GDPR 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), seek 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.

1 - The Practice

Norwich Osteopathic Clinic, based at 433 Earlham Road Norwich NR4 4HL, which hereafter for the purposes of this Privacy Notice will be referred to as “The Clinic”, is pleased to provide the following information:

2 - Who we are

Our practitioners diagnose and treat health conditions. Treatments are carried out in accordance with the Institute of Osteopathy’s patient charter http://www.iosteopathy.org/osteopathy/the-patient-charter/. The Clinic may also provide other treatments, about which our staff will be pleased to provide more details.

3 - Personal Data

a) For the purposes of providing treatment, The Clinic records and keeps detailed medical information about the Data Subject.  The Clinic only collects what is relevant and necessary for patient 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 personal 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. To be able to process your personal data it is a condition of any treatment that you give your explicit consent to allow your practitioner 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.

b) For marketing purposes, The Clinic 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 Clinic believes may be of interest to you.

c) In making initial contact with The Clinic you consent to The Clinic maintaining a marketing dialogue with you until you either opt out (which you can do at any time) or we decide to desist in promoting our services. The Clinic 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. The Clinic do not broker your data and you can ask to be removed from our marketing database by emailing or phoning The Clinic using the contact details provided at the end of this Privacy Notice.  When you arrive at your first appointment you will opt in or out of this in the signed Patient Explicit Data Agreement.

d) Some basic personal data may be collected about you from the marketing forms and surveys you complete, from records of our correspondence and phone calls and details of your visits to our website, including but not limited to, personally identifying information like Internet Protocol (IP) addresses.

e) The Clinic’s website  is hosted by Squarespace. Squarespace collects personal data when you visit this website, including:

  • Information about your browser, network and device

  • Web pages you visited prior to coming to this website

  • Your IP address

Squarespace needs this data to run this website, and to protect and improve its platform and services. Squarespace analyzes the data in a de-personalised form.  We share this information with Squarespace, our website analytics provider, to learn about site traffic and activity.

f) The clinic’s website uses cookies and similar technologies, which are small files or pieces of text that download to a device when a visitor accesses a website or app. We use these technologies to customise content and advertising, to provide social media features and to analyse traffic to the site. We also share information about your use of our site with our trusted social media, advertising and analytics partners. For information about viewing the cookies dropped on your device, visit About the cookies Squarespace uses.

g) The Clinic 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.

4 - 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.

5 - Legitimate interests pursued by The Clinic

To promote treatments for patients with all types of health problems indicated for osteopathic care.

6 – Consent

Through agreeing to this privacy notice you are consenting to The Clinic 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.

7 – Disclosure

The Clinic 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. The Clinic will not disclose your Personal Information unless compelled to, in order to meet legal obligations, regulations or valid governmental requests. The Clinic may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions 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.

8 - Retention Policy

The Clinic 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.

9 - Data storage

All electronic medical records are held and stored securely within Cliniko, which is a web based practice management software application based in Australia which stores its data in data centres in the United States.  Cliniko only stores the data and does not use it in any other way. For more information about this please see the section about “Personal Information we collect indirectly” within Cliniko’s Privacy Policy here https://www.cliniko.com/policies/privacy  

All financial records are held and stored within Clinko and Xero.  Xero is a cloud based accounts software platform founded in New Zealand which stores its data in data centres in the United States.  Xero only stores Personal Data from The Clinic, and does not use it in any other way or pass it on to third parties.  For more information about this please see Xero’s Privacy Policy here https://www.xero.com/uk/about/terms/microsoft-terms/privacy/

Historic paper clinic records are archived in The Archive Vault, which is a records management and document storage company based in Norwich. For more information about how they store your the Clinic’s data please see here https://www.archive-vault.co.uk/privacy-statement/

10 - Your rights as a data subject

At any point whilst The Clinic 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 The Clinic 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 The Clinic can confirm what information it holds about you and how it is processed.

11 - You can request the following information:

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

  • Contact details of the data protection officer, 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 The Clinic 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 (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.

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

The Clinic 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 The Clinic is dissatisfied with the quality, further information may be sought before personal data can be released. All requests should be made to rebecca@norwichosteopathicclinic.co.uk or by phoning 01603 504508 or writing to us at the address further below.

13 Complaints

In the event that you wish to make a complaint about how your personal data is being processed by The Clinic you have the right to complain to The Clinic.  If you do not get a response from The Clinic within 30 days, you can complain to the ICO.

The details for each of these contacts are:

Data Protection Officer at the Clinic: Rebecca Thorby, Norwich Osteopathic Clinic, Norwich, Norfolk NR4 7HL
Telephone 01603 504508 or email: rebecca@norwichosteopathicclinic.co.uk

Information Commissioner’s Office: Wycliffe House, Water Lane, Wilmslow, SK9 5AFTelephone +44 (0) 303 123 1113 or email: https://ico.org.uk/global/contact-us/email/