This document refers to personal data, which is defined as information concerning any living person (hereafter referred to as the “individual”).
The General Data Protection Regulation (“GDPR”) is a legal framework, created by the European Union (EU), that requires businesses to protect the personal data and privacy of EU citizens for transactions that occur within EU member states.
In response to this, the UK government created and enacted a revised Data Protection Act 2018 to incorporate most of the provisions of GDPR and along with the Privacy and Electronic Communications Regulations (PECR) they seek to protect and enhance the rights of EU individuals.
These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU and its storage within the EEA.
Cuttica Osteopathy, based at 65 Meadvale Rd, Ealing W5 1LP, which hereafter for the purposes of this Privacy Notice will be referred to as the Osteopath, is pleased to provide the following information:
1) Role & function of an osteopath
The role of the Osteopath is to diagnose and treat health conditions. Treatments are carried out in accordance with the Institute of Osteopathy’s patient charter: www.iosteopathy.org/osteopathy/the-patient-charter
2) Personal Data
For the purposes of providing treatment, the Osteopath may require detailed medical information. She will only collect what is relevant and necessary for your treatment. When you visit the practice, she will make notes which may include details concerning your medication, treatment and other issues affecting your health. This data is always held securely and is not shared with anyone not involved in your treatment.
To be able to process your personal data, it is a condition of any treatment that you give your explicit consent to allow the Osteopath to document and process your personal medical data. Contact details provided by you, such as telephone numbers, email addresses and postal addresses, may be used to remind you of future appointments and provide reports or other information concerning your treatment.
As part of our obligations as primary healthcare practitioners, there may be circumstances related to your treatment, ongoing care or medical diagnosis that will require the sharing of your medical records with other healthcare practitioners eg GPs, consultants and/ or medical insurance companies. Where this is required, we will always inform you first, unless we are under a legal obligation to comply.
For marketing purposes, the Osteopath may also use the contact details provided by you to communicate information which the practice believes may be of interest.
In making initial contact with the practice, you consent to the Osteopath maintaining a marketing dialogue with you until you either opt out (which you can do at any time) or she decides to desist in promoting her services. The Osteopath will not broker your data and you can ask to be removed from the marketing database by emailing or phoning the practice using the contact details provided at the bottom of this page.
Some basic personal data may be collected about you from the marketing forms and surveys you complete, from records of our correspondence and phone calls and details of your visits to the website, including but not limited to, personally identifying information like Internet Protocol (IP) addresses.
The Osteopath will only collect the information needed so that she can provide you with the services you require; the business does not sell or broker your data.
3) Legal basis for processing any personal data
Personal data is obtained by explicit Patient Consent and is processed to meet her contractual obligations. The osteopath also has a legitimate interest to respond to enquiries concerning the services she provides.
4) Legitimate interests pursued by Osteopaths
To promote treatments for patients with all types of health problems indicated for osteopathic care.
Through agreeing to this privacy notice you are consenting to the Osteopath processing your personal data for the purposes outlined. You can withdraw consent at any time by using the postal, email address or telephone number provided at the bottom of this page.
The Osteopath will keep your personal information safe and secure. The Osteopath will not disclose your Personal Information unless compelled to meet legal obligations, regulations or valid governmental requests.
7) Retention Policy
The Osteopath will process personal data for the duration of any treatment and will continue to store the personal data for eight years after the contract has expired. After eight years, all personal data will be deleted, unless basic information needs to be retained to meet our future obligations to you, such as erasure details. Records concerning minors who have received treatment will be retained until the child has reached the age of 25.
8) Data storage
All written case notes, letters and Investigative reports will be stored in a locked cabinet. Data is stored on Microsoft 365 software which is GDPR compliant.
9) Your rights as an individual
At any point whilst the Osteopath is in possession of, or processing, your personal data, all individuals have the following rights:
Right of access – you have the right to request a copy of the information that we hold about you
Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete
Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records
Right to restriction of processing – where certain conditions apply you have a right to restrict the processing
Right of portability – you have the right to have the data we hold about you transferred to another organisation
Right to object – you have the right to object to certain types of processing such as direct marketing
Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling
Should the Osteopath refuse your request under rights of access, she will provide you with a reason why, which you have the right to legally challenge. At your request, the Osteopath can confirm what information she holds about you and how it is processed.
10) You can request the following information:
The identity and contact details of the person (the Osteopath) that has determined how and why to process your data
The purpose of the processing, as well as the legal basis for processing
If the processing is based on the legitimate interests of the Osteopath and information about these interests
The categories of personal data collected, stored and processed
Recipient(s) or categories of recipients that the data is/ will be disclosed to
How long the data will be stored
Details of your rights to correct, erasure, restrict or object to such processing
Information about your right to withdraw consent at any time
How to lodge a complaint with the supervisory authority (ICO)
Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data
The source of personal data if it was not collected directly from you
11) To access what personal data is held, identification will be required
Osteopaths will accept the following forms of identification (ID) when a request for your personal data is made:
a copy of your driving licence, passport, birth certificate and a utility bill not older than three months - A minimum of one piece of photographic ID listed above and a supporting document is required.
If the Osteopath is dissatisfied with the quality, further information may be sought before personal data can be released. All requests should be made to Mandy Cuttica in writing at the address below.
If you wish to make a complaint about how your personal data is being processed by the Osteopath, you have the right to complain to her directly in the first instance. If you do not get a response within 30 days, you can complain to the ICO.
The details for these contacts are:
Mandy Cuttica at Cuttica Osteopathy
65 Meadvale Rd, Ealing, London W5 1LP
tel: 07497 810634
Wycliffe House, Water Lane, Wilmslow, SK9 5AF
tel: 0303 123 1113