Personal data or information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed. 

We hold many types of data about you including:-

There are "special categories" of more sensitive personal data which require a higher level of protection. The following information falls under such category. 

• Health records

We will use your special category data:

• to ensure the care you receive at the clinic is appropriate to your condition
• to determine reasonable adjustments that should be made for access to the clinic or to treatment

We must process special categories of data in accordance with more stringent guidelines. We will process special categories of data when the following applies:

• you have given explicit consent to the processing (using our consent form)
• in order to carry out our legal obligations 
• for reasons of substantial public interest

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public.

As with all cases of seeking consent from you, you will have full control over your decision to give or withhold consent and there will be no consequences where consent is withheld. Consent, once given, may be withdrawn at any time. There will be no consequences where consent is withdrawn.

We collect data about you in a variety of ways and this will usually start when you make an enquiry to the clinic and continue when you attend your first and subsequent appointments. At this clinic we keep paper records, and compile letters in electronic form on the computer. We have introduced a computerised system using the clinic software "Jane". All information on Jane is encrypted using 256 bit encryption (the same as online banking uses). Data in Jane is stored in a private secure server bank located in a secured SOC2, Type2-certified data center, and all your data in Jane is stored in London, England. Administrators, practitioners and patients each access Jane using their own account secured by a username and password. Patients only have access to their own data and can not see other patient records or have any control over Jane. Jane is fully compliant with EU GDPR. 

The law on data protection allows us to process your data for certain reasons only, these are classified as legitimate interests. Most commonly, we will use your personal information in the following circumstances: 

• in order for us to carry out our contract with you (your requesting treatment and our agreement to provide it constitutes a contract) which will include confirming appointments, informing you of changes to appointments or clinic arrangements, changes to facilities or services at the clinic.
• in order to provide you with the best possible treatment by recording health and treatment information which would be in your best interest.
• in order to carry out legally required duties such as those required by me by my government appointed regulator
• where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests

We may use your personal information in these rare situations:

We need all the categories of information to primarily allow us to perform our contract of treatment with you and to enable us to comply with legal obligations. 

One of the reasons for processing your data is to allow us to carry out our duties in line with your contract of care with us. If you do not provide us with the data needed to do this, we will be unable to perform that care to ensure your best interests are being maintained. We may also be prevented from continuing with your treatment with us due to our legal obligations. 

We will only use your personal information for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. 

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. Your data is not used for marketing purposes.

No decision will be made about you solely on the basis of automated decision making (where a decision is taken about you using an electronic system without human involvement).

Your data may be shared with colleagues within the clinic but only where it is necessary for them to undertake their duties. This includes, for example, other chiropractors on behalf of the clinic, sports therapist, and reception staff.

We may share your data with third parties in order to facilitate a referral to another healthcare practitioner, investigation or to keep your GP informed about your progress with treatment 

We may also share your data with third parties as part of a Clinic sale or restructure, or for other reasons to comply with a legal obligation upon us. We would always keep you informed of these situations.

We do not share your data with bodies outside of the European Economic Area.

We have put in place measures to protect the security of your information against accidental loss or disclosure, alteration, unauthorised access, destruction or abuse. We have implemented processes to guard against such. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Personal data in paper form is kept in locked filing cabinets in the office which is locked out of clinic hours and/or when the office is unattended. Electronic data on the PC is password protected. Data stored on Jane is encrypted and username and password protected. If you require any more information as to how we protect your data please contact the clinic. 

Where we share your data with third parties, we provide written instructions to them to ensure that your data are held securely and in line with GDPR requirements. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.

In line with data protection principles, we only keep your data for as long as we need it for, which will be at least for the duration of your being a patient with us and we are legally required, by the Chiropractic regulator, to keep this data for eight years after your time as a patient has ended (or in the case of children until the age of 25). To determine the appropriate retention period for personal data beyond eight years we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means and the applicable legal requirements. 

Once we no longer have a lawful use for retaining your information, we will dispose of it in a secure manner than maintains data security. 

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. 

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 your time as a patient with us.

The law on data protection gives you certain rights in relation to the data we hold on you. These rights are as follows:- 

• the right of access. You have the right to access the data that we hold on you. To do so, you should make a subject access request. 
• the right for any inaccuracies to be corrected. If any data that we hold about you is incomplete or inaccurate, you can require us to correct it. 
• the right to be informed. This means that we must tell you how we use your data, and this is the purpose of this privacy notice. We also must inform you of any changes to how we use your data.
• the right to have information deleted. If you would like us to stop processing your data, you have the right to ask us to delete it from our systems where you believe there is no reason for us to continue processing it.
• the right to restrict the processing of the data. For example, if you believe the data we hold is incorrect, we will stop processing the data (whilst still holding it) until we have ensured that the data is correct.
• the right to portability. You may request transfer the data that we hold on you for your own purposes.

If you want to access your data, review, verify or correct your data, request we erase your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please submit a signed written request to the Chesterfield Chiropractic Clinic Data Controller.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee for a second or subsequent copy of information or if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

To withdraw consent please contact the Chesterfield Chiropractic Clinic Data Controller.

If you have any questions about this Privacy Notice or how we handle your information, please contact the Chesterfield Chiropractic Clinic Data Controller. They can be contacted at the Chesterfield Chiropractic Clinic, Gladstone House, 14 Gladstone Road, Chesterfield, Derbyshire, S40 4TE.

You have the right to make a complaint at any time to the supervisory authority in the UK for data protection matters, the Information Commissioner’s Office (ICO).