Privacy

This policy sets out how Frankel Dental Care, a company registered in England and Wales with registration number 07309793, whose registered office is Frankel Care Ltd, 7 Hermitage Parade, High Street, Ascot, Berkshire, SL5 7HE and uses and protects any information that you provide when you use Frankel Dental Care’s, website, mobile website or provide us with any information in the practice. Here you can read further information about how we use your data. By using Frankel Dental Care’s website, mobile website or any other information you provide, you are agreeing to the terms set out, and consenting to the use of data described, in this policy.

Frankel Care Ltd is registered with the Information Commissioners Office, registration number Z3294836.

You will be asked to provide personal information when joining the practice. The purpose of processing your personal data is to provide you with optimum dental health care and prevention.

The categories and examples of data we process are:

• Personal data for the provision of dental health care
• Personal data for the purposes of providing treatment plans, reCALL appointments, reminders or estimates
• Personal data such as details of family members for the provision of healthcare to children or for emergency contact details
• Personal data for the purposes of employed and self-employed team members employment and engagement respectively
• Personal data for the purposes of (direct mail/email/text/other) to inform you of important announcements or about new treatment and services
• Personal data – IP addresses so that we can understand our patients better and inform our marketing approach as well as improve the website experience
• Special category data including health records for the purposes of the delivery of health care and meeting our legal obligations
• Special category data including health records
• Special category data to meet the requirements of the Equality Act 2010
• Special category data details of criminal records check for employees and contracted team members

We minimise the data we keep, and do not keep it for longer than necessary.

We never pass your personal details to a third party unless we have a contract with them to process data on our behalf and will otherwise keep it confidential. If we intend to refer a patient to another practitioner or to secondary care such as a hospital, we will gain the individual’s permission before the referral is made and the personal data is shared. Your data will be shared with the NHS in England.

• Personal data is stored in the EU whether in digital or hard copy format.
• Personal data is obtained when a patient joins the practice, when a patient is referred to the practice and when a patient subscribes to an email list/other

For full details or where your data is stored, please ask to see the Information Governance Procedures.

We have established the following lawful basis for processing your data:

Our lawful bases for processing special category data:

• The legitimate interests of the dental practice
• Processing is necessary for the performance of a contract with the data subject or to take steps to enter into a contract
• Consent of the data subject
• To comply with our legal obligations
• Other

Our lawful bases for processing special category data:

• Processing is necessary for health care purposes
• Processing necessary for identifying or keeping under review the existence or absence of equality of opportunity or treatment between groups of people with the view to enabling such equality to be promoted or maintained
• We obtain consent of the data subject to process criminal records checks

The reasons we process the data include:

• To maintain your contemporaneous clinical records
• To provide you with dental treatment, prevention and oral health advice
• To carry out financial transactions with you
• To manage your NHS or HSC dental care treatment
• To send your personal data to the General Dental Council or other authority as required by law
• To communicate with you as and when required including appointment reminders, treatment plans, estimates and other communication about your treatment or the practice
• To communicate with your next of kin in an emergency
• If a parent or carer to communicate with you about the person or patient or care for
• To refer you to other dentists or doctors and health professionals as required
• To obtain criminal record disclosures for team members
• For debt recovery
• To continually improve the care and service you receive from us

The personal data we process includes:

Your name, address, gender, date of birth, NHS number, medical history, dental history, family medical history, family contact details, marital status, financial details for processing payment, your doctor’s details and details of treatment at the practice. We may process more sensitive special category data including ethnicity, race, religion, or sexual orientation so that we can meet our obligations under the Equality Act 2010, or for example to modify treatment to suit your religion and to meet NHS or HSC obligations.

The retention period for special data in patient records is a minimum of 10 years and may be longer for complex records or to meet our legal requirements. The retention period for other personal data is 2 years after it was last processed. Details of retention periods are available in the Record Retention procedure.

We obtain your personal 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.

• The right to be informed about the collection and use of personal data
• The right of access – to have a free copy of your data we have
• The right to rectification – to correct the data that we have if it is inaccurate or incomplete
• The right to deletion of your personal data (clinical records must be retained for a certain period)
• The right to restrict processing of your personal data
• The right to data portability – to have your data transferred to someone else
• The right to object to the processing of your personal data
• Rights in relation to automated decision making and profiling

Further details of these rights can be seen in our Information Governance Procedures or at the Information Commissioners Website. Here are some practical examples of your rights:

• If you are a patient of the practice you have the right to withdraw consent for important notifications, newsletters, surveys or marketing. You can inform us to correct errors in your personal details or withdraw consent from communication methods such as telephone, email or text. You have the right to obtain a free copy of your patient records within one month.
• If you are not a patient of the practice you have the right to withdraw consent for processing personal data, to have a free copy of it within one month, to correct errors in it or to ask us to delete it. You can also withdraw consent from communication methods such as telephone, email or text.

The details of how we ensure security of personal data is in our Security Risk Assessment and Information Governance Procedures.

Comments, suggestions and complaints

Please contact the IG lead at the practice for a comment, suggestion or complaint about your data processing at info@frankeldentalcare.co.uk, or 01344 297001 or by writing to or visiting the practice at 7 Hermitage Parade, High Street, Ascot, Berkshire, SL5 7HE. We take complaints very seriously.

If you are unhappy with our response or if you need any further advice, you should contact the Information Commissioners Office (ICO). Their telephone number is 0303 123 1113, you can also chat online with an advisor. The ICO can investigate your claim and act against anyone who’s misused personal data. You can also visit their website for information on how to make a data protection complaint.

Related practice procedures

You can also use these contact details to request copies of the following practice policies or procedures:

• Data Protection and Information Security Policy and consent policy
• Privacy Impact Assessment, Information Governance Procedure and Record Retention

If you have an enquiry or a request, please contact the Information Governance Lead Tanya Dandridge

• Frankel Dental Care
• 7 Hermitage Parade, High Street, Ascot, Berkshire, SL5 7HE
• Email: info@frankeldentalcare.co.uk
• Phone: 01344 482882

Data Opt-Out Policy (England)

How the NHS and care services use your information

Frankel Dental Care is one of the many organisations working in the health and care system to improve care for patients and the public. Whenever you use a health or care service, such as attending Accident & Emergency or using Community Care Services, important information about you is collected in a patient record for that service. Collecting this information helps to ensure you get the best possible care and treatment. The information collected about you when you use these services can also be used and provided to other organisations for purposes beyond your individual care, for instance to help with:

• Improving the quality standards of care provided
• Research into the development of new treatments
• Preventing illness and diseases
• Monitoring safety
• Planning Services

This may only take place when there is a clear legal basis to use this information. All these uses help to provide better health and care for you, your family and future generations. Confidential patient information about your health and care is only used like this where allowed by law.

Most of the time, anonymised data is used for research and planning so that you cannot be identified in which case your confidential patient information isn’t needed.

You have a choice about whether you want your confidential patient information to be used in this way, if you are happy with this use of information will still be used to support your individual care. To find out more or to register your choice to opt out, please visit www.nhs.uk/your -nhs-data-matters. On this web page you will

• See what is meant by confidential patient information
• Find examples of when confidential patient information is used for individual care and examples of when it is used for purposes beyond individual care
• Find out more about the benefits of sharing data
• Understand more about who uses the data
• Find out how your data is protected
• Be able to access the system view, set or change your opt-out-setting
• Find the contact telephone number if you want to know any more or to set/change your opt-out by phone
• See the situations where the opt-out will not apply

You can also find out more about how patient information is used at: https://www.hra.nhs.uk/information-about-patients (which covers health care and care research); and https://understanding patientdata.org.uk/what-you-need-to-know (which covers how and why patient information is used, the safeguards and how decisions are made)

You can change your mind about your choice at any time.

Data being used or shared for purposes beyond individual care does not include your data being shared with insurance companies or used for marketing purposes and data would only be used in this way with your specific agreement.

Health and care organisations have until 2020 to put systems and processes into place so they can be compliant with the national data opt-out and apply your choice to any confidential patient information they use or share for purposes beyond your individual care.

Our practice only uses your personal health data to provide individualised care to you and does not apply to our usage of your data and we are complaint with the policy.