Patient Data Privacy Policy

The Town Dental dental practice takes great care to protect the personal data we hold for our
patients in line with the requirements of the General Data Protection Regulation (GDPR) and the
Data Protection Act 2018.
The purpose of collecting and storing personal data about our patients is to ensure we can:
   • Provide, appropriate, safe and effective dental care, treatment and advice for all our
patients.
   • Fulfil any contracts we hold in relation to their care.
   • For business administration of their care.

During the COVID-19 pandemic, we may also collect and store personal data about our patients
for the purposes of protecting public health and monitoring and managing the COVID-19
pandemic.

Personal data held for our patients


The personal data we process (processing includes obtaining the information, using it, storing it,
securing it, disclosing it, and destroying it) for our patients includes:
   • Name, address, date of birth.
   • Unique identification number.
   • Next of kin.
   • Email address.
   • Phone numbers.
   • GP contact details.
   • Occupation.
   • Medical history.
   • Dental care records.
   • Photographs.
   • Family group.
   • Payment plan details.
   • Financial information.
   • Credit cards receipts.
   • Correspondence.
   • Details of any complaints received.

We keep an inventory of personal data we hold on our patients and this is available for patients
on request. A list of personal information held is also included in our Privacy Notice that is given
to all patients.


National Opt-out Policy


At The Town dental sensitive personal information relating to our patients is only used to
provide dental care for the individual. It is never shared for research purposes or any non-
clinical need. The National Opt-out Policy introduced in March 2020 is therefore not operated at
our practice on this basis.
Should we change our policy to use information for a non-clinical purpose or a research project,
we would then introduce the National Opt-out policy.


Disclosure to third parties


The information we collect, and store will not be disclosed to anyone who does not need to see
it.
We will share our patients’ personal information with third parties when required by law or to
enable us to deliver a service to them or where we have another legitimate reason for doing so.
Third parties we may share patients’ personal information with may include:
   • Regulatory authorities such as the General Dental Council or the Care Quality
Commission
   • NHS Local Authorities
   • Dental payment plan administrators
   • Insurance companies
   • Loss assessors
   • Fraud prevention agencies
   • In the event of a possible sale of the practice at some time in the future.
We may also share personal information where we consider it to be in a patient’s best interest
or if we have reason to believe an individual may be at risk of harm or abuse.


Personal privacy rights


Under the GDPR and the Data Protection Act 2018, all individuals who have personal
information held about them have the following personal privacy rights:
   • Right to subject access.
   • Right to have inaccuracies deleted.
   • Right to have information erased.
   • Right to object to direct marketing.

  • Right to restrict the processing of their information, including automated decision-
making.
   • Right to data portability.


Patients who wish to have inaccuracies deleted or to have information erased must speak to the
dentist who provided or provides their care.


Legal basis for processing data held about patients
The GDPR requires us to state the legal basis upon which we process all personal data for our
patients and it requires us to inform our patients of the legal basis on which we process their
personal data. This is clearly stated in our privacy notice that is given to all patients.
The legal bases for recording individual types of data are recorded in our patient personal data
inventory. This is available for all patients to see on request.
The legal basis on which we process personal information for our private patients is consent.
The legal basis on which we process personal information for our payment plan patients is
consent and performing the contract between plan third party and the plan patient .

Automated decision making


All individuals who have personal data held about them have a right to object to their personal
data being subjected to automated decision making.
Patients will always be asked to give specific, informed, verifiable, opt in consent for any
processes involving automated decision making.


Consent


Dental surgery The Town Dental always obtains specific, unambiguous opt in consent from all
patients to whom we send direct marketing information. We obtain consent verbally in the
surgery and put a note to the patient’s profile .
For a new patient, we obtain consent for these things when the patient first attends the
practice. For an existing patient, we ask the patient for consent when they attend for their recall
appointment or for a treatment appointment. We refresh this consent annually when the
patient completes a new medical history proforma.

Withdrawal of consent


Patients who have given their opt in consent have a right to withdraw their consent at any time.
Patients are advised of their right to withdraw their consent for anything they wish to withdraw
from in our privacy notice.


Consent during the COVID-19 pandemic


The rules on processing and sharing information during the COVID-19 pandemic have been
relaxed to allow healthcare providers to protect public health and manage the spread of the
virus.
The town dental may need to contact our patients, their families or third-party organisations
regarding patients’ appointments, medical histories, and treatment. Where possible, we will
obtain prior consent to process and share this information.
Where patients have not previously consented to or have withdrawn their consent for us to
contact or share or process their data, we will assess whether the need for processing is
proportionate and necessary in relation to the risk to the individual and/or the public if the
information is not shared.


Retention period


This practice retains dental records and orthodontic study models while the patient is a patient
of the practice and, after they cease to be a patient, for at least eleven years, or for children
until age 25, whichever is the longer.


Complaints


All individuals who have personal data held about them have a right to complain. All complaints
concerning personal data should be made in person or in writing to practice principal/practice
manager . All complaints will be dealt with in line with the practice complaints policy and
procedures.


Transferring personal data outside the EU

This practice sends any necessary laboratory work outside of the EU. Laboratory work sent
outside the EU will be labelled with the patient’s unique identifying number rather than the
patient’s name. A record of the unique identifying number will be held at the practice