Patient Privacy Notice
The practice aims to meet the requirements of the Data Protection Act 2018, the General Data Protection Regulation (GDPR), the guidelines on the Information Commissioner’s website as well as our professional guidelines and requirements.
The Data Controller is the Partners of John G Plummer & Associates Dental Surgeons, the Information Governance Lead is Andrew Cross who is also the Data Protection Officer.
This Privacy Notice is available on the practice website at www.plummers.co.uk/privacynotice / at reception/ by email if you contact email@example.com / by calling 01493 378200. You will be asked to provide personal information when joining the practice. The purpose of processing your personal data is to provide you with optimum dental health care and prevention. The categories and examples of data we process are:
- Personal data for the provision of dental health care
- Personal data for the purposes of providing treatment plans, recall appointments, reminders or estimates
- Personal data such as details of family members for the provision of health care to children or for emergency contact details
- Personal data for the purposes of employed and self-employed team members employment and engagement respectively
- Personal data for the purposes of direct mail/email/text/other to inform you of important announcements or about new treatments or services
- Personal data – IP addresses so that we can understand our patients better and inform our marketing approach as well as improve the web site experience
- Special category data including health records for the purposes of the delivery of health care and meeting our legal obligations
- Special category data including health records
- Special category data to meet the requirements of the Equality Act 2010
- Special category data details of criminal record checks for employees and contracted team members
We minimise the data that we keep, and do not keep it for longer than necessary. We never pass your personal details to a third party unless we have a contract for them to process data on our behalf and will otherwise keep it confidential. If we intend to refer a patient to another practitioner or to secondary care such as a hospital, we will gain the individual’s permission before the referral is made and the personal data is shared. Your data will be shared with the NHS in England, Scotland and Wales or the HSC in Northern Ireland if you are having NHS or HSC treatment.
- Personal data is stored in the EU whether in digital or hard copy format
- Personal data is stored in the US in digital format when suitable safeguards have been put in place to allow personal data to be transferred out of the EU
- Personal data is obtained when a patient joins the practice, when a patient is referred to the practice and when a patient subscribes to an email list / other
For full details or where your data is stored, please ask to see Information Governance Procedures. We have established the following lawful bases for processing your data:
- The legitimate interests of the dental practice
- Processing is necessary for the performance of a contract with the data subject or to take steps to enter into a contract
- Consent of the data subject
- To comply with our legal obligations
Our lawful bases for processing special category data:
Processing is necessary for health care purposes
Processing necessary for identifying or keeping under review the existence or absence of equality of opportunity or treatment between groups of people with the view to enabling such equality to be promoted or maintained
We obtain consent of the data subject to process criminal record checks
The reasons we process the data include:
To maintain your contemporaneous clinical records
To provide you with dental treatment, prevention and oral health advice
To carry out financial transactions with you
To manage your NHS or HSC dental care treatment
To send your personal data to the General Dental Council or other authority as required by law
To communicate with you as and when required including appointment reminders, treatment plans, estimates and other communications about your treatment or the practice
To communicate with your next of kin in an emergency
If a parent or carer to communicate with you about the person you parent or care for
To refer you to other dentists or doctors and health professionals as required
To obtain criminal record disclosures for team members
For debt recovery
To continually improve the care and service you receive from us
The personal data we process includes:
Your name, address, gender, date of birth, NHS number, medical history, dental history, family medical history, family contact details, marital status, financial details for processing payment, your doctor’s details and details of treatment at the practice. We may process more sensitive special category data including ethnicity, race, religion, or sexual orientation so that we can meet our obligations under the Equality Act 2010, or for example to modify treatment to suit your religion and to meet NHS or HSC obligations.
The retention period for special data in patient records is a minimum of 10 years and may be longer for complex records or to meet our legal requirements. The retention period for staff records is 6 years. The retention periods for other personal data is 2 years after it was last processed. Details of retention periods are available in the Record Retention procedure available from the practice.
We obtain your personal details when you enquire about our care and service, when you join the practice, when you subscribe to our newsletter or register online, when you complete a registration or medical history form and when another practitioner refers you for treatment at our practice. Occasionally patients are referred to us from other official sources such as NHS clinics or hospitals.
You have the following personal data rights:
The right to be informed about the collection and use of your personal data
The right of access – to have a copy of the data we hold about you. Generally, we will not charge for this service
The right to rectification – to correct the data we have if it is inaccurate or incomplete
The right to deletion of your personal data (clinical records must be retained for a certain time period)
The right to restrict processing of your personal data
The right to data portability – to have your data transferred to someone else
The right to object to the processing of your personal data
Rights in relation to automated decision making and profiling
Further details of these rights can be seen in our Information Governance Procedures or at the Information Commissioner’s website. Here are some practical examples of your rights:
If you are a patient of the practice, you have the right to withdraw consent for important notifications, newsletters, surveys, or marketing. You can inform us to correct errors in your personal details or withdraw consent from communication methods such as telephone, email, or text. You have the right to obtain a free copy of your patient records within one month
If you are not a patient of the practice you have the right to withdraw consent for processing personal data, to have a free copy of it within one month, to correct errors in it or to ask us to delete it. You can also withdraw consent from communication methods such as telephone, email, or text
We have carried out a Privacy Impact Assessment in our Sensitive Information Map, PIA and Risk Assessment and you can request a copy from the details below. The details of how we ensure security of personal data is in our Security Risk Assessment and Information Governance Procedures.
Comments, suggestions and complaints
Please contact the IG Lead at the practice for a comment, suggestion or a complaint about your data processing at firstname.lastname@example.org, or 01493 378200 or by writing to our Patient Relations Manager, Mrs Plummer at 66 Tan Lane, Caister-on-Sea, Great Yarmouth, NR30 5DT . We take complaints very seriously.
If you are unhappy with our response or if you need any advice you should contact the Information Commissioner’s Office (ICO). Their telephone number is 0303 123 1113, you can also chat online with an advisor. The ICO can investigate your claim and take action against anyone who’s misused personal data. You can also visit their website for information on how to make a data protection complaint.
Related practice procedures
You can also use these contact details to request copies of the following practice policies or procedures:
Data Protection and Information Security Policy, Consent Policy
Sensitive Information Map, PIA and Risk Assessment, Information Governance Procedures, Record Retention
If you have an enquiry or a request please contact the Information Governance Lead, Andrew Cross
John G Plummer & Associates Dental Surgeons,
66 Tan Lane, Caister-on-Sea, Great Yarmouth, NR30 5DT,
Phone: 01493 378200.
Data Opt-Out Policy
How the NHS and care services use your information
John G Plummer & Associates Dental Surgeons is one of many organisations working in the health and care system to improve care for patients and the public. Whenever you use a health or care service, such as attending Accident & Emergency or using Community Care services, important information about you is collected in a patient record for that service. Collecting this information helps to ensure you get the best possible care and treatment. The information collected about you when you use these services can also be used and provided to other organisations for purposes beyond your individual care, for instance to help with:
Improving the quality and standards of care provided
Research into the development of new treatments
Preventing illness and diseases
This may only take place when there is a clear legal basis to use this information. All these uses help to provide better health and care for you, your family and future generations. Confidential patient information about your health and care is only used like this where allowed by law.
Most of the time, anonymised data is used for research and planning so that you cannot be identified in which case your confidential patient information isn’t needed.
You have a choice about whether you want your confidential patient information to be used in this way. If you are happy with this use of information you do not need to do anything. If you do choose to opt out your confidential patient information will still be used to support your individual care. To find out more or to register your choice to opt out, please visit www.nhs.uk/your-nhs-data-matters. On this web page you will:
See what is meant by confidential patient information
Find examples of when confidential patient information is used for individual care and examples of when it is used for purposes beyond individual care
Find out more about the benefits of sharing data
Understand more about who uses the data
Find out how your data is protected
Be able to access the system to view, set or change your opt-out setting
Find the contact telephone number if you want to know any more or to set/change your opt-out by phone
See the situations where the opt-out will not apply
You can also find out more about how patient information is used at:
https://www.hra.nhs.uk/information-about-patients/ (which covers health and care research); and
https://understandingpatientdata.org.uk/what-you-need-know (which covers how and why patient information is used, the safeguards and how decisions are made)
You can change your mind about your choice at any time.
Data being used or shared for purposes beyond individual care does not include your data being shared with insurance companies or used for marketing purposes and data would only be used in this way with your specific agreement.
Health and care organisations have until 2020 to put systems and processes in place so they can be compliant with the national data opt-out and apply your choice to any confidential patient information they use or share for purposes beyond your individual care.
Our practice only uses your personal health data to provide individualised care to you and does not disclose your data for any other purposes. The national data opt-out does not apply to our usage of your data and we are compliant with the policy.
Processing of Staff and Candidates’ Information
This section explains how John G Plummer & Associates Dental Surgeons processes the information of staff and applicants for job roles within the practice.
What data do we have?
So that we can provide a safe and professional service, we need to keep certain records about our team members. We may record the following types of data:
Your basic details and contact information e.g. your name, address, date of birth, National Insurance number and next of kin
Your financial details e.g. details so that we can pay you, insurance, pension and tax details
Your training records
We also record the following data which is classified as “special category”:
Health and social care data about you, which might include both your physical and mental health data – we will only collect this if it is necessary for us to know as your employer, e.g. fit notes or in order for you to claim statutory maternity/paternity pay
We may also, with your permission, record data about your race, ethnic origin, sexual orientation, or religion
As part of your engagement with the practice, you will be required to undergo a Criminal Record Check. This information is not kept for longer than is necessary—usually not more than 6 months following the recruitment decision, unless a dispute is raised or, in exceptional circumstances.
Why do we have this data?
We require this data so that we can contact you, pay you and make sure you receive the training and support you need to perform your job. By law, we need to have a lawful basis for processing your personal data.
We process your data because:
We have a legal obligation under UK employment law
We have a legitimate interest in processing your data – for example, for administration of training or learning course or emergency planning etc. These legitimate interests will be customary, or necessary for operational, administrative, HR and recruitment purposes and to otherwise manage employment relationship and interaction between employees
We are required to provide data to our regulator, CQC, as part of our public interest obligations
We are required to do so in our performance of another public task
We process your special category data because It is necessary for us to process requests for sick pay or maternity pay
If we request your criminal records data it is because we have a legal obligation to do this due to the type of work you do. This is set out in the Data Protection Act 2018 and the Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975
We may also process your data with your consent. If we need to ask for your permission, we will offer you a clear choice and ask that you confirm to us that you consent. We will also explain clearly to you what we need the data for and how you can withdraw your consent
Where do we collect your data from?
As your employer we need to receive specific data about you. This is collected from or shared with:
You or your legal representative(s)
Third parties – for example this could include references from your previous job
We do this face to face, via phone, via email, via our website, via post, via application forms and via apps
How do we share your data?
Third parties are organisations we have a legal reason to share your data with. These include:
Our pension and healthcare schemes
Organisations we have a legal obligation to share information with i.e. for safeguarding, the CQC
The police or other law enforcement agencies if we have to by law or court order
How long do we hold your data?
The retention period for staff records is 6 years, however, certain information relating to team members may lawfully be kept for longer. Team members should refer to Record Retention for further details on how this practice keeps and deposes of staff data. Application forms and interview notes for unsuccessful candidates are kept for one year.
As an individual you have certain rights regarding our processing of your personal data, including a right to lodge a complaint with the Information Commissioner’s Office (ICO) as the relevant supervisory authority. For more information on your personal data rights, you can access information and advice on the ICO’s website.
You can request a copy of your personal file by contacting Mrs Plummer.
Website Privacy and Cookies
What information do we collect?
We may collect, store and use the following kinds of personal information:
(a) information about your computer and about your visits to and use of this website (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views, website navigation and time spent on the site;
(b) information relating to any transactions carried out between you and us on or in relation to this website, including information relating to any purchases of our courses or training;
(c) information that you provide to us for the purpose of sending us an enquiry form;
(d) information that you provide to us for the purpose of subscribing to our website services, email notifications and/or newsletters;
(e) any other information that you choose to send to us.
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser, and stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. This enables the web server to identify and track the web browser.
For more information about cookies see below.
Using your personal information
We may use your personal information to:
(a) administer the website;
(b) improve your browsing experience by personalising the website;
(c) enable your use of the services available on the website;
(d) supply to you services purchased via the website, e.g training;
(e) send statements and invoices to you, and collect payments from you;
(f) send you general (non-marketing) commercial communications;
(g) send you email notifications which you have specifically requested;
(h) send to you our newsletter and other marketing communications relating to our business or the businesses of carefully-selected third parties, which we think may be of interest to you by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications);
(i) provide third parties with statistical information about our users – but this information will not be used to identify any individual user;
(j) deal with enquiries and complaints made by or about you relating to the website;
(k) keep the website secure and prevent fraud;
Where you submit personal information for publication on our website, we will publish and otherwise use that information in accordance with the licence you grant to us.
We will not without your express consent provide your personal information to any third parties for the purpose of direct marketing.
We may disclose your personal information:
(a) to the extent that we are required to do so by law;
(b) in connection with any legal proceedings or prospective legal proceedings;
(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
(e) to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
Information which you provide may be transferred to countries (including the United States and India which do not have data protection laws equivalent to those in force in the European Economic Area).
We cannot prevent the use or misuse of such information by others.
You expressly agree to such transfers of personal information.
Security of your personal information
We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
We will store all the personal information you provide on our secure (password- and firewall- protected) servers. All electronic transactions you make to or receive from us will be encrypted using SSL technology.
Of course, data transmission over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
You are responsible for keeping your password and user details confidential. We will not ask you for your password (except when you log in to the website).
You may instruct us to provide you with any personal information we hold about you. Provision of such information will be subject to:
The supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).
We may withhold such personal information to the extent permitted by law.
You may instruct us not to process your personal information for marketing purposes, by sending an email to us. In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt-out of the use of your personal information for marketing purposes.
Third party websites
Our practice websites contain links to other websites. We are not responsible for the privacy policies or practices of third party websites.
Please let us know if the personal information which we hold about you needs to be corrected or updated.
The data controller responsible in respect of the information collected on these websites is John G Plummer & Associates Dental Surgeons
What are cookies?
For more general information on cookies see the Wikipedia article on HTTP Cookies
You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this). Be aware that disabling cookies will affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionality and features of this site. Therefore, it is recommended that you do not disable cookies.
The cookies we set
When you submit data to through a form such as those found on contact pages or comment forms cookies may be set to remember your user details for future correspondence.
Third party cookies
This site uses Google Analytics which is one of the most widespread and trusted analytics solution on the web for helping us to understand how you use the site and ways that we can improve your experience. These cookies may track things such as how long you spend on the site and the pages that you visit so we can continue to produce engaging content. These cookies do not collect or store any personal information about you. Analytics data cannot be used to identify you, or to tell us what you did on our website. It is anonymous. You can read more about Google Analytics cookies here.
Other third-party cookies are set by web sites other than our website when you carry out certain activities such as view a YouTube video, click a social media link such as Facebook, Twitter and LinkdIn or follow a link on this site outside of this one.
As third-party cookies are not controlled by us we only link to sites that we consider to be safe but it is up to the user to verify that they are happy to visit other sites or use other web services as we cannot control them.
From time to time we test new features and make subtle changes to the way that the site is delivered. When we are still testing new features, these cookies may be used to ensure that you receive a consistent experience whilst on the site whilst ensuring we understand which optimisations our users appreciate the most.
There are instructions on how to delete cookies and how to control cookies on the About Cookies website. This website is owned by John G Plummer & Associates Dental Surgeons.
Hopefully that has clarified things for you and as was previously mentioned if there is something that you aren’t sure whether you need or not it’s usually safer to leave cookies enabled in case it does interact with one of the features you use on our site. However, if you are still looking for more information you can contact us using the contact form.