London Orthodontics takes great care to protect the personal data we hold for you in line with the requirements of the General Data Protection Regulation (GDPR).
The purpose of collecting and storing personal data about you is to ensure we can:
- Provide, appropriate, safe and effective Orthodontic care, treatment and advice for you
- Fulfil any contracts we hold in relation to your care
- For business administration of your care.
We are London Orthodontics operating at 40 Harley Street, London, W1G 9PP. Dr Simon Manara is responsible for keeping secure the information about you that we hold. Those at the practice who have access to your information include Dr Simon Manara, the orthodontic nurse involved with your care and treatment, as well as the reception staff responsible for the management and administration of the practice.
The Information that we hold
We can only keep and use information for specific reasons set out in the law. If we want to keep and use information about your health, we can only do so in particular circumstances. Below, we describe the information we hold, why, and the lawful basis for collecting and using it.
Processing of data includes obtaining the information, using it, storing it, securing it, disclosing it, and destroying it.
We hold personal information about you including your name, date of birth, address, telephone number, email address. This information allows us to fulfil our contract with you to provide appointments. We will also use the information to send you reminders and recall appointments as we have a legitimate interest to ensure your continuing care and to make you aware of our services. This applies to the designated responsible parties of those under 16 years of age. Orthodontics is an extended treatment which frequently includes a pre-treatment period of observation, followed by active treatment and then close monitoring of retention for twelve months. Finally annual retention reviews.
We hold information about your orthodontic and general health, including:
- Clinical records made by the orthodontist and other dental professionals involved with your care and treatment
- Radiographs, clinical photographs, 3D optical scans of your mouth and teeth. (Historic study models are being scanned sequentially)
- Medical and Orthodontic histories, occupation.
- Treatment plans and consent
- Notes of conversations with you about your care
- Dates of your appointments
- Details of any complaints you have made and how these complaints were dealt with
- Correspondence with you and other health professionals or institutions.
- Unique identification number
We collect and use this information to allow us to fulfil our contract with you to discuss your treatment options and provide orthodontic care that meets your needs. We also use this information for the legitimate interest of ensuring the quality of the treatment we provide.
We hold information about the fees we have charged, the amounts you have paid and some payment details. This information forms part of our contractual obligation to you to provide orthodontic care and allows us to meet legal financial requirements.
There is CCTV at the Ground floor entrance and exit of 40 Harley street and is operated by Howard de Walden. The purposes of this is for the security of the building. Please see the policy for CCTV for further details provided by Howard de Walden.
We keep an inventory of personal data we hold on our patients and this is available on request.
How we use your information
To provide you with the orthodontic care and treatment that you need, we require up-to-date and accurate information about you.
We may contact you to conduct patient surveys or to find out if you are happy with the treatment you received for quality control purposes.
We will seek your preference for how we contact you about your Orthodontic care. Our usual methods are telephone, email or letter. In future we hope to also be able to offer SMS.
If we wish to use your information for Orthodontic research or Orthodontic education, we will discuss this with you and seek your consent. Depending on the purpose and if possible, we will anonymise your information. If this is not possible we will inform you and discuss your options.
We may use your contact details to inform you of products and services available at our Practice.
Sharing information (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 your personal information with third parties when required by law or to enable us to deliver a service to you or where we have another legitimate reason for doing so. Third parties we may share your 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
- Your private insurance provider when you specifically as us to do so.
- Loss assessors
- Fraud prevention agencies
- In the event of a possible sale of the practice at some time in the future.
- Specialist Orthodontic or medical / dental services to which we may refer you including your Physician.
We will only disclose your information on a need-to-know basis and will limit any information that we share to the minimum necessary. We will let you know in advance if we send your medical information to another medical provider and we will give you the details of that provider at that time.
In certain circumstances or if required by law, we may need to disclose your information to a third party not connected with your health care, including HMRC or other law enforcement or government agencies. 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.
Keeping your information safe
We store your personal information securely on our practice computer system. Your information cannot be accessed by those who do not work at the practice; only those working at the practice have access to your information. They understand their legal responsibility to maintain confidentiality and follow practice procedures to ensure this. The
We take precautions to ensure security of the practice premises, and computers.
We use high-quality specialist orthodontic software to record and use your personal information safely and effectively. Our computer system has a secure audit trail and we back-up information routinely (Daily and weekly). Redundancy; back up to local hard drives and encrypted cloud storage.
We use cloud computing facilities for storing some of your information. The practice has a rigorous agreement with our provider to ensure that we meet the obligations described in this policy and that we keep your information securely.
We keep your records for a minimum of 10 years after the date of your last visit to the Practice or until you reach the age of 25 years, whichever is the longer. At your request, we will delete non-essential information (for example some contact details) before the end of this period.
Personal privacy rights
Under the General Data Protection Regulation (GDPR) you have the following personal privacy rights in relation to the information we hold about you.
- Access to and copies of your records.
- Have inaccuracies deleted.
- Have information about you erased. This should be seen in light of the need to keep records about your Orthodontic care in case you have any problems in the future.
- Object to direct marketing.
- Correct any information that you believe is inaccurate or incomplete. If we have disclosed that information to a third party, we will let them know about the change.
- Erase some of the information we hold. For legal reasons, we may be unable to erase certain information (for example, information about your Orthodontic treatment). This should be seen in light of the need to keep records about your Orthodontic care in case you have any problems in the future. However, we can, if you ask us to, delete some contact details and other non-clinical information.
- Stop using your information – for example, sending you reminders for appointments or information about our service. Even if you have given us consent to send you marketing information, you may withdraw that consent at any time.
- Stop using information if you believe the information is inaccurate or you believe we are using your information illegally.
- Supply your information electronically to another Orthodontic practice or anywhere else.
- Restrict the processing of your information, including automated decision-making.
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 is
Legitimate, legal and contract basis
– The legal basis on which we process personal information for our payment plan patients is contract basis
Automated decision making
Orthodontic treatment extends over several years and frequently requires careful follow up. Dr Manara feels that he is obliged to contact you to remind his patients and responsible parties for recalls as discussed at previous appointments and to remind patients of appointments when in active treatment.
The usual method has been email notification and verbal confirmation has be sought to date. Going forwards, new patients will be asked to confirm their preference in writing at their first appointment. You will be asked to opt in to any processes involving automated decision making. This includes:
- You will automatically receive confirmation by email and (in future SMS) of the appointment you have made
- You will receive automatic reminders by email and (in future SMS) of your appointment at intervals before the scheduled appointment inviting you to confirm by responding to the message using a button in the email.
- You will receive recall reminders to follow up your care both before and after your orthodontic treatment.
London orthodontics will always obtain specific, opt in consent from you for direct marketing information.
We will also obtain specific, opt in consent from you for the use of your records for publication or use in our marketing material. 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. Orthodontics is an ongoing treatment plan so we will not refresh this consent.
Withdrawal of consent
After you have given your opt in consent you have a right to withdraw your consent at any time.
This practice retains Orthodontic records and orthodontic study models while you are a patient of our practice and after you cease to be a patient, for at least eleven years, or for children until age 25, whichever is the longer.
You have a right to complain about how we process your personal data. All complaints concerning personal data should be made in person or in writing to Dr Simon Manara. All complaints will be dealt with in line with the practice complaints policy and procedures.
Transferring personal data outside the EU
This practice may send out any necessary laboratory work outside the EU. Laboratory work sent outside the EU will be labelled with your unique identifying number rather than your name. A record of the unique identifying number will be held at the practice.
This Privacy Notice was reviewed and implemented on: 16 May 2018
It will be reviewed annually and is due for review on: 15 May 2019 or prior to this date in accordance with new guidance or legislative changes.
Statistics are collected by placing a cookie on your computer for general demographic purposes (eg. 100 people from England, 20 from the USA) but this is not used to identify individual users.