PRIVACY POLICY

Wilson Smith Physiotherapy Privacy Policy 

Introduction

This Privacy Policy outlines Wilson Smith Physiotherapy ("we", "our" or "the Company") practices with respect to information collected from users who access our website at Walnut Cottage, Nursery Lane, Sheldwich ME13 0DZ ("Site"), or otherwise share personal information with us (collectively: "Users"). 

Grounds for data collection 

Processing of your personal information (meaning, any information which may potentially allow your identification with reasonable means; hereinafter "Personal Information") is necessary for the performance of our contractual obligations towards you and providing you with our services, to protect our legitimate interests and for compliance with legal and financial regulatory obligations to which we are subject.

When you use the Site, you consent to the collection, storage, use, disclosure and other uses of your Personal Information as described in this Privacy Policy.

We encourage our Users to carefully read the Privacy Policy and use it to make informed decisions. 

Who We Are

We are committed to safeguarding the privacy of our patients; this policy sets out how we will treat your personal information. Nothing in this policy shall limit your statutory rights in relation to your personal data.
By providing personal data to us via our patient registration forms or mailing list request forms you consent to our processing of your data in accordance with this policy.

We are a “data controller” for the purpose of EU General Data Protection Regulation 2016/679 “Data Protection Law”. This means that we are responsible for, and control the processing, your personal information. In certain circumstances we process data on behalf of your General Practitioner (GP), Private Medical Insurance, Employers or Solicitors. In such circumstances we may be joint data controller.

For further information about our privacy practices, please contact our Data Protection Officer by writing to Wilson Smith Physiotherapy, Walnut Cottage, Nursery Lane, Sheldwich, Faversham, Kent ME13 0DZ or calling 01795 530881 or 07974146353 emailing liz@wilsonsmithphysio.co.uk.

How We Collect Information About You

We collect information from you when you interact with us directly: This could be if you ask us about our services and products, register as a patient or otherwise provide us with your personal information. This includes when you phone us, visit our website, get in touch through the post or in person.

We collect information about you when you are referred to our services via our joint data controllers. This could be your GP, Private Medical Company, Employer or Solicitors.

Information We Collect and Why We Use It

Personal Information
Personal information we collect includes details such as your name, date of birth, email address, postal address, telephone number, GP and occupation details. You will have given us this information whilst registering as a patient.

We Will Mainly Use This Information:
To provide the services or goods that you have requested.
To contact you with important administrative messages.
To help us design you a personalised treatment programme.
To keep other Medical Professionals, Insurance Companies, Employers and Solicitors up to date with your progress where appropriate.
We May Also Use Your Personal Information:
To send you updates on our clinic, team members, services and products.

Sensitive Personal Information:
Data Protection Law recognises that some categories of personal information are more sensitive. Examples of sensitive personal information can include a person’s health, race, ethnic origin, sex life or political opinions. When registering as a patient and during your treatment we will ask you about any relevant and significant medical history which will be recorded in your treatment notes. This information is only used to form a clinical diagnosis and treatment plan. We will share this information with your referrer and with your express permission. We will not pass on your details without your express permission except in exceptional circumstances. Examples of this might include anyone reporting serious self-harm or posing as a threat to others or children reporting to us serious issues such as physical abuse or exploitation.

Using Your Information
In some cases, we will only use our personal information where we have your consent or;
For you to be able to use our services
To send statements and invoices to you
To send you email notifications you have specifically requested
To send you our newsletter or marketing communications relating to our business (you can inform us at any time if you no longer require marketing communications)
To deal with enquiries or complaints made by you about our services or products.
We will not without your express consent provide your personal information to any third parties for the purpose of direct marketing.

Legal Disclosure

We may disclose your information if required to do so by law (for example, to comply with applicable laws, regulations and codes of practice or in response to a valid request from a competent authority); or, in order to enforce our conditions of sale and other agreements.

Keeping Your Information Safe
We take looking after your information very seriously. We’ve implemented appropriate physical, technical and organisational measures to protect the personal information we have under our control, both on and off-line, from improper access, use, alteration, destruction and loss.
Unfortunately the transmission of information using the internet is not completely secure. Although we do our best to protect your personal information sent to us this way, we cannot guarantee the security of data transmitted to our site.
All our website financial transactions are handled through our payment service provider(s). You should only provide your personal information to those providers after reviewing their privacy policies, which are available on their website(s). We will share information with payment service providers only to the extent necessary for the purposes of processing payments you make via our site and for the prevention and detection of crime. We will not store any credit card information.

How Long We Hold Your Information For
We only keep it as long as is reasonable and necessary for the relevant activity, which may be to fulfil statutory obligations.

Your Rights

You may request to: 
Receive confirmation as to whether or not personal information concerning you is being processed, and access your stored personal information, together with supplementary information. 
Receive a copy of personal information you directly volunteer to us in a structured, commonly used and machine-readable format. 
Request rectification of your personal information that is in our control.
Request erasure of your personal information. 
Object to the processing of personal information by us. 
Request to restrict processing of your personal information by us.
Lodge a complaint with a supervisory authority.

You may have certain rights under the Act in relation to the information that we hold about you. The rights include:
You are entitled to have access to your personal data. You may request by writing to us (at the address given at the start of the policy), details of your information which we hold and the purposes for which it is held. We will provide this information within 40 days of your request, subject to any routine processing continuing between that time and the time of the response.
You are entitled to request that we stop using information about you for the purpose of direct marketing (i.e. the communication to you (by whatever means) of any advertising or marketing material). The request can be made by email at any time.
You are entitled to require a correction of errors in the personal information held about you are entitled to apply to ask the court for an order that such erroneous information be rectified, blocked, destroyed or erased.

However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements. 

If you wish to exercise any of the aforementioned rights, or receive more information, please contact our Data Protection Officer (“DPO”) using the details provided above.

Updating Information

Please let us know if the personal information which we hold about you needs to be corrected or updated.

Retention

We will retain your personal information for as long as necessary to provide our services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we will keep records containing client personal data, account opening documents, communications and anything else as required by applicable laws and regulations. 

We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.

Third party collection of information

Our website may contain links to other websites. We are not responsible for the privacy policies or practices of third part websites.  Our policy only addresses the use and disclosure of information we collect from you. To the extent you disclose your information to other parties or sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them. Accordingly, we encourage you to read the terms and conditions and privacy policy of each third party that you choose to disclose information to. 

This Privacy Policy does not apply to the practices of companies that we do not own or control, or to individuals whom we do not employ or manage, including any of the third parties which we may disclose information as set forth in this Privacy Policy. 

How do we safeguard your information?

We take great care in implementing and maintaining the security of the Site and your information.  Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse our Site, and we make no warranty, express, implied or otherwise, that we will prevent such access.

Transfer of data outside the EEA 

Please note that some data recipients may be located outside the EEA. In such cases we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection.

Marketing

We may use your Personal Information, such as your name, email address, telephone number, etc. ourselves or by using our third party subcontractors for the purpose of providing you with promotional materials, concerning our services, which we believe may interest you.  

Out of respect to your right to privacy we provide you within such marketing materials with means to decline receiving further marketing offers from us. If you unsubscribe we will remove your email address or telephone number from our marketing distribution lists. 

Please note that even if you have unsubscribed from receiving marketing emails from us, we may send you other types of important e-mail communications without offering you the opportunity to opt out of receiving them. These may include customer service announcements or administrative notices.

Corporate transaction

We may share information in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, the transferee or acquiring company will assume the rights and obligations as described in this Privacy Policy.

Minors

We understand the importance of protecting children’s privacy, especially in an online environment. The Site is not designed for or directed at children. Under no circumstances shall we allow use of our services by minors without prior consent or authorization by a parent or legal guardian. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at the above address.

Updates or amendments to this Privacy Policy

We reserve the right to periodically amend or revise the Privacy Policy; material changes will be effective immediately upon the display of the revised Privacy policy. The last revision will be reflected in the "Last modified" section. Your continued use of the Platform, following the notification of such amendments on our website, constitutes your acknowledgment and consent of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments.

How to contact us

If you have any general questions about the Site or the information we collect about you and how we use it, you can contact us at the  address above.

Last Modified 12/04/2019
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