G.D.P.R. 2018 PRIVACY NOTICE

 

 

Scope

This document refers to personal data, which is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain.

The General Data Protection Regulation (GDPR) which is EU wide and far more extensive than its predecessor the Data Protection Act, along with the Privacy and Electronic Communications Regulations (PECR), seeks to protect and enhance the rights of EU data subjects. 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.

 

The Practice

The Clear Ear Clinic is based in Flat 3, Lister House, 11-12 Wimpole Street, London. W1G 9ST. For the purposes of this Privacy Notice Clear Ear Clinic will be referred as CEC. We are pleased to provide the following information:

 

Who we are

CEC provide an aural care and management service using the treatment of micro-suction. Micro-suction is the safest and most effective method of removing earwax, foreign bodies and treating ear infections of the external canal. The method enlists the use of an operating microscope and a low-pressure suction system to remove all occluding earwax and debris, completely and safely, avoiding the need or use of irrigating or syringing the ear canal. 

 

Statement of Purpose

Clear Ear Clinic has developed the ‘gold standard’ in aural micro suction through being committed in providing genuine customer care. Commitment to a safe, clean, caring environment where accessible and affordable individual ear care and ear health management is delivered through the advanced clinical practitioners and the technique of aural micro-suction.

Our aims and objectives are to encourage patients to view their aural care as a preventative measure.

 

Personal Data

  1. For the purposes of providing treatment, CEC may require detailed medical information. We will only collect what is relevant and necessary for your treatment. When you visit our practice, we will make notes which may include details concerning your medication, treatment and other issues affecting your health. This data is always held securely, is not shared with anyone not involved in your treatment, although for data storage purposes it may be handled by pre-vetted staff who have all signed an integrity and confidentiality agreement

  2. To be able to process your personal data it is a condition of any treatment that you give your explicit consent to allow CEC to document and process your personal medical data. Contact details provided by you such as telephone numbers, email addresses, postal addresses may be used to remind you of future appointments and provide reports or other information concerning your treatment where consent is given. As part of our obligations as primary healthcare practitioners there may be circumstances related to your treatment and on-going care that will require the sharing of your medical records with other healthcare practitioners e.g. GPs, consultants, surgeons and/or medical insurance companies. Where this is required we will always inform you first unless we are under a legal obligation to comply.

  3. For marketing purposes, CEC may also use the contact details provided by you to respond to your enquiries, including making telephone contact and emailing information to you which the practice believes may be of interest to you, once again only if we have obtained your consent.

  4. CEC may occasionally also act on behalf of its patients in the capacity of data processor, when we may promote other practitioners based at our premises, who may not be employed by us. CEC do not broker your data and you can ask to be removed from our database by emailing or phoning the practice using the contact details provided at the end of this Privacy Notice.

  5. CEC will only collect the information needed so that we can provide you with the services you require, the business does not sell or broker your data.

 

 

Legal basis for processing any personal data

To meet our contractual obligations obtained from explicit Patient Consent and legitimate interest to respond to enquiries concerning the services provided.

 

 

Legitimate interests pursued by Clear Ear Clinic

To promote treatments for patients with all aural health problems requiring aural care and management.

 

 

Consent

Through agreeing to this privacy notice you are consenting to CEC 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 end of this Privacy Notice.

 

Disclosure

CEC will keep your personal information safe and secure. Only staff engaged in providing your treatment will have access to your patient records, although our administration team will have access to your contact details so that they can make appointments and manage your account. CEC will not disclose your personal information unless compelled to, in order to meet legal obligations, regulations or valid governmental requests. CEC may also need to investigate any potential violations to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of its staff.

Retention Policy

CEC will process personal data during the duration of any treatment and will continue to store only the personal data needed for eight years after the contract has expired to meet any legal obligations. After eight years all personal data will be deleted, unless basic information needs to be retained by us 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.

Data storage

All data is stored within the United Kingdom. CEC does not store personal data outside the EEA.

Your rights as a data subject

At any point whilst CEC are in possession of, or processing your personal data, all data subjects 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

In the event that CEC refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge. At your request CEC can confirm what information it holds about you and how it is processed.

 

You can request the following information:

  • Identity and the contact details of the person or organisation (CEC) that has determined how and why to process your data

  • Contact details of the data protection contact, where applicable

  • The purpose of the processing as well as the legal basis for processing

  • If the processing is based on the legitimate interests of CEC 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 INFORMATION COMISSION OFFICE (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 wasn’t collected directly from you

  • Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing

 

 

To access what personal data is held, identification will be required

CEC will accept the following forms of identification (ID) when information on your personal data is requested: 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 CEC is dissatisfied with the quality, further information may be sought before personal data can be released.

All requests should be made to info@clearearclinic.co.uk or by phoning +44 (0) 2074956314 or writing to us at the address below.

 

 

 

 

 

Complaints

In the event that you wish to make a complaint about how your personal data is being processed by CEC, you have the right to complain to us. If you do not get a response within 30 days, you can complain to the Information Commissioner’s Office.

 

 

 

The details for each of these contacts are:

Clear Ear Clinic Limited

Cathy Peel (Data Protection Contact)

Flat 3, Lister House

11-12 Wimpole Street

London

Telephone + 44 (0) 207 4956314    Email: cathypeel@clearearclinic.co.uk

 

 

 

Information Commissioner’s Office (ICO)

Wycliffe House, Water Lane, Wilmslow, SK9 5AF

Telephone +44 (0) 303 123 1113    Email: https://ico.org.uk/global/contact-us/email/

Please quote Registration No. Z1812248