Surrey Centre for Natural Health PRIVACY STATEMENT

We are a Data Controller under the terms of the Data Protection Act 2017 and the requirements of the EU General Data Protection Regulation.

PERSONAL & SENSITIVE DATA

The clinic holds personal and sensitive data in the following categories:

1. Patient clinical and health data and correspondence.
2. Staff employment data.

YOUR PERSONAL AND SENSITIVE DATA

Under data protection legislation, the data that organisations hold about you can be categorised as follows:

Personal Data: This is data related to an identifiable person or data that can be used to identify a distinct individual. Examples of personal data we collect and process include names, email addresses, location, telephone numbers, ID numbers and online identifiers.

Sensitive Personal Data: Sometimes referred to as "Special Category Data", this is data that is deemed to be more sensitive than the above personal data. For example, medical records, genetics, biometric data, details of ethnicity, sexual orientation. We only use this data for the purposes of your treatment and to ensure you care and safety as a patient. We will usually ask for your consent to collect or process this data, though there may be instances where we are required or permitted to do so by applicable law (eg. To comply with public health requirements). We never use your sensitive personal data for marketing purposes.

WHY WE PROCESS PERSONAL AND SENSITIVE DATA (WHAT IS THE "PURPOSE")

“Process” means we obtain, store, update and archive data.

1. Patient data is held for the purpose of providing patients with appropriate, high quality, safe and effective health care and treatment.
2. Staff employment data is held in accordance with Employment, Taxation and Pensions law.

HOW WE USE YOUR PERSONAL AND SENSITIVE DATA

1. To contact you regarding your enquiry – we have to collect and process your data in order to fulfil your request for further information or to book an appointment.
2. To provide you with further information about the subject of your enquiry so you understand your options and can make an informed decision.
3. To remind you by email to book subsequent appointments for a treatment you have previously had which requires ongoing review.
4. With your consent, we will send you special offers and news via email – to keep you up to date with our promotions.
5. To tailor the content of our communications – to make it more relevant to you.
6. To contact you regarding your appointments and treatments – we want to make sure you don’t miss your appointments.
7. To make sure we’re speaking to the right person – to help prevent and detect fraud.
8. To issue invoices and receipts
9. To provide customer service and support

WHAT IS THE LAWFUL BASIS FOR PROCESSING PERSONAL DATA?

1. We hold patients' data because it is in our Legitimate Interest to do so. Without holding the data we cannot work effectively.
2. We hold staff employment data because it is a Legal Obligation for us to do so.

WHO MIGHT WE SHARE YOUR DATA WITH?

We can only share data if it is done securely and it is necessary to do so.

1. Patient data may be shared with other healthcare professionals who need to be involved in your care (for example if we refer you to a specialist or need laboratory work undertaken). [Patient data may also be stored for back-up purposes with our computer software suppliers] [who may also store it securely]
2. Employment data will be shared with government agencies such as HMRC.

We do not sell, trade, or rent personal identification information to others.

PRIVACY POLICY in relation to our WEBSITE

This part of the Privacy Policy covers our treatment of information that we gather when you are accessing or using our Website or when you contact us in any manner. We gather various types of information, including information that identifies you as an individual ("Personal Information") from our users, as explained in more detail below.

What information does Surrey Centre for Natural Health Collect?

Information You Provide to Us:

We may collect any Personal Information that you choose to send to us or provide to us, for example, if you contact us via our online form or by email. If you contact us through the Website, we will keep a record of our correspondence.

Information We Automatically Collect:

When you visit the Website, we collect certain information related to your device, such as your device's IP address, referring website, what pages your device visited, and the time that your device visited our Website. Information collected by cookies and other similar technologies – we use various technologies to collect information which may include saving cookies to users' computers.

For further information, please see the section below headed "Cookies and other Tracking Technologies" and / or read our Cookie Policy.

How do we use the information?

We will use the information we collect via our Websites:

• To administer our Website, our events and for internal operations, including troubleshooting, data analysis, testing, statistical and survey purposes;
• To improve our Website to ensure that content is presented in the most effective manner for you and for your computer;
• Analyze customers' use of the Websites for trend monitoring, marketing and advertising purposes;
• As part of our efforts to keep our Website safe and secure.

We may also use the information you send to us via the Website to communicate with you via email and, possibly, other means, regarding products, services, offers, promotions and events we think may be of interest to you or to send you our newsletter, if this is in accordance with your marketing preferences. However, you will always be able to opt-out of such communications at any time (see the "Your Choices" section below).

How do we share and disclose information to third parties?

We do not rent or sell your Personal Information to anyone. We may share and disclose information (including Personal Information) about our customers in the following limited circumstances:

We may share your information with third party vendors, consultants and other service providers who we employ to perform tasks on our behalf. These companies include (for example) website analytics companies (e.g., Google Analytics).

Disclosures for National Security or Law Enforcement: Under certain circumstances, we may be required to disclose your Personal Information in response to valid requests by public authorities, including to meet national security or law enforcement requirements.

Is Personal Information about me secure?

We use appropriate technical, organizational and administrative security measures to protect any information we hold in our records from loss, misuse, and unauthorized access, disclosure, alteration and destruction. Unfortunately, no company or service can guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.

Cookies and other tracking technologies

Our Website uses cookies (small text files containing a string of alphanumeric characters that we put on your computer) and other similar tracking technologies (like web beacons, tags and scripts) to uniquely identify your browser and to gather information about how you interact with the Websites and Services. We use this information for the following purposes:

• Assisting you in navigation;
• Assisting with our promotional and marketing efforts to examine browsing behaviour.

Please consult our Cookie Policy for more information about the type of cookies and tracking technologies that we use on this Website and why, and how to accept and reject them.

We utilize Google Analytics, a web analysis service provided by Google, to better understand your use of our Websites and Services. Google Analytics collects information such as how often users visit the Websites, what pages they visit and what other sites they used prior to visiting. Google uses the data collected to track and examine the use of the Websites, to prepare reports on its activities and share them with other Google services. Google may use the data collected on the Websites to contextualize and personalize the ads of its own advertising network. Google's ability to use and share information collected by Google Analytics about your visits to the Websites is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

Google offers an opt-out mechanism for the web available here.

Your Privacy Rights

What choices do I have?

Cookies

You can accept or reject cookies by adjusting your web browser controls. Please consult our Cookie Policy for more information about our use of cookies and how to accept and reject them.

Marketing Communications

You can opt-out of receiving certain promotional or marketing communications from us at any time, by emailing us at info@surreycentrefornaturalhealth.com

How can I update and access my information (Exercise my Data Subject Rights)?

If you would like to access, review, update, rectify, and delete any Personal Information we hold about you, or exercise any other data subject right available to you under the EU General Data Protection Regulation (GDPR), you can contact us directly at info@surreycentrefornaturlhealth.com.

Please note that we may still use any aggregated and de-identified Personal Information that does not identify any individual, and may also retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

What if I have questions about this policy?

If you have any questions or concerns regarding our privacy policies, please send us a detailed message to info@surreycentrefornaturlhealth.com, and we will try to resolve your concerns.

Changes to this privacy policy

Surrey Centre for Natural Health has the discretion to update this privacy policy at any time. When we do, we will revise the updated date at the bottom of this page. We encourage Users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of modifications.

This document was last updated on May 23, 2018