Privacy Notice

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 controllers are Dr Peter Dahlman, Parminder Nagi and David Barrett who are also the information Governance Leads and the Data Protection Officers.

This Privacy Notice is available by calling the practice directly on 01865 244304.

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 and 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 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 if you are having NHS treatment.

• Personal data is stored in the [EU] whether in digital or hard copy format
• Personal data is stored in the US in digital format when the data storage company is certified with the EU-US Privacy Shield
• 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

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

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 obligations.

The lawful basis for processing special category data such as patients’ and employees’ health data is:

• Processing is necessary for the purposes of preventative or occupational medicine, for assessing the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or management of health or social care systems and services on the basis of Union or Member State law or a contract with a health professional
• The lawful basis of processing personal data such as name, address, email or phone number is:
• Consent of the data subject
• Processing is necessary for the performance of a contract with the data subject or to take steps to enter into a contract
  The retention period for special data in patient records is a minimum of 10 years and may be longer for complex records in order 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 other 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 free copy of your data that we have
• 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 (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 Peter Dahlman, Parminder Nagi or David Barrett at the practice for a comment, suggestion or a complaint about your data processing by dialling 01865 244304 or by writing to or visiting the practice at Cornmarket Street Dental Practice, 3rd Floor, 11-12 Cornmarket Street, Oxford, OX1 3EX. 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)
• Privacy Impact Assessment (M 217S), Information Governance Procedures (M 217C), Record Retention (M 215)

If you have an enquiry please contact the information governance leads:

Peter Dahlman, Parminder Nagi or David Barrett
Cornmarket Street Dental Practice, 3rd Floor, 11-12 Cornmarket Street, Oxford, OX1 3EX.
Phone: 01865 244304

Privacy Notice for Children

The practice keeps records of your name, address, date of birth and details of any health problems as well as details of your dental treatment and details about your family. We keep this information so that we can provide you with the best dental care. Your personal information is kept very confidentially and securely.

We only use your personal information so we can give you the best dental care and for sending reminders to you.

We only pass your personal information to another dentist, doctor or hospital if you have a problem that needs their special skills and you need to go and see them. We will not give your information to anyone else unless the law allows us to or we have to provide it for legal reasons.

If you leave the practice, we will stop using your information, but will keep it confidentially and securely until you are 25 years old, when we will review if and when we can delete it. You can always ask for a copy of the information we hold for you, we can transfer it to another dentist or doctor at your request and you can ask us to stop using your personal information to send letters or contact you in other ways if you are no longer a patient at the practice.

When you reach 18 years of age the Privacy Notice about how we process your personal information will change to the adult version. This can be found on our website.

If you would like a copy of the information we hold about you or if you have any other enquiries it about such as to change an error in your information or to provide a copy of your information to somebody else please contact:

Peter Dahlman, Parminder Nagi or David Barrett
Cornmarket Street Dental Practice
3rd Floor, 11-12 Cornmarket Street,
Oxford, OX1 3EX.
Phone: 01865 244304