Privacy Policy

The practice aims to meet the requirements of the Data Protection Act 2018, the General Data
Protection Regulation (GDPR], the guidelines on the Information Commissioner’s website as well as our
professional guidelines and requirements.
The data controller is the Christopher Barley, the information governance lead is Karen Rolfe
This Privacy Notice is available on the practice website at
privacynotice / at reception/ by email if you contact or by calling 01242 260009.
You will be asked to provide personal information when joining the practice. The purpose of processing
your personal data is to provide you with optimum dental health care and prevention.
The categories and examples of data we process are:
▪ Personal data for the provision of dental health care
▪ Personal data for the purposes of providing treatment plans, recall appointments, reminders or
▪ Personal data such as details of family members for the provision of health care to children or for
emergency contact details
▪ Personal data for the purposes of employed and self-employed team members employment and
engagement respectively
▪ Personal data for the purposes of [direct mail/email/text/other] to inform you of important
announcements or about new treatments or services
▪ Personal data - IP addresses so that we can understand our patients better and inform our
marketing approach as well as improve the web site experience
▪ Special category data including health records for the purposes of the delivery of health care and
meeting our legal obligations
▪ Special category data including health records
▪ Special category data to meet the requirements of the Equality Act 2010
▪ Special category data details of criminal record checks for employees and contracted team
We minimise the data that we keep, and do not keep it for longer than necessary.
We never pass your personal details to a third party unless we have a contract for them to process data
on our behalf and will otherwise keep it confidential. If we intend to refer a patient to another
practitioner or to secondary care such as a hospital we will gain the individual’s permission before the
referral is made and the personal data is shared. Your data will be shared with the NHS in England,
Scotland and Wales or the HSC in Northern Ireland if you are having NHS or HSC treatment.
▪ Personal data is stored in the [EU] whether in digital or hard copy format
▪ Personal data is obtained when a patient joins the practice, when a patient is referred to the
practice and when a patient subscribes to an email list / other.
For full details or where your data is stored, please ask to see Information Governance Procedures (M
GL50 3PE

We have established the following lawful bases for processing your data:
Our lawful bases for processing personal data:
▪ The legitimate interests of the dental practice
▪ Processing is necessary for the performance of a contract with the data subject or to take steps to
enter into a contract
▪ Consent of the data subject
▪ To comply with our legal obligation
Our lawful bases for processing special category data:
▪ Processing is necessary for health care purposes
▪ Processing necessary for identifying or keeping under review the existence or absence of equality
of opportunity or treatment between groups of people with the view to enabling such equality to
be promoted or maintained
▪ We obtain consent of the data subject to process criminal record checks
The reasons we process the data include:
▪ To maintain your contemporaneous clinical records
▪ To provide you with dental treatment, prevention and oral health advice
▪ To carry out financial transactions with you
▪ To send your personal data to the General Dental Council or other authority as required by law
▪ To communicate with you as and when required including appointment reminders, treatment
plans, estimates and other communications about your treatment or the practice
▪ To communicate with your next of kin in an emergency
▪ If a parent or carer to communicate with you about the person you parent or care for
▪ To refer you to other dentists or doctors and health professionals as required
▪ To obtain criminal record disclosures for team members
▪ For debt recovery
▪ To continually improve the care and service you receive from us
The personal data we process includes:
Your name, address, gender, date of birth, NHS number, medical history, dental history, family medical
history, family contact details, marital status financial details for processing payment, your doctor’s
details and details of treatment at the practice. We may process more sensitive special category data
including ethnicity, race, religion, or sexual orientation so that we can meet our obligations under the
Equality Act 2010, or for example to modify treatment to suit your religion and to meet NHS or HSC
The retention period for special data in patient records is a minimum of 10 years and may be longer for
complex records or to meet our legal requirements. The retention period for staff records is 6 years. The
retention periods for other personal data is 2 years after it was last processed. Details of retention
periods are available in the Record Retention (M 215) procedure available from the practice.
We obtain your personal details when you enquire about our care and service, when you join the
practice, when you subscribe to our newsletter or register online, when you complete a registration or
medical history form and when another practitioner refers you for treatment at our practice.
Occasionally patients are referred to us from other official sources such as NHS clinics or hospitals.
GL50 3PE

You have the following personal data rights:
▪ The right to be informed about the collection and use of your personal data
▪ The right of access – to have a free copy of your data that we have
▪ The right to rectification - to correct the data we have if it is inaccurate or incomplete
▪ The right to deletion of your personal data (clinical records must be retained for a certain time
▪ The right to restrict processing of your personal data
▪ The right to data portability – to have your data transferred to someone else
▪ The right to object to the processing of your personal data
▪ Rights in relation to automated decision making and profiling
Further details of these rights can be seen in our Information Governance Procedures (M 217C) or at the
Information Commissioner’s website. Here are some practical examples of your rights:
▪ If you are a patient of the practice you have the right to withdraw consent for important
notifications, newsletters, surveys or marketing. You can inform us to correct errors in your
personal details or withdraw consent from communication methods such as telephone, email or
text. You have the right to obtain a free copy of your patient records within one month
▪ If you are not a patient of the practice you have the right to withdraw consent for processing
personal data, to have a free copy of it within one month, to correct errors in it or to ask us to
delete it. You can also withdraw consent from communication methods such as telephone, email
or text
We have carried out a Privacy Impact Assessment (M 217Q) and you can request a copy from the details
below. The details of how we ensure security of personal data is in our Security Risk Assessment (M
217M) and Information Governance Procedures (M 217C).
Comments, suggestions and complaints
Please contact the IG Lead at the practice for a comment, suggestion or a complaint about your data
processing at, or 01242 260009 or by writing to or visiting the
practice at The Regency House Dental Practice, 4 Crescent Terrace, Cheltenham, Glos, GL50 3PE. We take
complaints very seriously.
If you are unhappy with our response or if you need any advice you should contact the Information
Commissioner’s Office (ICO). Their telephone number is 0303 123 1113, you can also chat online with an
advisor. The ICO can investigate your claim and take action against anyone who’s misused personal data.
You can also visit their website for information on how to make a data protection complaint.
Related practice procedures
You can also use these contact details to request copies of the following practice policies or procedures:
▪ Data Protection and Information Security Policy (M 233-DPT), Consent Policy (M 233-CNS)
▪ Privacy Impact Assessment (M 217Q), Information Governance Procedures (M 217C), Record
Retention (M 215)
If you have an enquiry or a request please contact the Information Governance Lead
Karen Rolfe
The Regency House Dental Practice, 4 Crescent Terrace Cheltenham Glos GL50 3PE
Phone: 01242 260009
Thank you.
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