Privacy Policy for Patient Data – The Riley Dental Studio Limited

The Riley Dental Studio takes great care to protect the personal data we hold for our patients in line with the requirements of the General Data Protection Regulation (GDPR).

The purpose of collecting and storing personal data about our patients is to ensure we can:

•    Provide, appropriate, safe and effective dental care, treatment and advice for all our patients
•    Fulfil any contracts we hold in relation to their care
•    For business administration of their care.

Personal data held for our patients
The personal data we process (processing includes obtaining the information, using it, storing it, securing it, disclosing it, and destroying it) for our patients includes:

•    Name (including any previous names), address, date of birth
•    Unique identification number (alternative reference)
•    Email address
•    Phone numbers
•    GP contact details
•    Occupation
•    Ethnicity
•    Medical history
•    Dental care records
•    Photographs
•    Family group
•    Financial information for payment plan/finance applications
•    Credit/debit cards receipts
•    Correspondence
•    Details of any complaints received
•    Details of any referrals made

We keep an inventory of personal data we hold on our patients and this is available for patients on request. A list of personal information held is also included in our Privacy Notice that is given to all patients.

Disclosure to third parties
The information we collect and store will not be disclosed to anyone who does not need to see it. We will share our patients’ personal information with third parties when required by law or to enable us to deliver a service to them or where we have another legitimate reason for doing so. Third parties we may share patients’ personal information with may include:

•    Regulatory authorities such as the General Dental Council or the Care Quality Commission
•    NHS Local Authorities
•    Dental payment plan administrators
•    Insurance companies
•    Loss assessors
•    Fraud prevention agencies
•    In the event of a possible sale of the practice at some time in the future.

We may also share personal information where we consider it to be in a patient’s best interest or if we have reason to believe an individual may be at risk of harm or abuse.

Personal privacy rights
Under the GDPR all individuals who have personal information held about them have the following personal privacy rights:

•    Right to subject access.
•    Right to have inaccuracies deleted.
•    Right to have information erased.
•    Right to object to direct marketing.
•    Right to restrict the processing of their information, including automated decision-making.
•    Right to data portability.

Patients who wish to have inaccuracies deleted or to have information erased must speak to the dentist who provided or provides their care.

Legal basis for processing data held about patients
The GDPR requires us to state the legal basis upon which we process all personal data for our patients and it requires us to inform you of the legal basis on which we process your personal data. The legal basis on which we process personal information for our private patients are:

Consent: Our patients are asked for and give clear consent for us to process their personal data for a specific purpose. It is appropriate for direct marketing, automated decision making e.g. texts and emails and for permission to share information with another individual e.g. a family member or other named person.
Vital interests: The processing is necessary to protect someone’s life for example the information detailed on your medical history questionnaire.
Legitimate interests: The processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect your personal data which overrides those legitimate interests in relation to treatment provided under a private contract.

Automated decision making
You will be asked to opt in to any processes involving automated decision making. This includes:

Consent
The Riley Dental Studio will always obtain specific, opt in consent from you for direct marketing information. Each patient is asked specifically to sign for their consent on their Medical History Questionnaire at their Dental Health Examination appointment. This information is then recorded in our dental software.

We will also obtain specific, opt in consent from you for:
•    Appointment reminders, recalls and important information (this includes but is not limited to in-formation about road closures/diversions, inclement weather, railway crossing issues) via SMS  message/s, e-mail or post.
•    Consent is obtained in order to discuss/share information about your dental appointments or any dentally related issue with a designated named person as detailed by you on your Medical History Questionnaire.

If you are a new patient, we will obtain consent when you first attend the practice. If you are an existing patient, we will obtain consent when you attend for your recall appointment or for a treatment appointment. We will refresh this consent annually when you complete a new medical history proforma.

Withdrawal of consent
After you have given your opt in consent you have a right to withdraw your consent at any time.

Retention period
This practice retains dental records while the patient is a patient of the practice and after they cease to be a patient, for at least eleven years, or for children until age 25, whichever is the longer.

Complaints
All individuals who have personal data held about them have a right to complain. All complaints concerning personal data should be made in person or in writing to Lisa Lawrence. All complaints will be dealt with in line with the practice complaints policy and procedures.

Transferring personal data outside the EU

This practice sends any necessary laboratory work, mainly via digital scanning technology to Costa Rica. Any physical laboratory work sent outside the EU will be labelled with the patient’s unique identifying number rather than the patient’s name. A record of the unique identifying number will be held at the practice.

This Policy was reviewed and implemented on 25th May 2018. This policy and relevant procedures will be reviewed annually and are due for review
on 25th May 2019 or prior to this date in accordance with new guidance or legislative changes.