What personal information do we collect?
In order to treat you, we will ask you to provide certain information. This includes:
Date of birth
To this, over time, we will add details of the conditions for which you have consulted us and the remedies and other therapies that we have prescribed or recommended.
How do we collect this personal information?
All the information collected is obtained directly from you. This is usually at the point of you getting in touch and booking an initial consultation. In order for us to treat you effectively we do need to obtain this information from you; the gathering and processing of this information is covered under the legal base of ‘legitimate interests’ and this term is defined within data protection regulation and law. All changes to this policy or the way in which your data will be processed will be discussed with you.
How do we use this personal information?
Lisa Strbac use your personal information to analyse the conditions for which you have consulted us and to prescribe remedies and other therapies.
Lisa Strbac will communicate with you by email, other digital methods, by telephone and by post.
With whom do we share your personal information?
Lisa Strbac will not disclose any personal information that we hold on you to any unrelated third party, except where required by law.
How long do we keep your personal information?
Your information will be kept for seven years after your last consultation. In the case of children, 7 years after their 18th Birthday. At that point, your file will be securely destroyed and any digital information will be erased from our computer systems.
How your information can be updated or corrected
To ensure that we have accurate and up-to-date information, you need to inform us of any changes you believe we should make to the personal information we hold. You can do this by contacting us by any of the methods previously described.
Under data protection legislation, you have the right to inspect the personal information we hold about you. You can make a request to do so by contacting us and we will endeavour to respond within 14 working days.
How do we store your personal information?
Our patient files are paper-based and are held securely within our consulting rooms. We take steps to protect your personal information against loss or theft, as well as unauthorised access, disclosure, copying, use, or modification.
Your email address, if you have one, is held securely on the servers of our email providers (we use gmail).
Changes to this policy
This policy may change from time to time. If Lisa Strbac makes any material changes, we will make you aware of them.
If you have any queries about this policy, need it in an alternative format, or have any complaints about my privacy practices, please contact us.
DATA PROTECTION POLICY
Why this policy exists
This data protection policy ensures that Lisa Strbac:
complies with data protection law and follows good practice
protects the rights of patients
how we store and processes patients’ data
protects itself from the risks of a data breach
Data protection principles
The General Data Protection Regulation identifies 8 data protection principles.
Principle 1 - Personal data shall be processed lawfully, fairly and in a transparent manner
Principle 2 - Personal data can only be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
Principle 3 - The collection of personal data must be adequate, relevant and limited to what is necessary compared to the purpose(s) data is collected for.
Principle 4 – Personal data held should be accurate and, where necessary, kept up to date. Every reasonable step must be taken to ensure that personal data that are inaccurate are erased or rectified without delay.
Principle 5 – Personal data which is kept in a form which permits identification of individuals shall not be kept for longer than is necessary.
Principle 6 - Personal data must be processed in accordance with the individuals’ rights.
Principle 7 - Personal data must be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
Principle 8 - Personal data cannot be transferred to a country or territory outside the European Union unless that country or territory ensures an adequate level of protection for the rights and freedoms of individuals in relation to the processing of personal data.
Certain of these principles are expanded upon in the sections that follow.
Lawful, fair and transparent data processing
Lisa Strbac requests personal information from patients and potential patients for the purpose of consulting with them and providing them with advice and guidance on homeopathic treatments. The forms used to request personal information may contain a privacy statement informing patients and potential patients why the information is being requested and what the information will be used for. Patients should be asked to provide consent for their data to be held and a record of this consent along with patient information will be securely held. Patients will be informed that they can, at any time, remove their consent and will be informed as to what to do should they wish to do so.
Processed for Specified, Explicit and Legitimate Purposes
Patients will be informed how their information will be used and Lisa Strbac will seek to ensure that patients’ information is not used inappropriately. Appropriate use of information provided by patients includes:
Communicating with patients in order to make, change or cancel consultations
Assessing the conditions and issues reported by patients and devising and prescribing relevant remedies and therapies.
Lisa Strbac will ensure that patients’ information is managed in such a way as to not infringe an individual’rights which include:
The right to be informed
The right of access
The right to rectification
The right to restrict processing
The right to data portability
The right to object.
Adequate, Relevant and Limited Data Processing
Lisa Strbac's patients will only be asked to provide information that is relevant to support consultations and prescription. This includes:
Date of birth
Where additional information may be required, this will be obtained with the specific consent of the patient who will be informed as to why this information is required and the purpose for which it will be used.
There may be occasional instances where a patient’s information needs to be shared with a third party due to an accident or incident involving statutory authorities. Where it is in the best interests of the patient or of Lisa Strbac, in these instances where Lisa Strbac has a substantiated concern then consent does not have to be sought from the individual.
Accuracy of Data and Keeping Data up to Date
Lisa Strbac has a responsibility to ensure that patients’ information is kept up to date. Patients will be required to let Lisa Strbac know if any of their personal information changes.
Accountability and Governance
Lisa Strbac is responsible for ensuring that her practice remains compliant with data protection requirements and can provide evidence that it has. For this purpose, those from whom data is required will be covered by the legal base of ‘legitimate interest’. Where data is to be shared, explicit consent will be obtained from the patient and this consent will be formally recorded. This will be completed prior to any action being taken.
Lisa Strbac has a responsibility to ensure that data is both securely held and processed. This includes:
using strong passwords for information held within computer systems
restricting access to computer and paper-based files
using password protection on laptops and PCs that contain or access personal information
using password protection or secure cloud systems
providing adequate virus-protection and firewall software to secure computer-based systems.
Subject Access Request
Lisa Strbac's patients are entitled to request access to the information that is held by them. The request needs to be received in the form of an email request to Lisa Strbac.
On receipt of the request, the request will be formally acknowledged and dealt with within 14 days unless there are exceptional circumstances as to why the request cannot be granted. Lisa Strbac will provide a written response detailing all information held on the individual. A record shall be kept of the date of the request and the date of the response.
Data Breach Notification
Were a data breach to occur, action shall be taken to minimise the harm. Lisa Strbac will inform any patients where she believes their personal information has been compromised. Where necessary, the Information Commissioner's Office will be notified.
If a patient contacts Lisa Strbac to say that they feel that there has been a breach by Lisa Strbac, they will ask the patient to provide an outline of their concerns. If the initial contact is by telephone, Lisa Strbac will ask the patient to follow this up with an email or a letter detailing their concern. The concern will then be investigated fully and a response made to the patient. Breach matters will be subject to a full investigation, records will be kept and all those involved notified of the outcome.
Policy review date: May 2022