Smile Care Cosmetic Centre 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 data controller is Smile Care Cosmetic Centre Ltd, the information Governance Lead Dr Rafal Topolski. The Information Commissioner’s Office(ICO) registration number is Z284176X.
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, address, date of birth
- Unique identification number
- Next of kin
- Email address
- Phone numbers
- GP contact details
- Medical history
- Dental care records
- Family group
- Payment plan details
- Financial information
- Credit cards receipts
- Details of any complaints received
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 our patients of the legal basis on which we process their personal data. This is clearly stated in our privacy notice that is given to all patients.
The legal bases for recording individual types of data are recorded in our patient personal data inventory. This is available for all patients to see on request.
The legal basis on which we process personal information for our private patients is 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 legal basis on which we process personal information for our payment plan patients is 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.
Automated decision making
All individuals who have personal data held about them have a right to object to their personal data being subjected to automated decision making.
Patients will always be asked to give specific, informed, verifiable, opt in consent for any processes involving automated decision making.
Smile Care Cosmetic Centre will always obtain specific, opt in consent from you for direct marketing information. This will be discussed with you and you will be asked to sign the appropriate consent form.
We will also obtain specific, opt in consent from you for any photographs containing any facial features that may unable to recognise you. 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 pro forma.
Withdrawal of consent
Patients who have given their opt in consent have a right to withdraw their consent at any time. Patients are advised of their right to withdraw their consent for anything they wish to withdraw from in our privacy notice.
This practice retains dental records and orthodontic study models 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.
Comments, suggestions and 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 Dr Rafal Topolski. All complaints will be dealt with in line with the practice complaints policy and procedures.
Please contact reception at our practice for a comment or suggestion about your data processing at Smile Care Cosmetic Centre or call 01752 663239. 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.
Google Analytics and “cookies”
This website uses Google Analytics to help analyse how users use the site. The tool uses “cookies,” which are text files placed on your computer, to collect standard Internet log information and visitor behaviour information in an anonymous form. The information generated by the cookie about your use of the website (including IP address) is transmitted to Google. This information is then used to evaluate visitors’ use of the website and to compile statistical reports on website activity.
We will never (and will not allow any third party to) use the statistical analytics tool to track or to collect any Personally Identifiable Information (PII) of visitors to our site. Google will not associate your IP address with any other data held by Google. Neither we nor Google will link, or seek to link, an IP address with the identity of a computer user. We will not associate any data gathered from this site with any Personally Identifiable Information from any source, unless you explicitly submit that information via a fill-in form on our website.
Transferring personal data outside the EU
Patients’ personal data is not transferred outside the EU.
This Policy was reviewed and implemented on: 30-05-2018
This policy and relevant procedures will be reviewed annually and are due for review
on: 30-05-2019 or prior to this date in accordance with new guidance or legislative changes.