Great Northern Physiotherapy Ltd
DATA PRIVACY NOTICE FOR CLIENTS AND SUPPLIERS
Introduction
Great Northern Physiotherapy Ltd (“We”) are committed to protecting and respecting your privacy.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
You must read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Data controller:
Great Northern Physiotherapy Ltd is the controller and responsible for your personal data (collectively referred to as [“COMPANY”], “we”, “us” or “our” in this privacy notice). Our contact details are:
Unit C1
The Point Business Park
Lincoln
LN6 3QN
01522 787164
The rules on processing of personal data are set out in the UK General Data Protection Regulation (the “UK GDPR”).
- Definitions.
Data controller – A controller determines the purposes and means of processing personal data.
Data processor – A processor is responsible for processing personal data on behalf of a controller.
Data subject – Natural person.
Data protection legislation – Means the data protection legislation enforce in the UK from time to time and includes the Data Protection 2018 (as amended) and the UK General Data Protection Regulation (UK GDPR).
Categories of data: Personal data and special categories of personal data
Personal data – The UK GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of UK GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.
Special categories personal data – The UK GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of UK GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.
Processing – Means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Third party – Means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
- Who are we?
Great Northern Physiotherapy Ltd is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are:
Unit C1
The Point Business Park
Lincoln
LN6 3QN
01522 787164
For all data matters contact Rebecca Robinson on hello@greatnorthernphysiotherpy.co.uk
- The purpose(s) of processing your personal data.
We use your personal data for the following purposes:
Provision of healthcare and Physiotherapy services
4. The categories of personal data concerned.
With reference to the categories of personal data described in the definitions section, we process the following categories of your data:
- Personal data, such as your name, address, date of birth, phone numbers, email addresses, financial data
- Special categories of data such as healthcare records we store for you. We have obtained your personal data from information you have provided to us and through other healthcare providers.
5. What is our legal basis for processing your personal data?
- Personal data (article 6 of UK GDPR)
Our lawful basis for processing your general personal data:
- Processing necessary for the performance of a contract with the data subject or to take steps to enter into a contract
- Processing necessary for compliance with a legal obligation
- Special categories of personal data (article 9 of UK GDPR)
Our lawful basis for processing your special categories of data:
Processing necessary for reasons of preventative or occupational medicine, for assessing the working capacity of an 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 data protection legislation or a contract with a health professional
More information on lawful processing can be found on the ICO website.
- Sharing your personal data.
Your personal data will be treated as strictly confidential, and will be shared only with other Healthcare providers with your informed consent or with 3rd parties for data processing purposes (see section 26).
7. How long do we keep your personal data?
We keep your personal data for no longer than reasonably necessary for a period of 8 years (or in the case of children we will retain until the clients 25th birthday or 26th if young person was 17 at conclusion of treatment) in order to comply with UK regulations on healthcare record storage.
8. Providing us with your personal data.
You are under no statutory or contractual requirement or obligation to provide us with your personal data. But failure to do so will have the following consequences:
- An incomplete health record or personal data record which may affect our ability to provide our services to you in an effective manner.
9. Your rights and your personal data.
Unless subject to an exemption under the UK GDPR, you have the following rights with respect to your personal data:
- The right to request a copy of the personal data which we hold about you;
- The right to request that we correct any personal data if it is found to be inaccurate or out of date;
- The right to request your personal data is erased where it is no longer necessary to retain such data;
- The right to withdraw your consent to the processing at any time, where consent was your lawful basis for processing the data;
- The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
- The right to object to the processing of personal data, where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); (direct marketing and processing for the purposes of scientific/historical research and statistics).
- Transfer of Data Abroad.
Some of the services we use for processing and storing your data will be processed and stored outside of the UK, in these instances we have made sure that such services are and continue to be GDPR compliant.
- Automated Decision Making.
We do not carry out automated decision making.
- Further processing.
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.
- Changes to our privacy policy.
Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.
How we process your data through our website and other IT services
We respect your privacy and are determined to protect your personal data. The following terms inform you how we look after your personal data when you visit our website (regardless of where you visit it from) and how we store your data securely when we process your data as a client of our services. We’ll also tell you about your privacy rights and how the data protection laws protects you.
Our website is not intended for children and we do not knowingly collect data relating to children.
14. Third-party links outside of our control.
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
15. The personal data we collect from you.
Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioners Office.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows
Identity Data includes [first name/last name/ username/marital status/ title/date of birth/gender].
- Contact Data includes: address/email address/ telephone numbers.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
16. If you fail to provide personal data.
Where we need to collect your personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
17. How we collect your personal data.
We use different methods to collect data from and about you including through:
- Directly. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you
- Apply for our products or services;
- Create an account on our website;
- Subscribe to our service or publications;
- Request marketing to be sent to you.
18. How we use your personal data.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Performance of Contract this means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
- Comply with a legal or regulatory obligation this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
19. Purposes for which we will use your personal data.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, with the legal bases we rely on to do so.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
| To register you as a new client | Identity, Contact, Special data such as information your provide us about your health | Performance of a contract with you. Legal requirements |
20. Marketing.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We have established the following personal data control mechanisms:
21. Promotional offers from us.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving that marketing.
22. Opting out.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase.
23. Cookies.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
We use cookies to identify you as a unique visitor and to identify which pages are being used. The cookie that is stored does not include any information that is personally identifiable to you. The information is completely anonymous.
We also use Google Analytics to monitor and analyse the use of our website. This helps us monitor web page traffic- we will use this information for this purpose only and this will be stored on Google’s servers. You can view Google’s Privacy Policy here: www.google.com/policies/privacy.
24. Change of purpose.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
25. Who we share your personal data with.
We may have to share your personal data with the parties set out below for the purposes set out in this policy.
External Third Parties Services:
- Providers acting as processors based in the UK (or when not based in the UK or EU we have made sure that such external 3rd parties data processing meets GDPR compliance) who provide IT and system administration services.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
26. International transfers.
Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring the data processing meets GDPR compliance. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the uk.
27.Use of CCTV & image recording equipment.
Great Northern Physiotherapy Ltd intermittently operates CCTV externally on its premises. It also operates cameras inside its premise with their use being limited to outside of business hours only. All images captured will be retained for a period of 30 days before deletion. Requests for recorded images are available to both staff and customers. All requests will be dealt with in a timely manner and always within 30 days of receipt of request. Images will not be provided to third parties other than law enforcement bodies to assist them in the detection or prevention of a crime.
28. Data security.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
29. Data retention.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
30. Your legal rights.
Unless subject to an exemption under the data protection laws, you have the following rights with respect to your personal data:
- The right to request a copy of the personal data which we hold about you;
- The right to request that we correct any personal data if it is found to be inaccurate or out of date;
- The right to request your personal data is erased where it is no longer necessary to retain such data;
- The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data;
- The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), where applicable 9i.e. where our processing is based on consent or is necessary for the performance of our contract with you or where we process your data by automated means);
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
- The right to object to our processing of personal data, where applicable i.e. where processing is based on our legitimate interests (or in performance of a task in the public interest/exercise of official authority); direct marketing or processing for the purposes of scientific/historical research and statistics).
If you wish to exercise any of the rights set out above, please contact Rebecca Robinson, hello@greatnorthernphysiotherpy.co.uk
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
31. What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
32. Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
33. Changes to this notice and your duty to inform us of changes
This version was last updated on 24.8.21 and historic versions can be obtained by contacting us. Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.
34. Queries, requests or concerns
To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and us, please in the first instance contact our DPO Rebecca Robinson on hello@greatnorthernphysiotherpy.co.uk
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England, UK.
35. How to make a complaint
To exercise all relevant rights, queries or complaints please in the first instance contact our DPO Rebecca Robinson on hello@greatnorthernphysiotherpy.co.uk.
Read our Complaints Procedure here.
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.