Privacy Statement

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, 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.

This means that we will be publishing a new privacy notice so you can access this information, along with information about the increased rights you have in relation to the information we hold on you and the legal basis on which we are using it.

This new privacy notice comes into effect and will be published on our website on 25 May 2018

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Who are we?

New Cross Natural Therapy Centre, 394 New Cross Road, London SE14 6TY

Whose information does this privacy notice apply to?

This privacy notice applies to information we collect from:

• patients;
• prospective patients;
• former patients;
• visitors to our website;

What is personal data?

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. Special category data may be held by your practitioner and if you have told us details about your health in an email, by the Centre.

How do we process your personal data?

We comply with our obligations under the GDPR by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data. We use your personal data for the purposes set out below.

Sections 1 - 15 apply to our patients, prospective patients, former patients and visitors to our clinic

1. We use your name, address, telephone number and email address to make and rearrange appointments. We store these details in an index and electronically. 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. Some patients and prospective patients tell us about their medical conditions and medication by email. 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. We keep a permanent attendance register which records all appointments for patients attending our clinic to keep a record of when you were treated for tax purposes and to secure potential evidence in the event of a criminal prosecution, civil litigation, insurance claim or complaint to a practitioner's regulatory body.

4. 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

5. 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.

6. We maintain records of the patient's consent (or the consent of their next-of-kin) to having their details recorded and their name in the appointment book, in order to be able to prove that the patient (and/or parent/guardian/next of kin) has given informed consent to these matters to secure evidence in the event of a civil claim, criminal prosecution, insurance claim or complaint.

Section 16 applies to those who complain about our services

7. 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. This information will be stored in a file and electronically.

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 a professional association 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.

8. We use website cookies to improve user experience of our website by enabling our website to 'remember' users for the duration of their visit - using a session cookie'.

9. Our website search is powered by (insert name of website search company). 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.

Sharing your personal data

Your personal data will be treated as strictly confidential, and will be shared:

• with named third parties with your explicit consent;
• with the relevant authority such as the police or a court, if necessary for compliance with a legal obligation to which we are subject e.g. a court order;
• with your doctor or the police if necessary to protect yours or another person?s life;
• with the police or a local authority for the purpose of safeguarding a children or vulnerable adults; or
• with a practitioner?s regulatory body or insurance company or our insurance company in the event of a complaint or insurance claim being brought against th a Practitioner; or the Centre.
• our solicitor in the event of any investigation or legal proceedings being brought against us.

For further details about the situations when information about you might be shared please see the Information Commissioner?s website at https://ico.org.uk/for-the-public/personal-information/sharing-my-info/

How long do we keep your personal data?

We keep your personal data for no longer than reasonably necessary.

We keep patient contact details for a period of 7 years in accordance with the recommendations of practitioner professional organisations.

We keep employee records for a period of two years after the employee has left the Centre. We retain these records in case of legal claims or complaints.

We will store personal data on cards and electronically. If a patient returns to the Centre we will check this data for accuracy. We will destroy personal data on cards by incineration or by using a recognised firm.

At any time you may request that changes are made to your contact details.

Your rights and your personal data

Unless subject to an exemption under the GDPR, you have certain rights with respect to your personal data as set out below.

• The right to request a copy of your personal data which we hold about you.
• The right to request that we correct any personal data if it is found to be inaccurate or out of date.
• The right to request your personal data is erased where it is no longer necessary for us to retain such data.
• The right to withdraw your consent to the processing at any time. This right does not apply where we are processing information using a lawful purpose other than consent.
• The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable) [This right only applies where the processing is based on consent or is necessary for the performance of a contract with you and in either case the we are processing the data by automated means].
• The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing.
• The right to object to the processing of personal data, (where applicable) [This right only applies where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics].
• The right to be informed if your data is lost. We shall also inform the Information Commissioner's Office in accordance with the time limits in the GDPR.
• The right to lodge a complaint with the Information Commissioner's Office.

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/

Further processing

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.

Contact Details

To exercise all relevant rights, queries of complaints please in the first instance contact us at

The Directors

New Cross Natural Therapy Centre

394 New Cross Road, London SE14 6TY

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 5AE