This section contains:
Privacy Notice for Patients
Privacy Notice for Children
Privacy Notice for Staff
Privacy Notice for Patients
1 Purpose: Cottingham Dental Practice aims to meet the requirements of the Data Protection Act 2018, the United Kingdom General Data Protection Regulation (UK GDPR), the guidelines on the Information Commissioner's (ICO) website, and our professional guidelines and requirements.
2 Registered name: the Data Controller is Robert Nichols.
3 Contact details: if you have an enquiry or request, contact: Christine Andrews, Cottingham Dental Practice, 190-192 King Street, Cottingham, East Yorkshire, HU16 5QJ, Email: info@cottinghamdp.karoo.co.uk, Tel: 01482 848655
This Privacy Notice is available on the practice website at www.cottinghamdental.co.uk or a hard copy can be requested from the practice by emailing or calling directly.
4 What information we collect, use, and why: the personal data we process includes: Name, address, contact details, gender, pronoun preferences, date of birth, nationality, medical history, dental history, family medical history, family contact details, emergency contact numbers, marital status, information about care needs, financial details, doctor's details, treatment plans, consent, X-rays, clinical photographs, digital scans, study models, appointment dates and details of complaints.
We may also process more sensitive special category data, including: Ethnicity, race, religion, health records, sex-life information or sexual orientation.
The reasons we process the data include:
a To fulfil our contract with you
b To maintain a contemporaneous clinical record
c To discuss treatment options
d To provide dental prevention and oral health advice
e To ensure any medication we prescribe is suitable
f to modify treatments based on individual neds
g To meet our obligations under the Equality Act 2010
h To carry out financial transactions
i To manage appointments, recall arrangements and send reminders
j To communicate with your next of kin in an emergency
k To communicate with parents or carers about the person being cared for
l To refer to other dentists, doctors and health professionals as required
m For debt recovery
n To continually improve the care and service you receive from us
o To assist with safeguarding or public protection concerns
p To assist with dealing with queries, complaints or claims
5 Lawful basis (Personal data): our lawful bases for processing personal data:
a A legitimate interest to provide evidence-based dental care to patients safely and effectively
b Consent of the data subject
c To comply with our legal obligations
6 Lawful basis (special category data): our Article 9 conditions for processing special category data:
a Processing is necessary for ethical and professional health care purposes
b Processing is necessary to monitor and assess the quality of opportunity or treatment between different groups
c Consent of the data subject
7 Data protection rights: you have the following personal data rights:
a The right of access – you can ask for a copy of the data we hold about you. We do not usually charge you for copies of your information; if we charge you, we will explain why
b The right to rectification – you can ask us to correct or delete information if it is inaccurate or incomplete. If we have disclosed that information to a third party, we will let them know about the change
c The right to erasure – you can ask us to delete your personal data. For legal reasons, we may be unable to erase certain information (eg information about your dental treatment). However, we can, if you ask us to, delete some contact details and other non-clinical information
d The right to restrict processing – you can ask us to limit how we use your personal data, eg stop sending you appointment reminders or information about our service
e The right to data portability – you can ask us to transfer your personal data to someone else, eg supplying your information electronically to another dentist
f The right to withdraw consent – you can withdraw your consent to the processing of your personal data at any time, eg even if you have given us your consent to send you marketing information, you may withdraw that consent
8 Where we get personal information from: we obtain your details when you enquire about our care and service, when you join the practice, when you subscribe to our newsletter or register online, when you complete a registration or medical history form, from family members or carers, and when another healthcare provider refers you for treatment at our practice
9 How long we keep information: we minimise the data that we keep and do not keep it any longer than necessary. We keep your records for 11 years after the date of your last visit to the practice or until you reach the age of 25, whichever is longer. At your request we will delete non-essential information, eg some contact details, before the end of this period
10 how we store information: we store your personal information securely on our practice computer system and in a manual filing system. Only those working at the practice have access to your information. They understand their legal responsibility to maintain confidentiality and follow practice procedures to ensure this.
We take precautions to ensure the security of the practice premises, the practice filing systems and computers.
We use high-quality specialist dental software to record and use your personal information safely and effectively. Our computer system has an audit trail, and we back up information routinely.
11 Sharing information: to provide you with appropriate care, we might need to share personal data with the following; however, only the minimum information required will be shared:
a Another dentist or another health professional who is caring for you
b Your GP or consultant
c A laboratory
d A private dental scheme, if you are a member
e Safeguarding organisations
12 Duty of confidentiality: exceptional circumstances might override the duty to maintain confidentiality. We will inform you of requests to share personal information where possible. The decision to disclose information will only be taken by senior staff. Examples include:
a Situations where there is a serious public health risk or risk of harm to other individuals
b When information is required by the police to prevent or detect crime or to apprehend or prosecute offenders (if not providing the information would prejudice these purposes)
c In response to a court order
d To enable a dentist to pursue a legal claim against a patient
13 How to complain: if you have any comments, suggestions or complaints about how we use your data, you can contact us using the contact details at the top of this privacy notice.
If you remain unhappy with our response or feel unable to discuss it with the practice, you can contact the Information Commissioner's Office (ICO) on 0303 123 1113 or by visiting www.ico.org.uk/make-a-complaint
14 Review and revision: this privacy notice is reviewed annually and updated to ensure its effectiveness and compliance with current regulations, guidance and standards.
Privacy Notice for Children
The practice keeps records of your name, address, date of birth and details of any health problems as well as details of your dental treatment and family. We keep this information to provide you with the best dental care. Your personal information is kept very confidentially and securely.
We only use your personal information to provide the best dental care and to send you reminders.
We only pass your personal information to another dentist, doctor or hospital if you have a problem that requires their special skills and you need to see them. We will not give your information to anyone else unless the law allows us to, or we need to provide it for legal reasons.
If you leave the practice, we will stop using your information, but will keep it confidential and secure until you are 25 years old (or 26 years old if you were 17 when your last treatment ended), or for 11 years after the completion of treatment, whichever is longer.
We will then review if and when we can delete it. You can always ask for a copy of the information we hold for you; we an transfer it to another dentist or doctor at your request; and you can ask us to stop using your personal information to send letters or contact you in other ways if you are no longer a patient at the practice.
If you would like a copy of the information we hold about you, or if you have any other enquiries such as correcting an error in your information or providing a copy of your information to somebody else, contact: Christine Andrews, Cottingham Dental Practice, Cottingham House, 190-192 King Street, Cottingham, East Yorkshire, HU16 5QJ
Privacy Notice for Staff
1 Purpose: Cottingham Dental Practice aims to meet the requirements of the Data Protection Act 2018, the United Kingdom General Data Protection Regulation (UK GDPR), the guidelines on the Information Commissioner’s (ICO) website and our professional guidelines.
This privacy notice explains how we process the information of our staff. It covers:
Applicants, employees and workers, including agency, casual and contracted staff, volunteers, trainees apprentices and work-experience placements.
2 Registered name: the data controller is Robert Nichols.
3 Contact details: if you have an emergency or request, contact Christine Andrews, email info@cottinghamdp.karoo.co.uk, tel: 01482 848655.
This privacy notice is also available on the practice website at wwww.cottinghamdental.co.uk or a hard copy can be requested from the practice by emailing or calling directly.
4 What information we collect, use and why: the personal data we process includes:
Name, address (including proof of address), contact details, gender, pronoun preferences, date of birth, National insurance Number, employment history, right to work information, employment contract, next of kin, emergency contact details, marital status, financial details, expenses, overtime, leave, pension details, training records, performance records, training history, occupational health records, fit notes, accident records, access needs and photo ID.
We may also process more sensitive special category data, including: Ethnicity, race, religion, health records, disabilities, criminal convictions (DBS checks), or sexual orientation.
The reasons we process the data include:
a Staff recruitment and selection
b Obtaining criminal record disclosures in line with our legal obligations
c Fulfilling our contract with you
d Ensuring we can contact you
e Maintaining staff records, including payroll, benefits etc
f Managing salaries and pensions
g Managing health and wellbeing
h Processing requests for sick pay
i Processing requests for statutory maternity/paternity leave
j Monitoring equal opportunities
k Providing facilities and access to IT systems
l Providing the training and support you need to perform your job
m Communicating about the practice, including news and events
n Managing HR processes like absence, parental leave and workforce planning
o Providing data to our regulator, CQC, as part of our public interest obligations
p Assisting with dealing with queries, complaints or claims
5 Lawful basis: our lawful bases for processing personal data:
a A legitimate interest to provide training, learning, emergency planning etc
b Consent of the data subject
c To comply with our legal obligations under UK employment law
6 Data protection rights: you have the following personal data rights:
a The right of access – you can ask for a copy of the data we hold about you
b The right to rectification – you can ask us to correct or delete information if it is inaccurate or incomplete
c The right to erasure – you can ask us to delete your personal data where there is no need for us to continue processing it and when the retention period has lapsed
d The right to restrict processing – you can ask us to limit how we use your personal data based on personal circumstances
e The right to data portability – you can ask us to transfer your personal data to someone else
f The right to object – you can object to how your information is used
g The right to withdraw consent – you can withdraw your consent to the processing of your personal data at any time
h The right to challenge any automated decision-making
7 Where we get personal information from: we obtain your details from you directly, your legal representatives and third parties, such as referees, employment agencies, occupational health providers, pension administrators, government departments (eg HMRC, DWP) and public sources (eg LinkedIn).
8 How long we keep information: we minimise the data that we keep, and do not keep it for longer than necessary.
Criminal record check information is not kept for longer than is necessary – usually not more than six months following the recruitment decision, unless a dispute is raised or, in exceptional circumstances.
The retention period for staff records is six years; however, certain information relating to team members may lawfully be kept for longer. Team members should refer to the Record Retention Schedule (M215A) for further details. Application forms and interview notes for unsuccessful candidates are kept for one year.
9 How we store information: we maintain electronic and paper records related to your recruitment and employment. The practice holds this information with your line manager. All paper files are securely stored, and only relevant staff can access them.
10 Sharing information: for legal reasons, we might need to share your data with the following; however, only the minimum information required will be shared:
a HMRC
b Our pension and healthcare schemes
c Our payroll providers
d Training providers
e Internal and external auditors
f Professional regulatory bodies, eg CQC
g The police or other law enforcement agencies, if requested by law or court order
h Relatives or guardians of an employee
11 How to complain: if you have any comments, suggestions or complaints about how we use your data, you can contact us using the contact details at the top of this privacy notice.
If you remain unhappy with our response or feel unable to discuss it with the practice, you can contact the information Commissioner’s Office (ICO) on 0303 123 1113 or by visiting www.ico.org.uk/make-a-complaint
12 Review and revision: this privacy notice is reviewed annually and updated to ensure its effectiveness and compliance with current regulations, guidance and standards. It’s also important that the personal information we hold about you is accurate and up to date. Please let us know if your information changes during your working relationship with us.