Just like this website, my Privacy Policy is a work in progress. It is in ‘plain English’.

PRIVACY NOTICE (Why we collect your personal data and what we do with it)

When you supply your personal details to this clinic they are stored and processed for 4 reasons (the bits in bold are the relevant terms used in the General Data Protection Regulation – ie the law):

• We need to collect personal information about your health in order to provide you with the best possible treatment. Your requesting treatment and our agreement to provide that care constitutes a contract. You can, of course, refuse to provide the information, but if you were to do that we would not be able to provide treatment or advice.
• We have a “Legitimate Interest” in collecting that information, because without it we couldn’t do our job effectively and safely.
• We also think that it is important that we can contact you in order to confirm your appointments with us or to update you on matters related to your medical care. This again constitutes “Legitimate Interest”, but this time it is your legitimate interest.
• Provided we have your consent, we may occasionally send you general health information in the form of articles or advice or information on things like clinic hours etc. You may withdraw this consent at any time – just let us know by any convenient method. All emails or SMS will have an ability to reply/unsubscribe.

We have a legal obligation to retain your records for 8 years after your most recent appointment (or age 25, if this is longer). Every six months, an audit will be conducted and records not updated by attending an appointment within the last 8 years will be deleted.

We may email you now and then to check our records are still correct.

Your records are stored

• on paper, in locked filing cabinets, and the premises are always locked when not monitored.
• electronically (“in the cloud”), using specialist medical records services. This provider/providers has/have given us their assurances that they are fully compliant with the General Data Protection Regulations and. Access to this data is password protected, and the passwords are changed regularly.
• on my office computers and devices. These are password-protected, backed up regularly, and the premises are locked when not monitored.

We will never share your data with anyone who does not need access without your written consent unless required by a court order, government order or similar other legal obligation or public health protection mandate which gives us no choice.

Only the following people/agencies will have routine access to your data:

• The medical records service who store and process our files.
• Your practitioner(s) in order that they can provide you with treatment
• Our reception staff, because they organise the diary, and coordinate appointments (but they do not have access to your medical history or sensitive personal information)
• Other administrative staff, from time to time. Again, administrative staff will not have access to your medical notes, just your essential contact details.
• Mailchimp to coordinate our messages, Physitrack to send you exercise programmes, Sumup who process payments, and other similar GDPR compliant systems which, from time to time, which will aid in services which are in “Legitimate Interest” or clearly consented to by you.   Any companies outside the EEA will have to have signed the US/EU Privacy Shield or will otherwise be compliant with GDPR.
• Tracy Hannigan is a participant in the Amazon Services LLC Associates Program, an affiliate advertising program designed to provide a means for sites to earn advertising fees by advertising and linking to Amazon.  All links in the shop are affiliate links.  Services are provided by Amazon.

From time to time, we may have to employ consultants to perform tasks which might give them access to your personal data (but not your medical notes). We will ensure that they are fully aware that they must treat that information as confidential, and we will ensure that they sign a non-disclosure agreement.

You have the right to see what personal data of yours we hold, and you can also ask us to correct any factual errors. Provided the legal minimum period has elapsed, you can also ask us to erase your records. We want you to be absolutely confident that we are treating your personal data responsibly, and that we are doing everything we can to make sure that the only people who can access that data have a genuine need to do so.

Changes to the Privacy Policy

Each time the privacy policy is updated, the date at the bottom of the page will reflect the date of those changes. We encourage you to check frequently and stay informed about how we are helping protect your information.

By using this site and services, you are signifying that you accept this policy. If you don’t agree to the policy, please don’t use the site or services. Continuing use following posting of changes will be deemed to be acceptance of those changes.

What can you do if you’re not happy?

Please feel free to express your concerns by reaching out! We are happy to clarify the policy for you and you also have the right to make a complaint.

Complaints need to be sent to what is referred to in the jargon as the “Data Controller”: Tracy Hannigan tracy@tracytheosteopath.co.uk 020 143 3163 at 51 Addison Gardens London W14 0DP

If you are not satisfied with our response, then you have the right to raise the matter with the Information Commissioner’s Office

Wycliffe House, Water Lane, Wilmslow, SK9 5AF Telephone +44 (0) 303 123 1113 or email: https://ico.org.uk/global/contact-us/email/

16/6/2018