Scope
This document refers to personal data, which is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain.
The General Data Protection Regulation (GDPR) which is EU wide and far more extensive than its predecessor the Data Protection Act, along with the Privacy and Electronic Communications Regulations (PECR), seek to protect and enhance the rights of EU data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU and its storage within the EEA.
1- Swords Osteopaths based at 18 Bunbury Gate Crescent, Swords which hereafter for the purposes of this Privacy Notice will be referred to as the Osteopaths, is pleased to provide the following information:
2 – Who we are
The Osteopaths diagnose and treat health conditions. The practice may also provide other treatments, about which our staff will be pleased to provide more details.
3 – Personal Data
- a) For the purposes of providing treatment, Osteopaths may require detailed medical information. We will only collect what is relevant and necessary for your treatment. When you visit our practice, we will make notes which may include details concerning your medication, treatment and other issues affecting your health. This data is always held securely, is not shared with anyone not involved in your treatment, although for data storage purposes it may be handled by pre-vetted staff who have all signed an integrity and confidentiality agreement. To be able to process your personal data it is a condition of any treatment that you give your explicit consent to allow Osteopaths to document and process your personal medical data. Contact details provided by you such as telephone numbers, email addresses, postal addresses may be used to remind you of future appointments and provide reports or other information concerning your treatment.
- b) For marketing purposes, the Osteopaths may also use the contact details provided by you to respond to your enquiries, including making telephone contact and emailing information to you which the practice believes may be of interest to you.
- c) In making initial contact with the practice you consent to Osteopaths maintaining a marketing dialogue with you until you either opt out (which you can do at any time) or we decide to desist in promoting our services. Osteopaths may occasionally also act on behalf of its patients in the capacity of data processor, when we may promote other practitioners based at our premises, who may not be employed by us. Osteopaths do not broker your data and you can ask to be removed from our marketing database by emailing or phoning the practice using the contact details provided at the end of this Privacy Notice.
- d) Some basic personal data may be collected about you from the marketing forms and surveys you complete, from records of our correspondence and phone calls and details of your visits to our website, including but not limited to, personally identifying information like Internet Protocol (IP) addresses.
- e) Osteopaths’ website uses cookies, which is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. WordPress.org uses cookies to help Osteopaths to identify and track visitors and their website access preferences. Osteopaths’ website visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using Osteopaths’ website.
- f) Osteopaths will only collect the information needed so that we can provide you with the services you require, the business does not sell or broker your data.
4 – Legal basis for processing any personal data
To meet our contractual obligations obtained from explicit Patient Consent and legitimate interest to respond to enquiries concerning the services provided.
5 – Legitimate interests pursued by Osteopaths
To promote treatments for patients with all types of health problems indicated for osteopathic care.
6 – Consent
Through agreeing to this privacy notice you are consenting to Osteopaths processing your personal data for the purposes outlined. You can withdraw consent at any time by using the postal, email address or telephone number provided at the end of this Privacy Notice.
7 – Disclosure
Osteopaths will keep your personal information safe and secure, only staff engaged in providing your treatment will have access to your patient records, although our administration team will have access to your contact details so that they can make appointments and manage your account. Osteopaths will not disclose your Personal Information unless compelled to, in order to meet legal obligations, regulations or valid governmental requests. The practice may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of its staff.
8 – Retention Policy
Osteopaths will process personal data during the duration of any treatment and will continue to store only the personal data needed for eight years after the contract has expired to meet any legal obligations. After eight years all personal data will be deleted, unless basic information needs to be retained by us to meet our future obligations to you, such as erasure details. Records concerning minors who have received treatment will be retained until the child has reached the age of 25.
9 – Data storage
All Data is held in republic of Ireland. Osteopaths do not store personal data outside the EEA.
10 – Your rights as a data subject
At any point whilst Osteopaths are in possession of, or processing your personal data, all data subjects have the following rights:
- Right of access – you have the right to request a copy of the information that we hold about you.
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
- Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.
- Right of portability – you have the right to have the data we hold about you transferred to another organisation.
- Right to object – you have the right to object to certain types of processing such as direct marketing.
- Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.
In the event that Osteopaths refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge. At your request Osteopaths can confirm what information it holds about you and how it is processed.
11 – You can request the following information:
- Identity and the contact details of the person or organisation (Osteopaths) that has determined how and why to process your data.
- Contact details of the data protection officer, where applicable.
- The purpose of the processing as well as the legal basis for processing.
- If the processing is based on the legitimate interests of Osteopaths and information about these interests.
- The categories of personal data collected, stored and processed.
- Recipient(s) or categories of recipients that the data is/will be disclosed to.
- How long the data will be stored.
- Details of your rights to correct, erasure, restrict or object to such processing.
- Information about your right to withdraw consent at any time.
- How to lodge a complaint with the supervisory authority (ICO).
- Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
- The source of personal data if it wasn’t collected directly from you.
- Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
12 – To access what personal data is held, identification will be required
Osteopaths will accept the following forms of identification (ID) when information on your personal data is requested: a copy of your driving licence, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If Osteopaths is dissatisfied with the quality, further information may be sought before personal data can be released. All requests should be made to info@dataprotection.ie or by phoning 353 (0)761 104 800 or writing to us at the address further below.
13 Complaints
In the event that you wish to make a complaint about how your personal data is being processed by Osteopaths you have the right to complain to us. If you do not get a response within 30 days, you can complain to the ICO.
The details for each of these contacts are: Data protection commissioner, 21 Fitzwilliam Square, Dublin 2, Ireland D02 RD28 Email: info@dataprotection.ie
DOWNLOAD THE PATIENT EXPLICIT CONSENT DATA PROTECTION AGREEMENT
Cookies and This Website
This website collects and uses personal information for the following reasons:
Site visitation tracking
This site uses Google Analytics to track user interaction. We use this data to determine the number of people using our site, to better understand how they find and use our web pages and to see their journey through the website.
Although Google Analytics records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to us. Google Analytics also records your computer’s IP address which could be used to personally identify you but Google does not grant us access to this. Swords Osteopaths consider Google to be a third party data processor and their privacy policy can be viewed here. Google are based in the USA and are EU-U.S Privacy Shield compliant.
Google Analytics makes use of cookies, details of which can be found on Google’s developer guides.
Disabling cookies on your internet browser will stop Google Analytics from tracking any part of your visit to pages within this website.
Cookies used by Google Analytics include: utma / utmb / utmc / utmt / utmz / ga / gat / gid
Contact forms and email links
Should you choose to contact us using the contact forms on the Swords Osteopaths Website, none of the data that you supply will be stored by this website or passed to third parties. Instead, the data will be collated into an email and sent to us over the Simple Mail Transfer Protocol (SMTP).
WordPress
This site uses WordPress as the content management system to run the site. WordPress sets cookies which are known as “Functional Cookies”, meaning they are essential to the running of the site but do not collect any personal information. Cookies used by WordPress include;
wordpress_logged_in* Checks whether or not the current visitor is a logged in WordPress.com user.
wp-settings-{user_id} Persists a user’s wp-admin configuration.
wp_sharing_{id} Tracks whether or not a user has already performed an action.
Types of Cookies
Strictly Necessary: These cookies are essential for websites on our services to perform their basic functions.
Functionality: These cookies are used to allow the general function of the website and end-user experience.
Security: We use these cookies to help identify and prevent potential security risks.
Analytics and Performance: Performance cookies collect information on how users interact with our websites, including what pages are visited most, as well as other analytical data. We use these details to improve how our websites function and to understand how users interact with them.
Third Party / Embedded Content: We make use of different third-party applications and services to enhance the experience of website visitors. These include social media platforms such as Facebook and Twitter (through the use of sharing buttons), or embedded content from Youtube and Vimeo. As a result, cookies may be set by these third parties and used by them to track your online activity. We have no direct control over the information that is collected by these cookies.
Embedded content from other websites
Articles on this site may include embedded content (such as YouTube videos). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.
This Websites Server
This website is hosted by Siteground within a UK data centre located in Chessington, South West London, and is run by Digital Realty.
All traffic (transferral of files) between this website and your browser is encrypted and delivered over HTTPS.
Data Breaches
Even though Swords Osteopaths do not store any personal information on our website database, we will report any unlawful data breach of this website’s database or the database(s) of any of our third party data processors to any and all relevant persons and authorities within 72 hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.
Changes To Our Privacy Policy
This privacy policy may change from time to time inline with legislation or industry developments. We will not explicitly inform our clients or website users of these changes. Instead, we recommend that you check this page occasionally for any policy changes.
Our Registered Office
18 Bunbury Gate Crescent, Swords, Co. Dublin, Ireland.
Telephone: 01 808 4977.
Registered Business Number in Ireland: 260740