Privacy Policy

BACKGROUND :

This Policy applies as between you, the User of this Web Site and Bramingham Dental Clinic the owner and provider of this Web Site. This Policy applies to our use of any and all Data collected by us in relation to your use of the Web Site and any Services or Systems therein.

Definitions and Interpretation

In this Policy the following terms shall have the following meanings :

"Account" : means collectively the personal information, Payment Information and credentials used by Users to access Material and / or any communications System on the Web Site;

"Content" : means any text, graphics, images, audio, video, software, data compilations and any other form of information capable of being stored in a computer that appears on or forms part of this Web Site;

"Cookie" : means a small text file placed on your computer by Bramingham Dental Clinic when you visit certain parts of this Web Site. This allows us to identify recurring visitors and to analyse their browsing habits within the Web Site. Further details can be found below;

"Data" : means collectively all information that you submit to the Web Site. This includes, but is not limited to, Account details and information submitted using any of our Services or Systems;

"Bramingham Dental Clinic" : means Bramingham Dental Clinic, 1st Floor Freeman Avenue, Whitehorse Vale, Luton, Bedfordshire, LU3 4AD;

"Service" : means collectively any online facilities, tools, services or information that Bramingham Dental Clinic makes available through the Web Site either now or in the future;

"System" : means any online communications infrastructure that Bramingham Dental Clinic makes available through the Web Site either now or in the future. This includes, but is not limited to, web-based email, message boards, live chat facilities and email links;

"User" / "Users" : means any third party that accesses the Web Site and is not employed by Bramingham Dental Clinic and acting in the course of their employment; and

"Web Site" : means the website that you are currently using (m) and any sub-domains of this site (www.braminghamdental.com) unless expressly excluded by their own terms and conditions.


Data Collected

Without limitation, any of the following Data may be collected:

  • name;
  • contact information such as email addresses and telephone numbers;
  • demographic information such as post code, preferences and interests;
  • IP address (automatically collected);
  • web browser type and version (automatically collected);
  • operating system (automatically collected);
  • a list of URLS starting with a referring site, your activity on this Web Site, and the site you exit to (automatically collected); and
Our Use of Data

  • Any personal Data you submit will be retained by Bramingham Dental Clinic for as long as you use the Services and Systems provided on the Web Site. Data that you may submit through any communications System that we may provide may be retained for a longer period of up to one year.
  • Unless we are obliged or permitted by law to do so, and subject to Clause 4, your Data will not be disclosed to third parties. This does not our affiliates and / or other companies within our group.
  • All personal Data is stored securely in accordance with the principles of the Data Protection Act 1998. For more details on security, see clause 9 below.
  • Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Web Site. Specifically, Data may be used by us for the following reasons:
    • internal record keeping;
    • improvement of our products / services;
    • transmission by email of promotional materials that may be of interest to you;
    • contact for market research purposes which may be done using email, telephone, fax or mail. Such information may be used to customise or update the Web Site.
Third Party Web Sites and Services

Bramingham Dental Clinic may, from time to time, employ the services of other parties for dealing with matters that may include, but are not limited to, payment handling, delivery of purchased items, search engine facilities, advertising and marketing. The providers of such services do have access to certain personal Data provided by Users of this Web Site. Any Data used by such parties is used only to the extent required by them to perform the services that Bramingham Dental Clinic requests. Any use for other purposes is strictly prohibited. Furthermore, any Data that is processed by third parties must be processed within the terms of this Policy and in accordance with the Data Protection Act 1998.

Changes of Business Ownership and Control

  • Bramingham Dental Clinic may, from time to time, expand or reduce its business and this may involve the sale of certain divisions or the transfer of control of certain divisions to other parties. Data provided by Users will, where it is relevant to any division so transferred, be transferred along with that division and the new owner or newly controlling party will, under the terms of this Policy, be permitted to use the Data for the purposes for which it was supplied by you.
  • In the event that any Data submitted by Users will be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your Data deleted or withheld from the new owner or controller.
Controlling Access to your Data

  • Wherever you are required to submit Data, you will be given options to restrict our use of that Data. This may include the following:
    • use of Data for direct marketing purposes; and
    • sharing Data with third parties.
Your Right to Withhold Information

  • You may access certain areas of the Web Site without providing any Data at all. However, to use all Services and Systems available on the Web Site you may be required to submit Account information or other Data.
Accessing your own Data

  • You may access your Account at any time to view or amend the Data. You may need to modify or update your Data if your circumstances change. Additional Data as to your marketing preferences may also be stored and you may change this at any time.
  • You have the right to ask for a copy of your personal Data on payment of a small fee.
Cookies

  • Bramingham Dental Clinic may set and access cookies on your computer.
  • A cookie is a small file that resides on your computer’s hard drive and often contains an anonymous unique identifier and is accessible only by the web site that placed it there, not any other sites.
  • You may delete cookies, however you may lose any information that enables you to access the website more quickly.
  • You can choose to enable or disable cookies in your web browser. By default, your browser will accept cookies, however this can be altered. For further details please consult the help menu in your browser. Disabling cookies may prevent you from using the full range of services available on the website.
Changes to this Policy

Bramingham Dental Clinic reserves the right to change this Privacy Policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Web Site and you are deemed to have accepted the terms of the Policy on your first use of the Web Site following the alterations.

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 controller is Bramingham Dental Clinic Limited, the information Governance Lead and the Data Protection Officer is the Practice Owner Rahim Sawani

This Privacy Notice is available on the practice website www.braminghamdental.com. It is also available on request by email if you contact info@braminghamdental.com or by calling the practice on 01582 490410

You will be asked to provide personal information when joining the practice. The purpose of us processing this data is to provide optimum health care to you.

The categories of data we process are:

 Personal data for the purposes of staff and self-employed team member management
 Personal data for the purposes of direct mail/email/text/other marketing
 Special category data including health records for the purposes of the delivery of health care
 Special category data including health records and details of criminal record checks for managing employees and contracted team members

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.

 Personal data is stored in the UK 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

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.

You have the following personal data rights:

• The right to be informed
• The right of access
• The right to rectification
• The right to erasure (clinical records must be retained for a certain time period)
• The right to restrict processing
• The right to data portability
• The right to object

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 217S) 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 Viviene Hallett at the practice for a comment, suggestion or a complaint about your data processing at info@braminghamdental.com, or 01582 490410 or by writing to or visiting the practice at First Floor, Freeman Avenue, Luton Beds LU3 4AD. 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)

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