PRIVACY POLICY

Privacy Notice

We have a legal duty to show you this notice under GDPR.
Body Logic Physiotherapy, Twickenham is committed to protecting and respecting your privacy. We understand that your personal data is entrusted to us and appreciate the importance of protecting and respecting your privacy. To this end we comply with GDPR 2018 law.

This Privacy Policy sets out the basis on which we collect and process personal data about you including our practices regarding the collection, use, storage and disclosure of personal data that we collect from you and/or hold about you, and your rights in relation to that data.

Please read the following carefully to understand how we process your personal data. By providing your personal data to us or by using our services, you are consenting to the practices as described or referred to in this Privacy Notice.

For the purpose of GDPR, the data controller is Body Logic Physiotherapy (Body Logic Twickenham Ltd registered at Companies House number 06211479) Unit A, 6A Staines Road, Twickenham, TW2 5AH
What personal data may we collect from you?
When we refer to personal data in this policy, we mean information that can or has the potential to identify you as an individual.

Accordingly, we may hold and use personal data about you as a customer, a patient or in any other capacity, for example when you complete a form, access our services or speak to us. Depending on what services you receive from us this may include sensitive personal data such as information relating to your health. We have a legal duty to process your clinical data to help us provide safe and effective treatment and to protect both parties in the event of legal action. We also process data for legitimate purposes e.g. to send text appointment confirmation or to inform previous patients of new treatments for chronic conditions, billing etc.
Personal data we collect from you may include the following:
• information that you give us when you become a customer or patient of ours such as name, address, contact details (including email address and phone number).
• details of referrals, quotes and other contact and correspondence we may have had with you
• details of services and/or treatment you have received from us or which have been received from a third party and referred on to us.
• information obtained from customer surveys.
• notes and reports about your health and any treatment and care you have received and/or need, including about clinic and hospital visits and medicines administered.
• patient feedback and treatment outcome information you provide.
• information about complaints and incidents.
• information you give us when you make a payment to us, such as financial or credit card information. We do not store these details electronically and destroy paper slips after 12 months.
• where you have named someone as your next of kin and provided us with personal data about that individual, it is your responsibility to ensure that that individual is aware of and accepts the terms of this Privacy Policy.
The data that we request from you may include sensitive personal data. This includes information that relates to the mental or physical health or racial or ethnic origin (which may include children’s data). By providing us with sensitive personal data, you give us your explicit consent to process this sensitive personal data for the purposes set out in this Privacy Notice.

When do we collect personal data about you?
We may collect personal data about you if you:
• visit one of our websites (cookies policy).
• register to be a customer or patient with us or book to receive any of our services or treatments.
• fill in a form or survey for us.
• contact us, for example by email, telephone or social media.
What personal data we may receive from third parties and other sources?
We may collect personal data about you from third parties such as:
• We carry out work on behalf of the NHS and for the continuity of your care we may be passed medical information usually in the form of a referral for the purposes of your treatment.
• Insurance providers will pass us personal data of patients who have commenced a claim and require medical treatment. This will normally be in the form of a referral and may consist of basic details e.g. full name, date of birth, address, contact number and email address and the type of treatment they require.

How do we use your personal data?
Your personal data will be kept confidential and secure and will, unless you agree otherwise, only be used for the purpose(s) for which it was collected and in accordance with this Privacy Policy, applicable Data Protection Laws, clinical records retention periods and clinical confidentiality guidelines.
Sensitive personal data related to your health will only be disclosed to those involved with your treatment or care, or in accordance with UK laws and guidelines of professional bodies or for clinical audits. Further details on how we use health related personal data are given below. We will only use your sensitive personal data for the purposes for which you have given us your explicit consent to use it. Please note that, although we have set out the purposes for which we may use your personal data below, we will not use your sensitive personal data for those purposes unless you have given us your explicit consent to do so.

We may use your personal data to:
• enable us to carry out our obligations to you arising from any contract entered into between you and us including relating to the provision by us of services or treatments to you and related matter such as, billing, accounting and audit, credit or other payment card verification and anti-fraud screening
• provide you with information, products or services that you request from us
• provide you with information about products or services we offer that we feel may interest you. Unless you have consented to receive marketing communications by electronic means from us, by ticking the relevant box on the form on which we collect your data, we will only contact you by electronic means (e-mail or SMS) with information about products and services similar to those which you previously purchased or enquired about from us.
• notify you about changes to our products or services.
• check the accuracy of information about you and the quality of your treatment or care, including auditing medical and billing information for insurance claims as well as part of any claims or litigation process
• support your doctor, nurse or other healthcare professional
• assess the quality and/or type of care you have received (including giving you the opportunity to complete customer satisfaction surveys) and any concerns or complaints you may raise, so that these can be properly investigated
• to conduct and analyze market research
• to ensure that content from any of our websites is presented in the most effective manner for you and for your computer.
• We do not share data outside the EU without your express permission.
• No automated decisions are made regarding your data.

The security of your personal data
We protect all personal data we hold about you by ensuring that we have appropriate organizational and technical security measures in place to prevent unauthorized access or unlawful processing of personal data and to prevent personal data being lost, destroyed or damaged. We conduct assessments to ensure the ongoing security of our information systems.

Any personal data you provide will be held for as long as is necessary having regard to the purpose for which it was collected and in accordance with all applicable UK laws. We have a legal duty to keep clinical records.
All information you provide to us is stored securely. Any payment transactions on our website will be processed securely by third party payment processors. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our website, you are responsible for keeping that password confidential. We ask you not to share a password with anyone.

The transmission of information via the internet cannot be guaranteed as completely secure. However, we ensure that any information transferred to our websites is via an encrypted connection. Once we have received your information, we will use strict procedures and security features for prevention of unauthorized access.
We may occasionally transfer personal information to you via email, or you may choose to transfer information to us via email. Email is not a secure method of information transmission; if you choose to send or receive such information via email, you do so at your own risk.

Disclosure of your personal data
In the usual course of our business we may disclose your personal data (to the extent necessary) to certain third-party organizations that we use to support the delivery of our services. This may include the following:
• business partners, suppliers and subcontractors for the performance of any contract we enter with you,
• organizations providing IT systems support and hosting in relation to the IT systems on which your information is stored,
• third party debt collectors for the purposes of debt collection,
• third party service providers for the purposes of storage of information and confidential destruction, third party marketing companies for sending marketing emails, subject to obtaining appropriate consent.
Where a third-party data processor is used, we ensure that they operate under contractual restrictions about confidentiality and security, in addition to their obligations under Data Protection Laws.
We may also disclose your personal data to third parties in the event that we sell or buy any business or assets or where we are required by law to do so.

Health information collected during provision of treatment or services
Sensitive personal data (including information relating to your health) will only be disclosed to third parties in accordance with this Privacy Policy. That includes third parties involved with your treatment or care, or in accordance with UK laws and guidelines of appropriate professional bodies. Where applicable, it may be disclosed to any person or organization who may be responsible for meeting your treatment expenses or their agents. It may also be provided to external service providers and regulatory bodies (unless you object) for the purpose of clinical audit to ensure the highest standards of care and record keeping are maintained.

Medical professionals working with us:
We share clinical information about you with our medical professionals as we think necessary for your treatment. Medical professionals working with us might be our employees, or they might be independent consultants in private practice. In the case of independent consultants, the consultant is the data controller of your personal data, either alone or jointly with us and will be required to maintain their own records in accordance with Data Protection Laws and applicable clinical confidential guidelines and retention periods. Where that is the case, we may refer you to that consultant to exercise your rights over your data. Our contracts with consultants require them to cooperate with those requests. In all circumstances, those individual consultants will only process your personal data for the purposes set out in this Privacy Notice or as otherwise notified to you.
External practitioners: If we refer you externally for treatment, we will share with the person or organisation that we refer you to, the clinical and administrative information we consider necessary for that referral. It will always be clear when we do this.

Your GP:
If the practitioners treating you believe it to be clinically advisable, we may also share information about your treatment with your GP. You can ask us not to do this, in which case we will respect that request if we are legally permitted to do so, but you should be aware that it can be potentially very dangerous and/or detrimental to your health to deny your GP full information about your medical history, and we strongly advise against it.

Your insurer:
We share with your medical insurer information about your treatment, its clinical necessity and its cost, only if they are paying for all or part of your treatment with us. We provide only the information to which they are entitled. If you raise a complaint or a claim we may be required to share personal data with your medical insurer for the purposes of investigating any complaint/claim.

The NHS:
If you are referred to us for treatment by the NHS, we will share the details of your treatment with the part of the NHS that referred you to us, as necessary to perform, process and report back on that treatment.
Medical regulators: We may be requested – and in some cases can be required – to share certain information (including personal data and sensitive personal data) about you and your care with medical regulators such as the Health Care Professions Council, for example if you make a complaint, or the conduct of a medical professional involved in your treatment is alleged to have fallen below the appropriate standards and the regulator wishes to investigate. We will ensure that we do so within the framework of the law and with due respect for your privacy.

In an emergency and if you are incapacitated, we may also process your personal data (including sensitive personal data) or make personal data available to third parties on the basis of protecting your ‘vital interest’ (i.e. your life or your health).
We will use your personal data in order to monitor the outcome of your treatment by us and any treatment associated with your care, including any NHS treatment.

Marketing
If you have consented to our processing your personal data for marketing purposes, in accordance with this Privacy Policy, we may send you information (via mail, email, phone or SMS) about our products and services which we consider may be of interest to you.
You have the right to ask us not to process your information in this way at any time. If you no longer wish to receive marketing information please email info@bodylogicphysio.co.uk

CCTV
Our premises are sometimes surveyed by a security camera for the purposes of security. Images and videos may be retained for a limited period. The camera is not in a treatment area. The data is stored on site.
Accessing and updating your information
The law gives you certain rights in respect of the personal data that we hold about you. In addition to your right to stop marketing, detailed above, below is a short overview of the most commonly-used rights. It is not an exhaustive statement of the law.
• You have the right to request a copy of your personal data in writing.
• You have the right to have the personal data we hold about you corrected if it is factually inaccurate. It is important to understand that this right does not extend to matters of opinion, such as medical diagnoses. If any of your personal data has changed, especially contact information such as: email address, postal address and phone number please let us know by emailing info@bodylogicphysio.co.uk so we can ensure your personal data is kept up to date.
• If you want to exercise your rights in respect of your personal data, the best way to do so is to contact us by email on info@bodylogicphysio.co.uk. In order to protect your privacy, we may ask you to prove your identity before we take any steps in response to such a request.
Changes to our Privacy Policy
We keep our Privacy Notice under regular review and as a result it may be amended from time to time without notice. As a result we encourage you to review this Privacy Policy regularly.

Contact
If you have any questions in relation to our privacy policy, please email us at info@bodylogicphysio.co.uk