2. Privacy Policy

Introduction

Norwich Spinal Health is committed to safeguarding the privacy of our customers, website visitors and service users.

Data Controller

Norwich Spinal Health is to be considered a data controller for the purposes of this policy and in compliance with the General Data Protection Regulation, effective from 25 May 2018 (“GDPR”).

Norwich Spinal Health is registered with the Information Commissioner’s Office.

Data Protection Officer

Norwich Spinal Health has decided that a Data Protection Officer is not required to be compliant with GDPR.

Data Processing

Norwich Spinal Health holds and processes data under varying legal basis (See Appendix One; legal basis). Our most common processes are detailed as follows:

Data process: Record cards and patient financial information Type of Data / Location: Specialist data: Record cards including: name, address, phone number, email, medical history, diagnosis, treatment information and payment details Legal Basis: Legal Requirement Details About the Data: Digital documents; stored securely. Retention Period: 8yrs

Data process: Booking System; Reminder Texts and Emails Type of Data / Location: Digital, cloud based: Including name, address, phone number, email address and date of birth Legal Basis: Contract Details About the Data: Capable; Server Based Software held on encrypted servers onsite within our clinic locations. Retention Period: 8yrs

Data process: CRM; Newsletter Type of Data / Location: Digital, Cloud Based: Including name, email address, clinic they attend Legal Basis: Consent Details About the Data: Mailchimp: Cloud based. Consent for marketing with new and existing patients Retention Period: Annual check – re opt-in/out

Data process: Survey Data Type of Data / Location: Digital, Cloud Based: Including name, email address Legal Basis: Consent Details About the Data: Survey Monkey: Consent to use data on taking Retention Period: Data deleted after use

Data process: Direct Debit Processing Type of Data / Location: Digital, Cloud Based: Including name, address, bank account details, email address Legal Basis: Consent Details About the Data: NatWest PayAway. Consent on taking prepayment plan. Details held by NatWest PayAway Retention Period: Data deleted 1yr after expiry of plan

Data process: Testimonials Type of Data / Location: Online – public domain, YouTube and our website Legal Basis: Consent Details About the Data: Held by internal marketing department. Retention Period: 8yrs or Removed by request of client

Norwich Spinal Health also processes data in terms of;

Staff and subcontractor details; name, profile pictures and employment details. In this instance the legal basis for processing is the performance of a contract between you and us.

Testimonials, see clauses 16–19.

Photographs at events; we reserve the right to use pictures taken at events for promotion and social media as part of a contractual basis on attendance, subject to your rights to opt out.

Website

Norwich Spinal Health’s website does not directly process any data, however it does process some data through indirect means, such as by utilising cookies (See Definitions; cookie), integrating with CRM booking software and using website tracking software.

Norwich Spinal Health’s website has an SSL certificate to add a greater level of security.

We cannot vouch for the safety or security of data published on an external link or via social media accounts. We remind all users to act with caution when posting.

Norwich Spinal Health does not store or process data directly on the website. The website does not contain logins for staff or members of the public to use.

Cookies

Norwich Spinal Health uses cookies to;

identify you when you visit our website and as you navigate our website

determine if you are logged onto our website

secure our website and services generally

help us to analyse and enhance the use and performance of our website and services; and

store your website use preferences.

Norwich Spinal Health will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website.

Website users are able to refuse to accept or block cookies through their browser security settings at any time. Blocking cookies may reduce usability or the number of features available on our website.

Norwich Spinal Health does not store, save or collect personal information from the website through cookies.

Tracking Software and CRM Integration

Norwich Spinal Health’s website uses tracking software to monitor its visitors to better understand how they use it. This software is provided by Google Analytics and Google Search Console. The information gathered relating to our website is used to create reports about the use of our website and to understand usage for further development. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.

Testimonials

Norwich Spinal Health may process testimonials and include the full name of the author of a testimonial.

Norwich Spinal Health reserves the right to copy, screenshot and use comments made about Norwich Spinal Health in a public arena, such as on social media and Google Reviews.

Testimonials may be shared on Norwich Spinal Health’s website, social media, paper and/or digital marketing. They may also be shared with employees and service users.

Norwich Spinal Health reserves the right to use anonymised testimonials or testimonials without use of identifiable data, where consent is not recorded following provision of a testimonial.

External Links

Although this website includes quality, safe and relevant external links, users are still advised to adopt a policy of caution before clicking any external web links mentioned throughout this website. (External links are clickable text / banner / image links to other websites etc.)

Norwich Spinal Health cannot guarantee or verify the contents of any externally linked website despite their best efforts. Users should therefore note that they click on external links at their own risk and this website and its owners cannot be held liable for any damages or implications caused by visiting any external links mentioned.

Shortened URL links might be used on social media or on Norwich Spinal Health’s website.

Social Media

Communication, engagement and actions taken through external social media platforms that this website and its owners participate on are subject to the terms and conditions as well as the privacy policies held with each social media platform respectively.

Users are advised to use social media platforms wisely and communicate / engage upon them with due care and caution in regard to their own privacy and personal details. Neither this website nor its owners will ever ask for personal or sensitive information through social media platforms. Users wishing to discuss sensitive details should do so through primary communication channels such as by telephone or email.

Norwich Spinal Health’s website may use social sharing buttons which help share web content directly from web pages to the social media platform in question. Users are advised before using such social sharing buttons that they do so at their own discretion and note that the social media platform may track and save your request to share a web page through your social media platform account.

Norwich Spinal Health reserves the right to publish comments, testimonials and posts made on social media in unedited form. We use automated social media walls and social share functions on our website to reflect up to date social media engagement. Website users are reminded that engagement with these functions are at their own risk.

Users are advised to take caution and use good judgement before clicking any shortened URLs published on social media platforms by Norwich Spinal Health. Despite the best efforts to ensure only genuine URLs are published, many social media platforms are prone to spam and hacking and therefore this website and its owners cannot be held liable for any damages or implications caused by visiting any shortened links.

Email Marketing and Contact

Norwich Spinal Health operates an email marketing program, used to inform visitors about products and services. Users can subscribe through an online automated process should they wish to do so at their own discretion. Some subscriptions may be manually processed through prior written agreement with the user.

Subscriptions are taken in compliance with UK Spam Laws detailed in the Privacy and Electronic Communications Regulations 2003 as well as GDPR.

Email marketing campaigns published by Norwich Spinal Health may contain tracking facilities within the actual email, linked to our website tracking. This information is used to refine future email campaigns and supply the user with more relevant content based around their activity.

In compliance with UK Spam Laws and the Privacy and Electronic Communications Regulations 2003, subscribers are given the opportunity to un-subscribe at any time through an automated system. This process is detailed at the footer of each email campaign. If an automated un-subscription system is unavailable, clear instructions on how to un-subscribe will be detailed instead.

Providing Your Data to Others

From time to time Norwich Spinal Health may contact your GP, insurance provider and/or other healthcare professionals about the status of your care. Norwich Spinal Health will gain consent from you that it is satisfactory for us to do this, however we reserve the right to do so should it be considered that there is a legal or vital interest to do so.

Norwich Spinal Health reserves the right to breach confidentiality and share personal data where there is a public safety, legal obligation or vital interest to do so.

Norwich Spinal Health may process any personal data identified in this policy for the establishment, exercise or defence of legal claims (whether administrative or out of court) and for the purposes of obtaining or maintaining insurance coverage, managing risks or obtaining professional advice.

Norwich Spinal Health might disclose personal data to our subcontractors or employees on your approval. We may also disclose some personal data on your request to other practitioners for referrals.

Financial transactions relating to our services are handled by [INSERT PAYMENT PROVIDER — see note]. We will share transaction data with any payment services or professional accountants in so far as processing and refunding payments, dealing with complaints and queries and to satisfy our wider financial and/or insurance obligations. You can find information about the payment services providers’ privacy policies and practices at [INSERT PAYMENT PROVIDER].

Your Rights: Retaining and Deleting Information

Personal data that we process, for any purpose, shall not be kept for longer than is necessary for that purpose or those purposes.

Norwich Spinal Health respects your rights under GDPR (See definitions, Your rights). Please contact [INSERT NORWICH SPINAL HEALTH CONTACT EMAIL] at any time to instruct us should you feel that your rights are being infringed or for requests for further information.

Requesting Data

You have the right to confirmation as to whether or not we process your personal data, the purposes of the processing, the categories of personal data concerned and the recipients of the personal data.

You have the right to request copies of data held by Norwich Spinal Health, providing the rights and freedoms of others are unaffected.

Requests for copies of data should be made to [INSERT NORWICH SPINAL HEALTH CONTACT EMAIL]. Norwich Spinal Health will confirm receipt of your request.

The first copy will be provided free of charge. Additional copies may be subject to a reasonable fee. Pursuant to GDPR, Norwich Spinal Health reserves the right to charge for requests that are vexatious or require additional administration.

Your Rights to Correct, Erase, Object to, Restrict Data and Withdraw Consent

You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

You have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

Variations

Norwich Spinal Health reserves the right to change and/or vary our website, services and/or policies at any time. Please check our website to see any latest variation.

Our Details

Norwich Spinal Health is owned and operated by [INSERT REGISTERED COMPANY NAME] (Registered Company Address in England and Wales: [INSERT REGISTERED ADDRESS]. Company number: [INSERT COMPANY NUMBER].)

[If applicable — insert details of any additional clinics/operating entities here. The original policy listed a separate Wickford clinic operated by a different company; delete this clause if it does not apply to Norwich Spinal Health.]

Please contact us via [INSERT CONTACT EMAIL] or [INSERT PHONE NUMBER] or by post at the above address should you need to contact us about anything within this policy.

[Policy last updated: [INSERT DATE] – Version 1.1]

APPENDIX ONE – Definitions

“Cookie” – A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

Legal Basis – the legal bases of the processing under the GDPR are:

Consent: the individual has given clear consent for you to process their personal data for a specific purpose.

Contract: the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract.

Legal obligation: the processing is necessary for you to comply with the law (not including contractual obligations).

Vital interests: the processing is necessary to protect someone’s life.

Public task: the processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law.

Legitimate interests: the processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.

Your Rights – Your principal rights under data protection law are:

the right to access;

the right to rectification;

the right to erasure;

the right to restrict processing;

the right to object to processing;

the right to data portability;

the right to complain to a supervisory authority; and

the right to withdraw consent.