· It describes how we collect, use and process your personal data, and how, in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.
· For the purpose of applicable data protection legislation (including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”), the company responsible for your personal data ("Lee Dental Care" or "us") can be found on our website.
· Patients - while it speaks for itself, this category covers our customers, clients, and others to whom Lee Dental Care provides treatments in the course of its business.
· Delete – while we will endeavour to permanently erase your personal data once it reaches the end of its retention period or where we receive a valid request from you to do so, some of your data may still exist within our systems, for example if it is waiting to be overwritten. For our purposes, this data has been put beyond use, meaning that, while it still exists on an archive system, this cannot be readily accessed by any of our operational systems, processes or Staff.
. General Data Protection Regulation (GDPR)– a European Union statutory instrument which aims to harmonise European data protection laws. It has an effective date of 25 May 2018, and any references to it should be construed accordingly to include any national legislation implementing it.
· Other people whom Lee Dental Care may contact – these may include Lee Dental Care's Staff emergency contacts and referees. We will only contact them in appropriate circumstances.
. Website Users - any individual who accesses any of the Lee Dental Care websites.
What kind of personal data do we collect?·
PATIENT DATA: In order to provide the best possible employment opportunities that are tailored to you, we need to process certain information about you. We only ask for details that will genuinely help us to help you, such as your name, contact details, and medical details (and of course you may choose to share other relevant information with us). Where appropriate and in accordance with local laws and requirements, we may also collect information related to your health, diversity information or details of any criminal convictions. ·
We thus may collect the following: ·
Contact details (home telephone number, mobile numbers);·
Emails and Email addresses
Extra information that you choose to tell us;·
Any emails you may have sent us may contain further information in addition to the above
.· Please note that the above list of categories of personal data we may collect is not exhaustive.
· At present don’t collect any personal data via our website. If that changes we will update this notice accordingly.
· PATIENT DATA: If you are a Lee Dental Care customer, we need to collect and use information about you, or individuals at your organisation, in the course of providing you treatments such as:
(i) Dentistry Work
(ii) Hygienist Work
· However, the data we collect about patients is actually very limited. We generally only need to have your contact details or the details of your Doctors (such as their names, telephone numbers and email addresses) to enable us to ensure that our relationship runs smoothly. We also hold information relating to your online engagement material published by Lee Dental Care, which we use to ensure that our marketing communications to you are relevant and timely. If we need any additional personal data for any reason, we will let you know.
· PEOPLE WHOSE DATA WE RECEIVE FROM DOCTORS, SUCH AS REFEREES AND EMERGENCY CONTACTS: In order to provide patients with suitable treatment opportunities safely and securely and to provide for every eventuality for them and our Staff, we need some basic background information. We only ask for very basic contact details, so that we can get in touch with you. To ask for a reference, we'll obviously need the referee's contact details (such as name, email address and telephone number). We'll also need these details if a member of our Staff has put you down as their emergency contact so that we can contact you in the event of an accident or an emergency.
· WEBSITE USERS: We don’t collect any data from our Website Users unless they send us an email.
How do we collect your personal data?
PATIENTS DATA: There are two main ways in which we collect your personal data:
1. Directly from you; and
2. From third parties.
Personal data you give to us
· Lee Dental Care needs to know certain information about you in order to provide a tailored service. This will enable us to provide you with the best opportunities, and should save you time.
· There are numerous ways you can share your information with us. It all depends on what suits you. These may include:
. Entering your details into an email having been directed from the Lee Dental Care website
. Leaving a hard copy at a Lee Dental Care or office;
. Emailing your information to a Lee Dental Care consultant.
Personal data we receive from other sources
· We also receive personal data about our patients from other sources. Depending on the relevant circumstances and applicable local laws and requirements, these may include personal data received in the following situations:
. Your doctors may disclose personal information about you;
· PATIENT DATA: There are two main ways in which we collect your personal data:1 Directly from you; and2 From third parties (e.g. Doctors)
Personal data that we receive directly from you
· We both share the same goal – to make sure that you have the best treatment for you. We will receive data directly from you in two ways:- Where you contact us proactively, usually by phone or email; and/or- Where we contact you, either by phone or email, or through your doctors more generally.
PEOPLE WHOSE DATA WE RECEIVE FROM PATIENTS AND STAFF, SUCH AS REFEREES AND EMERGENCY CONTACTS:
We collect your contact details only where a patients or a member of our Staff puts you down as their emergency contact or where a patient gives them to us in order for you to serve as a point of contact.
How do we use your personal data?·
PATIENTS DATA: The main reason for using your personal details is to help you find the right treatment that might be suitable for you. The more information we have about you, your health and your allergies, the more bespoke we can make our treatments.
· We only use patients data For dentistry work.
· Obviously, our main area of work is Dentistry – treating the right patient with the right procedure. We've listed below various ways in which we may use and process your personal data for this purpose, where appropriate and in accordance with any local laws and requirements. Please note that this list is not exhaustive: - Collecting your data from you and other sources, such as doctors;- Storing your details (and updating them when necessary) on our database, so that we can contact you in relation to treatments;- Assessing data about you against treatments we think may be suitable for you;- Sending your information to doctors
· We may use your personal data for the above purposes if we deem it necessary to do so for our legitimate interests. If you want to know more about what this means, please go to OUR LEGAL BASIS FOR PROCESSING YOUR DATA later in this notice. If you are not happy about this, in certain circumstances you have the right to object and can find out more about how and when to do by contacting your supervisory authority – see Annex 2.· Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements. For more information in relation to your jurisdiction, please see Annex 2
· We may periodically send you information that we think you may find interesting, or to ask for your help with connecting other patients with treatments. In particular, we may wish to use your data for the purposes listed below, where appropriate and in accordance with any local laws and requirements. Please note that this list is not exhaustive. To enable us to develop and market other products and services;· We may in the future need your consent for some aspects of these activities which are not covered by our legitimate interests (in particular, the collection of data via cookies, and the delivery of direct marketing to you through digital channels) and, depending on the situation, we'll ask for this via an opt-in or soft-opt-in at that time (and which we explain further below). Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements. For more information in relation to your jurisdiction, please [go to Annex 3].
· Soft opt-in consent is a specific type of consent which applies where you have previously engaged with us (for example by treatment). Under ‘soft opt-in’ consent, we will take your consent as given unless or until you opt out. For most people, this is beneficial as it allows us to suggest other opportunities to you alongside the specific one we approached you for, significantly increasing the likelihood of us finding you the correct treatments and procedures.
· If you are not happy about our approach to marketing, you have the right to withdraw your consent at any time and can find out more about how to do so by contacting us or your supervisory authority. We want to let you know that even if you have opted out from our marketing communications it is possible that your details may be recaptured through public sources in an unconnected marketing campaign. We will try to make sure this doesn't happen, but if it does, we're sorry. We'd just ask that in those circumstances you opt out again.
To help us to establish, exercise or defend legal claims
· In more unusual circumstances, we may use your personal data to help us to establish, exercise or defend legal claims.
· You have the right to withdraw that consent at any time and can find out more about how to do so contact us at email@example.com
· PEOPLE WHOSE DATA WE RECEIVE FROM PATIENTS AND STAFF, SUCH AS REFEREES AND EMERGENCY CONTACTS: We use the personal details of a patients emergency contacts in the case of an accident or emergency affecting that patient. So, for example:
- If our patient put you down on our form as an emergency contact, we'll contact you in the case of an accident or emergency affecting them
· If you are not happy about this, you have the right to object and can find out more about how to do so by contacting us at firstname.lastname@example.org.
How do we safeguard your personal data?
· We care about protecting your information. That's why we put in place appropriate measures that are designed to prevent unauthorised access to, and misuse of, your personal data. We do this by having in place a range of appropriate technical and organisational measures. These include measures to deal with any suspected data breach.
· If you suspect any misuse or loss of or unauthorised access to your personal information, please let us know immediately at email@example.com
How long do we keep your personal data for?How can you access, amend or take back the personal data that you have given to us?
· Even if we already hold your personal data, you still have various rights in relation to it. To get in touch about these, please contact us. We will seek to deal with your request without undue delay, and in any event in accordance with the requirements of any applicable laws. Please note that we may keep a record of your communications to help us resolve any issues which you raise.
Right to object:
If we are using your data because we deem it necessary for our legitimate interests to do so, and you do not agree, you have the right to object. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases). Generally, we will only disagree with you if certain limited conditions apply.
· This right enables you to object to us processing your personal data where we do so for one of the following four reasons: (i) our legitimate interest; (ii) to enable us to perform a task in the public interest or exercise official authority;
· The "legitimate interests" category above is the most likely to apply to our patients. If your objection relates to us processing your personal data because we deem it necessary for your legitimate interests, we must act on your objection by ceasing the activity in question unless:- we can show that we have compelling legitimate grounds for processing which overrides your interests; or- we are processing your data for the establishment, exercise or defence of a legal claim.
· If your objection relates to direct marketing, we must act on your objection by ceasing this activity.
· Right to withdraw consent:
Where we have obtained your consent to process your personal data, you may withdraw your consent at any time.
· Data Subject Access Requests (DSAR):
Just so it's clear, you have the right to ask us to confirm what information we hold about you at any time, and you may ask us to modify, update or Delete such information. At this point we may comply with your request or, additionally do one of the following:
- we may ask you to verify your identity, or ask for more information about your request; and- where we are legally permitted to do so, we may decline your request, but we will explain why if we do so.
· At this time we may ask you to verify your identity and for more information about your request. If we provide you with access to the information we hold about you, we will not charge you for this unless your request is "manifestly unfounded or excessive". If you request further copies of this information from us, we may charge you a reasonable administrative cost where legally permissible. Where we are legally permitted to do so, we may refuse your request. If we refuse your request we will always tell you the reasons for doing so.
· Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements regarding data subject access requests and may refuse your request in accordance with such laws. For more information in relation to your jurisdiction, please go to Annex 3.
· Right to erasure:
In certain situations, (for example, where we have processed your data unlawfully), you have the right to request us to "erase" your personal data. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases) and will only disagree with you if certain limited conditions apply. If we do agree to your request, we will Delete your data but will generally assume that you would prefer us to keep a note of your name on our register of individuals who would prefer not to be contacted. That way, we will minimise the chances of you being contacted in the future where your data are collected in unconnected circumstances. If you would prefer us not to do this, you are free to say so.
· Your right to request that we erase your personal data in certain circumstances must normally meet one of the following criteria:
- the data are no longer necessary for the purpose for which we originally collected and/or processed them;- where previously given, you have withdrawn your consent to us processing your data, and there is no other valid reason for us to continue processing;- the data has been processed unlawfully (i.e. in a manner which does not comply with the GDPR);- it is necessary for the data to be erased in order for us to comply with our legal obligations as a data controller; or- if we process the data because we believe it necessary to do so for our legitimate interests, you object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing.
· Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements regarding data subject right to erasure and may refuse your request in accordance with local laws. For more information in relation to your jurisdiction, please got to Annex 3.
· We would only be entitled to refuse to comply with your request for one of the following reasons:
- to exercise the right of freedom of expression and information;- to comply with legal obligations or for the performance of a public interest task or exercise of official authority;- for public health reasons in the public interest;- for archival, research or statistical purposes; or
- to exercise or defend a legal claim.
· When complying with a valid request for the erasure of data we will take all reasonably practicable steps to Delete the relevant data.
· Right of data portability: If you wish, you have the right to transfer your data from us to another data controller. We will help with this
– either by directly transferring your data for you, or by providing you with a copy in a commonly used machine-readable format. In effect, this means that you are able to transfer your Lee Dental Care account details to another data controller. To allow you to do so, we will provide you with your data in a commonly used machine-readable format that is password-protected so that you can transfer the data to another online platform. Alternatively, we may directly transfer the data for you. This right of data portability applies to: (i) personal data that we process automatically (i.e. without any human intervention); (ii) personal data provided by you; and (iii) personal data that we process based on your consent or in order to fulfil a contract.
· Right to lodge a complaint with a supervisory authority:
You also have the right to lodge a complaint with your local supervisory authority, details of which can be found Annex 2.
· Right to restrict processing:
You have the right to request that we restrict our processing of your personal data in certain circumstances. This means that we can only continue to store your data and will not be able to carry out any further processing activities with it until either: (i) one of the circumstances listed below is resolved; (ii) you consent; or (iii) further processing is necessary for either the establishment, exercise or defence of legal claims, the protection of the rights of another individual, or reasons of important EU or Member State public interest.
· The circumstances in which you are entitled to request that we restrict the processing of your personal data are:
- where you dispute the accuracy of the personal data that we are processing about you. In this case, our processing of your personal data will be restricted for the period during which the accuracy of the data is verified;- where you object to our processing of your personal data for our legitimate interests. Here, you can request that the data be restricted while we verify our grounds for processing your personal data;- where our processing of your data is unlawful, but you would prefer us to restrict our processing of it rather than erasing it; and- where we have no further need to process your personal data but you require the data to establish, exercise, or defend legal claims.
· If we have shared your personal data with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal data.
· Right to rectification:
You also have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you. If we have shared this personal data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. Where appropriate, we will also tell you which third parties we have disclosed the inaccurate or incomplete personal data to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.
· It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during the period for which we hold your data.
· If your interests or requirements change let us know by emailing us at firstname.lastname@example.org
Who is responsible for processing your personal data on the Lee Dental Care website?
· Lee Dental Care controls the processing of personal data on its website(s) but it does not retain any personal data at this time. If this changes we will update this section of this notice
OUR LEGAL BASIS FOR PROCESSING YOUR DATA LEGITIMATE INTERESTS
· Article 6(1)(f) of the GDPR is the one that is relevant here – it says that we can process your data where it "is necessary for the purposes of the legitimate interests pursued by [us] or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of [you] which require protection of personal data."
· We don't think that any of the following activities prejudice individuals in any way – in fact, they help us to offer you a more tailored, efficient treatment, so everyone's a winner! However, you do have the right to object to us processing your personal data on this basis.
· Please note that in certain of the jurisdictions in which we operate, a different legal basis for data processing might apply in certain cases. For more information in relation to your jurisdiction, please got to Annex 3
· PATIENT DATA:
· We consider it reasonable to expect that if you are interested in a treatment we have presented to you, you are happy for us to collect and otherwise use your personal data and share that information with doctors if needed. Your doctor may also want to double check any information you've given us or to confirm your personal details, to the extent that this is appropriate and in accordance with local laws.
· In certain circumstances, we are required to obtain your consent to the processing of your personal data in relation to certain activities. Depending on exactly what we are doing with your information, this consent will be opt-in consent or soft opt-in consent.
· Article 4(11) of the GDPR states that (opt-in) consent is "any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her." In plain language, this means that:
- you have to give us your consent freely, without us putting you under any type of pressure;- you have to know what you are consenting to
– so we'll make sure we give you enough information;- you should have control over which processing activities you consent to and which you don’t. - you need to take positive and affirmative action in giving us your consent
We will keep records of any consents that you have given.
· Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements regarding consenting to receive marketing materials. For more information in relation to your jurisdiction, please go to Annex 3.
ESTABLISHING, EXERCISING OR DEFENDING LEGAL CLAIMS
· Sometimes it may be necessary for us to process personal data and, where appropriate and in accordance with local laws and requirements, sensitive personal data in connection with exercising or defending legal claims. Article 9(2)(f) of the GDPR allows this where the processing "is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity".
· This may arise for example where we need to take legal advice in relation to legal proceedings or are required by law to preserve or disclose certain information as part of the legal process.
ANNEX 1 – HOW TO CONTACT USCountry in which you use Lee Dental Care' services or supply Lee Dental Care with services: UK
The Lee Dental Care entity responsible for processing the personal data of patients and the emergency contacts and referees of patients and Lee Dental Care' Staff will depend on which of the below companies is the counterparty associated with the relevant arrangement:
· Lee Dental Care Limited How you can get in touch with us:
· You can write to us at the following address: Lee Dental Care 14 Miller Road, Tadley, Hampshire RG26 4LW: Alternatively, you can send an email to: email@example.com
ANNEX 2 – HOW TO CONTACT YOUR LOCAL SUPERVISORY AUTHORITY
Country in which you use Lee Dental Care' services or supply Lee Dental Care with services: UK
Details of your local supervisory authority:
The Information Commissioner's Office. You can contact them in the following ways:
· Post: Information Commissioner's Office
Wycliffe HouseWater LaneWilmslowCheshireSK9 5AF
Lee Dental Care' PROCESSING OF YOUR SENSITIVE PERSONAL DATA
COUNTRY-SPECIFIC LEGAL REQUIREMENT:
Where your personal data are processed in accordance with the fair processing condition relating to our rights and obligations under dentristry law, this relates to our processing of your personal data which is necessary for compliance with legal obligations, comply with health and safety laws.
NOTE: THIS APPENDIX WILL BE UPDATED WHEN LOCAL IMPLEMENTING LAW HAS BEEN FINALISED