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Privacy Policy

    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 Jay Joshi. The information governance lead is Carolyn Flawn, who is also the Data Protection Officer.

    This Privacy Notice is available on the practice website, at reception/ by email if you contact info@mkdental.co.uk / by calling 01908 372885

    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 obtained when a patient joins the practice, when a patient is referred to the practice and when a patient subscribes to an email list
    • 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 (invisalign)

    For full details or where your data is stored, please ask to see Information Governance Procedures (M 217C).

    We have established the following lawful bases for processing your data:

    Our lawful bases for processing personal 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 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 (M 215) 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 (M 217C) 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 Sensitive Information Map, PIA and Risk Assessment (M 217Q) 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 (M 217M) and Information Governance Procedures (M 217C).

    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@mkdental.co.uk, or 01908 372885 or by writing to or visiting the practice at  251 Queensway, Bletchley, Milton Keynes, BUCKS, MK22EH. 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 (M 233-DPT), Consent Policy (M 233-CNS)
    • Sensitive Information Map, PIA and Risk Assessment (M 217Q), Information Governance Procedures (M 217C), Record Retention (M 215)

    If you have an enquiry or a request please contact the Information Governance Lead
    Milton Keynes Dental Clinic,
    251 Queensway, Bletchley, Milton Keynes, BUCKS, MK22EH,
    Email: info@mkdental.co.uk,
    Phone: 01908 372885.

    Thank you.

    Data Opt-Out Policy
    (England)

    How the NHS and care services use your information

    Milton Keynes Dental Clinic 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
    • Monitoring safety
    • Planning services

    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/introducing-patient-data (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 the national data opt-out does not apply to our usage of your data and we are compliant with the policy.

    Information relating to team members may lawfully be kept for longer. Team members should refer to Record Retention (M 215) 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.

    Your rights

    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 the Practice Manager

    Rights What does this
    mean?
    1. Rights to be informed You have the right to be provided with clear, transparent and easily
    understandable information about how we use your personal data and your
    rights. This is why we are providing you with the information in this
    Privacy Policy.
    2. Right of access You have the right to obtain access to your personal data (if we are
    processing it) and certain other information (similar to that provided in
    this Privacy Policy). This is so you are aware and can check that we are
    using your personal data in accordance with data protection law.
    3. Right to rectification You are entitled to have your personal data corrected if it is inaccurate or
    incomplete.
    4. Right to erasure This is also known as ‘the right to be forgotten’ and, in simple terms,
    enable you to request the deletion or removal of your personal data where
    there is no compelling reason for us to keep using it. This is not a general
    right to erasure; there are exceptions.
    5. Right to restrict processing You have the right to ‘block’ or supress further use of your personal data
    in certain circumstances. When processing is restricted, we can still store
    your personal data, but may not use it further.
    6. Right of data portability You have the right to obtain and reuse your personal data in a structured,
    commonly used and machine-readable format in certain circumstances. In
    addition, where certain conditions apply, you have the right to have such
    information transferred directly to a third party.
    7. Right to object to processing You have the right to object to us processing your personal data for our
    legitimate business interests or for direct marketing purposes (including in
    each case any related profiling).
    8. Right to withdraw consent to processing If you have given your consent to us to process your personal data for a
    particular purpose (for example, direct marketing), you have the right to
    withdraw your consent at any time (although if you do so, it does not mean
    that any processing of your personal data up to that point is unlawful).
    9. Right to make a complaint to the data protection
    authorities    		 You have the right to make a complaint to the Information Commissioner’s
    Office (ICO) if you are unhappy with how we have handled your personal data
    or believe our processing of your personal data does not comply with data
    protection law.

    How to contact us

    If you would like to exercise your data protection rights or if you are unhappy with how we have handled your personal data, please feel free to contact us by using the details set out on our Site.

    If you’re not satisfied with our response to any enquiries or complaint or believe our processing of your personal data does not comply with data protection law, you can make a complaint to the Information Commissioner’s Office (ICO) by:

    • writing to: Information Commissioner’s Officer, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF;
    • calling: 0303 123 1113; or
    • submitting a message through the ICO’s website at: ico.org.uk

    Links to other websites

    Our website may contain hyperlinks to websites owned and operated by third parties. This Privacy Policy does not apply to those other websites. We encourage you to read the privacy statements on the other websites you visit, as they will govern the use of any personal data you provide when visiting those websites. We do not accept any responsibility or liability for the privacy practices of such third party websites and your use of such websites is at your own risk.

    Changes to this Privacy Policy

    This Privacy Policy was last updated on 1 May 2018.

    This Privacy Policy may be updated from time to time, so you may want to check it each time you provide personal data to us.