Mama Wellness, details of which can be found on our website or can be provided by our staff.
3. Personal Data
- For the purposes of providing treatment, the Putney Clinic may require detailed medical information. We will only collect what is relevant and necessary for your treatment. When you visit our practice, we will make notes which may include details concerning your medication, treatment and other issues affecting your health. This data is always held securely, is not shared with anyone that could not be involved in your treatment, although for data storage and administration purposes it may be handled by pre-vetted staff who sign an integrity and confidentiality agreement. To be able to process your personal data, it is a condition of any treatment that you give your explicit consent to allow the Putney Clinic to document and process your personal medical data. Contact details provided by you such as telephone numbers, email addresses, postal addresses may be used to remind you of future appointments, to contact you regarding settlement of payments and to provide reports or other information concerning your treatment. As part of our obligations as primary healthcare practitioners, there may be circumstances related to your treatment, on-going care or medical diagnosis that will require the sharing of your medical records with other healthcare practitioners, which may include (but is not limited to) GPs, consultants, surgeons and/or medical insurance companies. Where this is required we will inform you first unless we are under a legal obligation to comply.
- For marketing purposes, the Putney Clinic may also use the contact details provided by you to respond to your enquiries, including making telephone contact and (either directly itself or through a third party supplier) emailing information to you which the practice believes may be of interest to you.
- Some basic personal data may be collected about you from the marketing forms and surveys you complete, from records of our correspondence and phone calls and details of your visits to our website.
4. Legal basis for processing any personal data
To meet our contractual obligations obtained from explicit Patient Consent and legitimate interest, including processing payments and insurance claims on behalf of clients, and to respond to enquiries concerning the services provided.
5. Legitimate interests pursued by the Putney Clinic
To promote treatments for patients with all types of health problems including osteopathy, physiotherapy and a wide range of other general services which benefit the health and mind-body well-being of its clients.
The Putney Clinic will keep your personal information safe and secure. Only staff who could be engaged in providing treatment or services for you will have access to your patient records, although our administration team will have access to your details so that they can make appointments, process insurance payments and generally manage your account.
We may also share, receive information from or exchange information:
- with our affiliated company, Yoga Mama Wellness, by means of a shared database;
- with other practitioners and providers of services based at our premises, who may not be employed by us and, some of whom, may use our database;
- with agents or suppliers who support us to deliver our services to you or who perform essential services for us; and
- in the event of a merger, asset sale or other related transaction.
We will only share or exchange data with third parties with the protection of a written agreement and we take care to ensure they have high data security standards. Otherwise, the Putney Clinic will not disclose your personal information unless compelled to, in order to meet legal obligations, regulations or valid governmental requests. The practice may also enforce its Terms and Conditions, including: investigating potential violations of its Terms and Conditions; to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of its practitioners and staff.
8. Retention Policy
The Putney Clinic will process personal data during the duration of any treatment and will retain the personal data for eight years after the contract has expired to meet any legal obligations. Thereafter, all personal data will be deleted, unless basic information needs to be retained by us to meet our future obligations to you, such as erasure details. Records concerning minors who have received treatment will be retained until the child has reached the age of 25 (or 8 years from the date of last treatment, whichever is the greater).
Where personal information is collected for the purposes of recruitment and an applicant is unsuccessful, that information will be erased promptly.
9. Data storage
10. Your rights as a data subject
At any point whilst The Putney Clinic is in possession of, or processing, your personal data, all data subjects have the following rights:
- Right of access – you have the right to request a copy of the information that we hold about you;
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete;
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records;
- Right to restriction of processing – where certain conditions apply you have a right to restrict the processing;
- Right of portability – you have the right to have the data we hold about you transferred to another organisation;
- Right to object – you have the right to object to certain types of processing such as direct marketing; and
- Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.
In the event that the Putney Clinic refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge. At your request the Putney Clinic can confirm what information it holds about you and how it is processed.
11. You can request the following information:
- Identity and the contact details of the person or organisation (the Putney Clinic) that has determined how and why to process your data;
- Contact details of the data protection officer, where applicable;
- The purpose of the processing as well as the legal basis for processing;
- If the processing is based on the legitimate interests of the Putney Clinic and information about these interests;
- The categories of personal data collected, stored and processed;
- Recipient(s) or categories of recipients that the data is/will be disclosed to;
- How long the data will be stored;
- Details of your rights to correct, erasure, restrict or object to such processing;
- Information about your right to withdraw consent at any time;
- How to lodge a complaint with the supervisory authority (ICO);
- Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data;
- The source of personal data if it wasn’t collected directly from you; and
- Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
13. To access what personal data is held, identification will be required
The Putney Clinic will accept the following forms of identification (ID) when information on your personal data is requested: a copy of your driving licence, passport, birth certificate AND a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If the Putney Clinic is dissatisfied with the quality, further information may be sought before personal data can be released. All requests should be made to firstname.lastname@example.org or by phoning 020-8789-3881 or writing to us at the address below.
14. Links to other sites
The Putney Clinic is regulated by the Information Commissioners Office (ICO), which is responsible for regulations that cover the collection, storage, processing, disclosure, transfer and destruction of personal data in the United Kingdom and we are registered with them as a data controller.
In the event that you wish to make a complaint about how your personal data is being processed by the Putney Clinic you have the right to complain to us. If you do not get a response within 30 days, you can complain to the ICO.
The details for each of these contacts are:
Mr. Clive Lathey, Director, at:
The Putney Clinic of Physical Therapy Ltd
266 Upper Richmond Road
London, SW15 6TQ
Wilmslow, SK9 5AF
Telephone:+44 (0) 303 123 1113.