1. This is a notice to inform you of our policy about all information that we record about you. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.
2. We regret that if there are one or more points below with which you are not happy, your only recourse is to leave our website immediately.
3. We take seriously the protection of your privacy and confidentiality. We understand that all visitors to our website are entitled to know that their personal data will not be used for any purpose unintended by them and will not accidentally fall into the hands of a third party.
4. We undertake to preserve the confidentiality of all information you provide to us and hope that you reciprocate.
5. Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).
6. The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. We do this now, by requesting that you read the information provided at knowyourprivacyrights.org
7. Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.
The bases on which we process information about you
The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.
If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.
If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.
TLC Medical Centre LLP (operating as The Lawrence Clinic & The Yorkshire Skin Hospital) understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our patients and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
1. Information About Us
TLC Medical Centre LLP (operating as The Lawrence Clinic & The Yorkshire Skin Hospital)
TLC Medical Centre is a Limited Liability Partnership registered in the UK under company number OC326438
Registered address: The Lawrence Clinic, 4-6 Greenside, LS28 8PU
Data Protection Officer: Mr Robert Jackson
Email address: firstname.lastname@example.org
Telephone number:0113 2900310.
Postal Address: The Lawrence Clinic, 4-6 Greenside, LS28 8PU
We are regulated by: The Care Quality Commission
CQC National Customer Service Centre
Newcastle upon Tyne
Telephone: 03000 616161
2. What Does This Notice Cover?
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
3. What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in Part 5, below.
4. What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
11. The right to be informed about or collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
12. The right to access the personal data we hold about you. Part 10 will tell you how to do this.
13. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
14. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we Please contact us using the details in Part 11 to find out more.
15. The right to restrict (i.e. prevent) the processing of your personal data.
16. The right to object to us using your personal data for a particular purpose or purposes.
17. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
18. Rights relating to automated decision-making and profiling. We do not use your personal data in this way
19. For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
5. What Personal Data Do You Collect?
We may collect some or all of the following personal data (this may vary according to your relationship with us):
Date of birth;
6. How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes:
Supplying our services to you. Your personal details are required in order for us to enter into a contract with you.
Communicating with you. This may include responding to emails or calls from you.
Supplying you with information by email AND/OR post that you have opted-in to (you may unsubscribe or opt-out at any time by emailing the clinic on:
email@example.com with the message ‘opt out marketing’
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email AND/OR telephone AND/OR text message AND/OR post with information, news, and offers on our products AND/OR services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out – as detailed above.
We do not use automated systems for carrying out certain kinds of decision-making AND/OR profiling.
7. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
For adults: 8 years after the last dated treatment episode
For Children (under 18): 8 years after 18th birthday OR until the age of 25
Registration form data:
Indefinitely on the secure Private Practice Software platform using external secure servers, unless:
Patient opts out as outlined above.
8.How and Where Do You Store or Transfer My Personal Data?
We will only store or transfer your personal data in the UK. This means that it will be fully protected under the GDPR.
9. Do You Share My Personal Data?
We will not share any of your personal data with any third parties for any purposes, subject to one important exception.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
10. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 30 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
11. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details for the attention of Mr Robert Jackson:
Email address: firstname.lastname@example.org.
Telephone number: 0113 2900310.
Postal Address: The Lawrence Clinic, 4-6 Greenside, Pudsey. LS28 8PU.
12. Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection. In this case this privacy notice will be updated accordingly.
13. Complaints regarding content on our website
If you complain about any of the content on our website, we shall investigate your complaint.
If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate.
Free speech is a fundamental right, so we have to make a judgment as to whose right will be obstructed: yours, or that of the person who posted the content that offends you.
If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.
13. Information relating to your method of payment
At the point of payment, you are transferred to a secure page on the website PayPal or if paying by credit/debit card payment is taken via Stripe payment gateway. No payment details are kept on our website or servers. All payment data is fully secure and safe and processed through stripe who is fully PCI compliant.
14. Sending a message to our support team
When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need.
We record your request and our reply in order to increase the efficiency of our business
We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.
Use of information we collect through automated systems when you visit our website
Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.
Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.
Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.
to track how you use our website
to record whether you have seen specific messages we display on our website
to keep you signed in our site
to record your answers to surveys and questionnaires on our site while you complete them
to record the conversation thread during a live chat with our support team
16. Personal identifiers from your browsing activity
Requests by your web browser to our servers for web pages and other content on our website are recorded.
We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.
We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.
If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed into our website.
17. Our use of re-marketing
Re-marketing involves placing a cookie on your computer when you browse our website in order to be able to serve to you an advert for our products or services when you visit some other website.
Disclosure and sharing of your information
18. Information we obtain from third parties
Although we do not disclose your personal information to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal information from third parties whose services we use.
No such information is personally identifiable to you.
19. Third party advertising on our website
Third parties may advertise on our website. In doing so, those parties, their agents or other companies working for them may use technology that automatically collects information about you when their advertisement is displayed on our website.
We do not have control over these technologies or the data that these parties obtain. Accordingly, this privacy notice does not cover the information practices of these third parties.
20. Credit reference
To assist in combating fraud, we share information with credit reference agencies, so far as it relates to clients or customers who instruct their credit card issuer to cancel payment to us without having first provided an acceptable reason to us and given us the opportunity to refund their money.
21. Data may be processed outside the European Union
Our website is hosted in the United Kingdom
We may also use outsourced services in countries outside the European Union from time to time in other aspects of our business.
Accordingly, data obtained within the UK or any other country could be processed outside the European Union.
Access to your own information
22. Access to your personal information
At any time you may review or update personally identifiable information that we hold about you, by signing in to your account on our website.
To obtain a copy of any information that is not provided on our website you may send us a request at email@example.com.
After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.
23. Removal of your information
If you wish us to remove personally identifiable information from our website, you may contact us at firstname.lastname@example.org.
This may limit the service we can provide to you.
24. Verification of your information
When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
25. Use of site by children
We do not sell products or provide services for purchase by children, nor do we market to children.
If you are under 18, you may use our website only with consent from a parent or guardian
26. Encryption of data sent between us
We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.
Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.
27. How you can complain
If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office. This can be done at https://ico.org.uk/concerns/
28. Retention period for personal data
Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:
to provide you with the services you have requested;
to comply with other law, including for the period demanded by our tax authorities;
to support a claim or defence in court.
29. Compliance with the law
However, ultimately it is your choice as to whether you wish to use our website.
We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.