The practice is committed to complying with the Data Protection Act 1998, the General Data Protection Regulation (GDPR), GDC, NHS and other standards.
The practice only keeps relevant information about employees for the purposes of employment, and about patients to provide them with safe and appropriate dental care.
The persons responsible for Data Protection are Pavan Gogna and Amita Aggarwal.
Our legal basis for processing data is:
Processing is necessary for the performance of our care for patients
And the healthcare data we process is called special data, our legal basis for processing it is:
“Processing is necessary for the purposes of preventative or occupational medicine, for assessing the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or management of health or social care systems and services on the basis of Union or Member State law or a contract with a health professional.”
What personal information do we need to hold
Your past and current medical & dental condition; personal details such as your age, address, telephone & medical practitioner
We may need to request details of your NHS number, your height & weight for referrals to local hospitals.
Radiographs, clinical photographs & study models
Information about treatment we have provided or purpose and it’s cost
Notes of conversations or incidents that might occur for which a record needs to be kept
Records of consent to treatment
Any correspondence relating to you with other health care professionals, for example in the hospital or community services
Hard copy and computerised records are stored, reviewed and updated securely and confidentially. Confidential information is only seen by personnel who need to see it and the team are trained on our policies and procedures to keep patient information confidential.
To facilitate patients’ health care, the personal information may be disclosed to a dentist, doctor, health care professional, hospital, NHS authorities, HMRC, the Benefits Agency (when claiming exemption or remission from NHS charges) or private dental schemes of which the patient is a member. In all cases only relevant information is shared. In very limited cases, such as for identification purposes, or if required by law, information may have to be shared with a party not involved in the patient’s health care. In all other cases, information is never disclosed to such a third party without the patient’s written authority.
All confidential information is sent via secure methods. Electronic communications and stored data are encrypted. All computerised clinical records are backed up and encrypted copies are kept off-site. No information or comments about patients are posted on social networking or blogging sites. Criminal record check information is kept securely with access strictly controlled and limited to persons who need to have access to this information in the course of their duties.
The practice has appropriate procedures to ensure personal data breaches are detected, reported and investigated effectively, including procedures to assess and then report any breaches to the ICO where the individual is likely to suffer some form of damage, e.g. through identity theft or confidentiality breach.
The practice will report serious data breaches to the ICO within 24 hours of becoming aware of the essential facts. The practice will keep a log of all personal data breaches and record the basic facts, effects of the breach and remedial action taken.
Subject Access Requests
Patients and team members can have access to view the original of their records free of charge. Copies of patient or team member records are provided following a written request using our Request for access to manual health records form, to the Practice Manager together with a payment of £10 for a copy of computerised records or £30 for a copy of paper records. Radiograph copies are charged at the current cost of taking x-rays at the practice. The requested copies will be provided within 40 days of receipt of payment.
An employee or a patient may challenge information held on record and, following the investigation, should the information be inaccurate the practice will correct the records and inform the person of the change in writing.
When the request for information is about the personal data of a child, the practice will consider if it is in the child’s best interest and not contrary to a competent child’s wishes..
When the practice receives a third-party request for information on someone else’s behalf (e.g. from a solicitor) evidence of their permission will be requested, this could be a written authority to make a request or a power of attorney.
When the practice receives a third-party request for information for a patient who lacks the mental capacity to manage their affairs the practice will ask to see evidence of a Lasting Power of Attorney or the evidence of appointment by: The Court of Protection in England & Wales;
This policy should be read in conjunction with the Confidentiality Policy and the Information Governance Procedure
Consent for Marketing
When we obtain consent for marketing such as email marketing, this consent is specific, granular, clear, prominent, opt-in, documented and easily withdrawn: We have a system used to record consent and implement appropriate mechanisms in order to ensure an effective audit trail.
Deleting Personal Data
We are required to retain your dental records, x-rays and study models while you are a patient of this practice and after you cease to be a patient, for at least 11 years or until age 25 whichever is longer. When these records are no longer required all personal date in electronic or paper form will be securely destroyed.
If you do not agree
If you do not wish personal data that we hold about you to be disclosed or used in the way that is described in this Code of Practice, please discuss the matter with your dentist. You have the right to object: however, this may affect our ability to provide you with dental care.
You have the right to withdraw your consent at any time, however this will not be retrospective.