Homeopathy GDPR Privacy Statement
The following statement outlines the Privacy Statement for Merran Sell’s Homeopathic Practice.
What data is collected
I collect the following data: your name, email addresses, phone numbers, address, an emergency contact phone number, name of GP or practice that you attend and answers to questions on your health history and your current state of health, records of your email correspondence with me.
Why do I collect this data?
I collect this data to use in determining the relevant remedy/ies required to support you or members of your family and to contact you via email and/or letter, of by phone, e.g. call or text.
How is this data used:
The data is used to compile a mailing list for communications with patients and in order to find the best remedy/ies for you and your family.
Where is this information kept:
The above information is stored securely and confidentially on a secure desk top computer and on a secure external hard drive.
This information is not passed onto any other party in any form whatsoever unless, in extreme cases, required by law.
How long is this information kept:
The data is kept on an ongoing basis until it is superseded, the patient no longer requires treatment or has requested to be removed from the contact list. Data will be kept for 7 years from the date of the last consultation or if under 18 years old, until your 25th birthday.
Who receives Communications from me
Communications will only be sent to patients who opt in to receive them. Opted in members are able to opt out by informing me that they wish to stop receiving them and ask to be removed from my contact list at anytime.
DATA PROTECTION POLICY
Scope of the policy
Why this policy exists
This data protection policy ensures that MS:
complies with data protection law and follows good practice
protects the rights of patients
is open about how she stores and processes patients’ data
protects herself from the risks of a data breach
Data protection principles
The General Data Protection Regulation identifies 8 data protection principles.
Principle 1 - Personal data shall be processed lawfully, fairly and in a transparent manner
Principle 2 - Personal data can only be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
Principle 3 - The collection of personal data must be adequate, relevant and limited to what is necessary compared to the purpose(s) data is collected for.
Principle 4 – Personal data held should be accurate and, where necessary, kept up to date. Every reasonable step must be taken to ensure that personal data that are inaccurate are erased or rectified without delay.
Principle 5 – Personal data which is kept in a form which permits identification of individuals shall not be kept for longer than is necessary.
Principle 6 - Personal data must be processed in accordance with the individuals’ rights.
Principle 7 - Personal data must be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
Principle 8 - Personal data cannot be transferred to a country or territory outside the European Union unless that country or territory ensures an adequate level of protection for the rights and freedoms of individuals in relation to the processing of personal data.
Certain of these principles are expanded upon in the sections that follow.
Lawful, fair and transparent data processing
MS requests personal information from patients and potential patients for the purpose of consulting with them and providing them with advice and guidance on homeopathic treatments. The forms used to request personal information may contain a privacy statement informing patients and potential patients why the information is being requested and what the information will be used for. Patients should be asked to provide consent for their data to be held and a record of this consent along with patient information will be securely held. Patients will be informed that they can, at any time, remove their consent and will be informed as to what to do should they wish to do so.
Processed for Specified, Explicit and Legitimate Purposes
Patients will be informed how their information will be used and MS will seek to ensure that patients’ information is not used inappropriately. Appropriate use of information provided by patients includes:
Communicating with patients in order to make, change or cancel consultations
Assessing the conditions and issues reported by patients and devising and prescribing relevant remedies and therapies.
MS will ensure that patients’ information is managed in such a way as to not infringe an individual’s rights which include:
The right to be informed
The right of access
The right to rectification
The right to restrict processing
The right to data portability
The right to object.
Adequate, Relevant and Limited Data Processing
MS patients will only be asked to provide information that is relevant to support consultations and prescription. This includes:
Date of birth
Where additional information may be required, this will be obtained with the specific consent of the patient who will be informed as to why this information is required and the purpose for which it will be used.
There may be occasional instances where a patient’s information needs to be shared with a third party due to an accident or incident involving statutory authorities. Where it is in the best interests of the patient or of MS, in these instances where MS has a substantiated concern then consent does not have to be sought from the individual.
Accuracy of Data and Keeping Data up to Date
IMS has a responsibility to ensure that patients’ information is kept up to date. Patients will be required to let MS know if any of their personal information changes.
Accountability and Governance
MS is responsible for ensuring that her practice remains compliant with data protection requirements and can provide evidence that it has. For this purpose, those from whom data is required will be asked to provide written consent. The evidence of this consent will then be securely held as evidence of compliance.
MS has a responsibility to ensure that data is both securely held and processed. This includes:
using strong passwords for information held within computer systems
restricting access to computer and paper-based files
using password protection on laptops and PCs that contain or access personal information
using password protection or secure cloud systems
providing adequate virus-protection and firewall software to secure computer-based systems.
Subject Access Request
MS’s patients are entitled to request access to the information that is held by her. The request needs to be received in the form of a written request to MS.
On receipt of the request, the request will be formally acknowledged and dealt with within 14 days unless there are exceptional circumstances as to why the request cannot be granted. MS will provide a written response detailing all information held on the individual. A record shall be kept of the date of the request and the date of the response.
Data Breach Notification
Were a data breach to occur, action shall be taken to minimise the harm. MS will inform any patients where she believes their personal information has been compromised. Where necessary, the Information Commissioner's Office will be notified.
If a patient contacts MS to say that they feel that there has been a breach by MS, she will ask the patient to provide an outline of their concerns. If the initial contact is by telephone, MS will ask the patient to follow this up with an email or a letter detailing their concern. The concern will then be investigated fully and a response made to the patient. Breach matters will be subject to a full investigation, records will be kept and all those involved notified of the outcome.
Policy review date: Every 2 years, e.g. May 2020