What is our full data protection policy under the General Data Protection Regulations?
This is our full data protection policy under the General Data Protection Regulation (GDPR).
Some of the following is a bit ‘heavy’, so for something more digestible (very important in Chinese medicine!) see our simplified privacy protection page.
The processing of personal data is governed by the General Data Protection Regulation 2016/679 (the GDPR). This legislation will replace current data privacy law on 25th May 2018, giving more rights to you as an individual and more obligations to organisations holding your personal data.
One of the rights is a right to be informed, which means we have to give you even more information than we do now about the way in which we use, share and store your personal information.
Jonathan Clogstoun-Willmott is the data controller of the Edinburgh Natural Health Centre and https://www.acupuncture-points.org and http://www.enhc.co.uk.
He decides how your personal data is processed and for what purposes.
This privacy notice applies to information collected from:
· prospective patients;
· former patients;
· people who subscribe to our newsletters;
· visitors to our website;
· job applicants and our current and former employees.
Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. Examples of personal data we may hold about you include your contact and appointment details.
Special category data is a sub-category of personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
Examples of special category data we may hold about you include the notes we make when you come to see us as a patient.
We comply with our obligations under the GDPR
We use your personal data for the purposes set out below.
Sections 1 – 15 below apply to our patients, prospective patients, former patients and visitors to our clinic and those who have consulted us for example by email or text or Skype or telephone, where we have kept records.
We store and transport your records predominantly in paper form but in some cases electronically.
1. We use your name, address, telephone number and email address to make and re-arrange appointments.
Note: we are unable to send or receive encrypted emails so you should be aware that any emails we send or receive may not be protected in transit. We will also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send us is within the bounds of the law.
2. We use your name, address, telephone number and email address, only if we have your explicit consent, to send you marketing materials.
We are unable to send or receive encrypted emails so you should be aware that any emails we send or receive may not be protected in transit. We will also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send us is within the bounds of the law.
3. Some patients and prospective patients return pre-first appointment questionnaires or tell us about their medical conditions and medication by telephone, email or via on-line enquiry forms.
We are unable to send or receive encrypted emails so you should be aware that any emails or questionnaires we send or receive may not be protected in transit. We will also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send us is within the bounds of the law.
4. We keep a permanent attendance register which records all appointments for patients attending our clinic
5. We may use your date of birth to help identify patients with the same name to avoid mistakes being made as to safe and appropriate treatment, for identification purposes if referring a patient to another health practitioner, and for identification purposes if writing to a registered medical practitioner so that they correctly identify the patient.
6. We use your presenting complaint and symptoms reported by you for the purposes of making a full traditional diagnosis, formulating treatment strategy and treatment planning.
7. We use any relevant medical and family history you have told us for making a full traditional diagnosis, formulating treatment strategy and treatment planning.
8. We use your GP’s name and address in the event that we need to contact your GP including in an emergency and because it is a mandatory requirement in the British Acupuncture Council’s Code of Professional Conduct.
9. We use our clinical findings about your health and well-being for making a full traditional diagnosis, and formulating treatment strategy and treatment planning.
10. We keep a record of and refer to that record of any treatment given and details of progress of your case, including reviews of treatment planning to enable us to:
11. We record and use any information and advice that we have given, especially when referring patients to any other health professional, to help you to receive the most appropriate treatment and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint.
12. We record any decisions made in conjunction with you to help you to receive the most appropriate treatment and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint.
13. We keep accident records for any patients, visitors or staff who are involved in accidents at our clinic in accordance with UK Health and Safety legislation including the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations (RIDDOR) to comply with the law and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint.
14. In the event of an adverse incident occurring from acupuncture to any of our patients we report the matter to the British Acupuncture Council and our insurance company to enable the insurance company to deal with any potential claims and to help the British Acupuncture Council to develop its safe practice guidelines, as well as providing research data and information for the BAcC’s insurers and other interested parties.
15. Where relevant we maintain records of the patient’s consent to treatment, or the consent of their next-of-kin in order to be able to prove that the patient (and/or parent/guardian/next of kin) has given informed consent to treatment to secure evidence in the event of a civil claim, criminal prosecution, insurance claim or complaint.
Note: we keep safely the above personal data for not less than 7 years and in the case of children, until age 21.
When data is destroyed, it is done so securely by a professional shredding company.
Please note that we store and transport your records in both paper form and electronically.
16. When we receive a complaint from a person we make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint.
We will only use the personal information we collect to process the complaint and to check on the level of service we provide. We usually have to disclose the complainant’s identity to whoever the complaint is about. If a complainant doesn’t want information identifying him or her to be disclosed, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis. We may need to provide personal information collected and processed in relation to complaints to the British Acupuncture Council or our insurance company.
We will keep personal information contained in complaint files in line with our retention policy. This means that information relating to a complaint will be retained for two years from closure. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.
Similarly, where enquiries are submitted to us we will only use the information supplied to us to deal with the enquiry and any subsequent issues and to check on the level of service we provide.
17. We maintain and use records of subscribers to our newsletters, only with their consent, for marketing purposes.
18. We do not use a third party provider to deliver our e-newsletters. We gather statistics around email opening and clicks using industry standard technologies including clear gifs to help us monitor and improve our e-newsletter.
19. When someone visits our website we use two third party services, Google Analytics and SBI, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google or SBI to make, any attempt to find out the identities of those visiting our website.
If we do want to collect personally identifiable information through our website, we will say so and will make it clear when we collect personal information and will explain what we intend to do with it.
20. We use website cookies to improve user experience of our website by enabling our website to ‘remember’ users, either for the duration of their visit – using a ‘session cookie’ – or for repeat visits – using a ‘persistent cookie’.
21. Our website search is powered by freefind (https://www.freefind.com)
Search queries and results are logged anonymously to help us improve our website and search functionality. No user-specific data is collected by us or any third party.
22. We use a third party service SBI to help maintain the security and performance of our website. To deliver this service it processes the IP addresses of visitors to our website.
23. We use a third party service, (SBI = Sitesell), to host our website including publishing our blog. This site is hosted by SBI/Sitesell. We use a standard SBI facility to collect anonymous information about users’ activity on the site, for example the number of users viewing pages on the site, to monitor and report on the effectiveness of the site and help us improve it. SBI requires visitors that want to post a comment to enter a name and email address.
For more information about how SBI processes data, please see SBI’s privacy notice (https://www.sitesell.com/more-info/privacy.html).
We keep your personal data for no longer than reasonably necessary.
We keep patient records for a period of no less than 7 years in accordance with the British Acupuncture Code of Professional Conduct https://www.acupuncture-points.org/data-protection-policy.html and in the case of children, until they are 25.
We keep employee records for a period of seven years in case of any legal claims/complaints and for safeguarding purposes etc.
Data is destroyed by a professional shredding company.
If Jonathan Clogstoun-Willmott is unable to practise, say because of illness, or when he dies, the data will be passed to another qualified practitioner either permanently or temporarily depending on circumstances.
At any time you may request that changes are made to your contact details.
Your personal data will be treated as strictly confidential, and will be shared:
Unless subject to an exemption under the GDPR, you have certain rights with respect to your personal data as set out below.
For further details about these rights please see the Information Commissioner’s website at https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/
If we wish to use your personal data for a new purpose, not covered by this Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.
Where and whenever necessary, we will seek your prior consent to the new processing.
To exercise all relevant rights, queries of complaints please in the first instance contact us at:
The Edinburgh Natural Health Centre
Spirit Health Gym
Holiday Inn Hotel
132 Corstorphine Road
Edinburgh EH12 6UA
You can contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.
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