Dentaria is an independent dental practice providing a range of dental treatments on a private and NHS basis. Our practice comprises of employed and self-employed individuals. We work together to ensure our patient’s privacy is respected and their personal data is protected.
This privacy notice outlines how we handle patient information according to the UK GDPR and Data Protection Act 2018 (DPA18).
|Dentaria, 19 Glenshiel Road, Eltham, London, SE9 1AQ
|020 8294 3081
We have appointed an in-house Data Protection Officer who can be contacted using the details above.
Most of the personal information we process is provided to us directly, such as when you contact the practice, engage with our website or during your appointment.
Occasionally, however, we may receive patient information from other sources such as:
We may receive data from third parties, including analytics providers such as Google located outside the UK, advertising networks such as Facebook located outside the UK providers of technical, payment and delivery services.
The Types of Personal Information We Collect and Process
The table below sets out the main types of patient information we process, the reasons why and the lawful basis for doing so.
|Categories of Personal Data
|Examples of Personal Data
|Purposes of Processing Personal Data
|Lawful Basis under UK GDPR and DPA18
|Name, Contact Details, Patient Reference number, NHS number, date of birth, signatures, photos and videos (non-clinical purposes), where you can be identified in CCTV footage.
|1. Add you to our patient system.
|1. Performance of a contract (in connection with private treatments), Public Task (in connection with NHS treatments)..
|2. Contact you in connection with your treatment and manage our relationship with you; this includes sending you recalls and appointment reminders.
|2. Performance of a contract (in connection with private treatments), Public Task (in connection with NHS treatments), in our legitimate interest.
|3. Send you marketing information.
|3. Consent, in our legitimate interest
|4. Share your non-clinical videos and photos such as reactions and testimonials to our online audiences and training courses.
|5. For the prevention and detection of crime and to protect our assets including staff (CCTV still and moving images)
|5. In our legitimate interest.
|Next of kin, and details of any guardians, carers and representatives.
|1. Contact them in an emergency.
|1. Vital interest, consent.
|2. Contact them about your care if they are responsible for looking after you.
|2. (In connection with private treatments), Public Task (in connection with NHS treatments)., consent.
|Details of any payments you make to us or need to make to us your debit and credit card details, and if applicable, your bank account details
|1. Process any payments you make to us or need to make to us.
|1. (In connection with private treatments), Public Task (in connection with NHS treatments).
|2. Recover any debts due to us.
|2. In our legitimate interest.
|Data about your use of our website such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website, social media channels and patient portal.
|1. Analyse how patients use our online services to develop them, grow our practice, and progress our marketing strategies.
|1, 2. In our legitimate interest.
|2. Administer and protect our practice, social media channels, website, deliver relevant online content and advertisements to you, and understand our advertising effectiveness.
|3. Detect and identify whether an individual has used the practice’s guest WI-FI network to conduct unlawful activities.
|3. In our legitimate interest, Legal obligation.
|Personal data contained in an email, comments on social media posts, letters, instant messages.
|1. To investigate and respond to a complaint, query or feedback you may have.
|1, 2 and 3. In our legitimate interest.
|2. Provide evidence required to establish a legal defence or regulatory enquiry.
|Medical and dental histories, lifestyle questions (e.g. alcohol and tobacco use), x-rays, clinical photographs, digital scans of your mouth and teeth, study models, treatment plans, patient understanding exercises, recorded communications (e.g. voice messages, video calls, instant messages, letters and emails), clinical notes made by our clinical staff and other dental professionals involved in your care and treatment, information of any health and safety incident you have been involved in.
|1. For the assessment, diagnosis of your dental health to administer care and treatment, including prescription and referral.
|1. Necessary for your dental and orthodontic treatment and the administration of it.
|2. To establish a legal defence in the event of a claim or regulatory investigation.
|2. *Legal defence
|3. For clinical and peer review to assess equality and the level of care provided to patients visiting the practice.
|3. Necessary for your dental and orthodontic treatment and the administration of it. Substantial Public Interest – Equality.
|4. To record and manage a health and safety incident that has occurred on the premises. Including, insurance purposes.
|4. **Legal defence, Substantial Public Interest – Insurance***
|Where relevant, we may need to process your ethnic group and language.
|1. 1. Understand your cultural, religious and language needs, identify any patients at risk.
|1. Necessary for your dental and orthodontic treatment and the administration of it.*
|2. Comply with the law which gives the practice a duty to promote equality.
|2. Public Task, Necessary for your dental and orthodontic treatment and the administration of it.* Substantial Public Interest – Equality.**
|Religious and philosophical beliefs
|Where relevant to your care, such as fasting or abstaining from certain types of treatments.
|1. For the assessment, diagnose your dental health to administer care and treatment, including prescription and referral.
|1. Necessary for your dental and orthodontic treatment and the administration of it.*
|2. Comply with the law, which gives the practice a duty to promote equality.
|2. Legal defence
|3. Necessary for your dental and orthodontic treatment and the administration of it. Substantial Public Interest – Equality.**
*For this purpose, we also rely on the lawful bases set out in the Data Protection Act 2018, Schedule 2, Part 1, Paragraph 2.2.C and 2.2.D, which states processing is necessary for medical diagnosis, and the provision of health care and treatment, respectively.
**For this purpose, we also rely on the lawful bases set out in the Data Protection Act 2018, Schedule 2, Part 2, Paragraph 8.1.B. This states processing is necessary for identifying or keeping under review the existence or absence of equality of opportunity or treatment between groups of people specified in relation to that category with a view to enabling such equality to be promoted or maintained.
*** For this purpose, we also rely on the lawful bases set out in the Data Protection Act 2018, Schedule 2, Part 2, Paragraph 20.1.A. This states processing is necessary for insurance purposes.
Providing you with private dental treatment means the practice and your treating clinician must collect and process your personal data. Refusal to provide personal data connected to these lawful bases may directly impact our ability to treat you and we may be unable to continue your treatment at the practice.
We process data relating to NHS treatment under the public task legal basis. Under the NHS dental contract, we must collect and share data as defined by the NHS. For example, the NHS PR form is used to claim for free or reduced cost NHS dental services. This form collects additional information which the practice would not usually ask where the treatment is privately funded.
You can view an online copy of the NHS PR form, which includes a privacy statement by the NHSBSA.
The above table sets out where we rely on your consent to process your personal data. You can request to withdraw your consent for these purposes by contacting the practice using the contact details found at the top of this notice.
How We Store Your Data
Your information is securely stored paper and digital formats. We use online and cloud-based digital storage. Where data is stored outside of the UK, we ensure the correct legal protection are in place to ensure compliance with international data transfer rules.
How long we keep your Personal Data
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including to satisfy any medical, legal, accounting, or reporting requirements.
When deciding the correct time to keep the data, we look at the amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, and necessary ongoing purposes of the processing.
Your information is typically used internally by staff employed by the practice and self-employed dentists working at the practice and responsible for your treatment.
There may be instances where we need to share it – for example, with:
We will only disclose your information on a need-to-know basis and limit any information we share to the minimum necessary.
In certain circumstances or if required by law, we may need to disclose your information to a third party not connected with your health care, including HMRC or other law enforcement or government agencies.
Where we transfer your data to third parties outside of the UK, we will ensure that certain safeguards are in place to provide a similar degree of security for your personal data. As such:
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
Under data protection law, you have rights including:
Your right of access – You have the right to ask us for copies of your personal information.
Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.
Your right to object to processing – You have the right to object to the processing of your personal information in certain circumstances.
Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
Depending on the nature of the request we may need to ask you to provide further information to verify your identity and/or better understand your request.
If you have any concerns about our use of your personal information, you can make a complaint to us using the contact details at the top of this notice.
If you are dissatisfied with our response or prefer to lodge your complaint with them directly you can do using the details below.
|The ICO’s address:
Information Commissioner’s Office
Helpline number: 0303 123 1113
We are one of several organisations aiming to enhance patient and public care in the health and care system. As such, we are required to inform you of how the NHS uses your data for additional purposes and how you can opt-out of this arrangement.
Important information about you is recorded in a patient record whenever you use a health or care service, such as visiting one of our dental or orthodontic practices. Gathering this information will assist you in receiving the best possible care and treatment.
The information acquired about you when you use these services can be used and shared with other organisations for purposes other than your personal care, such as to assist with:
This can only happen if there is a clear legal basis for using the data. All these applications contribute to your, your family’s, and future generations’ better health and care. Confidential patient information concerning your health and care is only used in this manner where permitted by law.
Typically, anonymised data is utilised for research and planning so that you cannot be identified, in which case your sensitive patient information is not required.
If you don’t want your sensitive patient information to be used in this way, you can opt out. You do not need to do anything if you are satisfied with this information use.
Visit www.nhs.uk/your-nhs-data-matters for additional information and to register your choice to opt out.
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