The practice aims to meet the requirements of the Data Protection Act 2018, the United Kingdom General Data Protection Regulation (UK GDPR), the guidelines on the Information Commissioner’s (ICO) website as well as our professional guidelines and requirements.

The data controller is Richard Hellen, and the Information Governance Lead is Gemma Travers.

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.

 
Categories and examples of data we process

• 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 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 website experience
• Audio recordings of telephone calls or conversations for the purposes of quality assurance, staff training, record keeping, and ensuring accurate information is captured
• Special category data including health records for the purposes of the delivery of health care and meeting our legal obligations
• Special category data to meet the requirements of the Equality Act 2010
• Special category data including details of criminal record checks for employees and contracted team members

 
Audio recording information

We may record telephone calls or in-person conversations for specific and limited purposes, such as:

• Ensuring accuracy of information provided or received;
• Monitoring and improving the quality of our services;
• Staff training and professional development; or
• Investigating and responding to complaints or Legal basis:

The lawful bases for processing audio recordings are the legitimate interests of the practice in providing safe, effective care and high-quality service, and in certain cases, consent where recordings are not strictly necessary for service provision.

Retention: 

Audio recordings are kept for a maximum of 12 months unless required for a longer period in connection with a complaint, investigation, or legal obligation, after which they are securely deleted.

Access and security:

Recordings are stored securely in the UK in encrypted digital format and are accessible only to authorised personnel. Recordings will not be shared with third parties except where required by law or with your explicit consent.

You have the right to object to the processing of your data through audio recordings, except where the recording is necessary to meet our legal or contractual obligations.

 
Lawful bases for processing

Our lawful bases for processing personal data:

• The legitimate interests of the dental practice
• Processing 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 Article 9 conditions for processing special category data:

• Processing 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

 
Retention

The retention period for special data in patient records is a minimum of 11 years and may be longer for complex records or to meet our legal requirements. The retention period for other personal data is 2 years after it was last processed.

Audio recordings are retained for up to 12 months, unless needed for a complaint, legal process, or investigation.

Your rights

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
• 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

 
Comments, suggestions and complaints

Please contact the IG Lead at the practice for a comment, suggestion or a complaint about your data processing at info@yorkplacedental.com, or 01228 533431 or by writing to or visiting the practice at 37 Upperby Road, Carlisle, Cumbria, CA2 4HZ. 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, or visit their website for more information on how to make a data protection complaint.