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 The Practice
Ben Colyer BSc(Hons)Ost DPO, based at 68 Ancastle Green, Henley-on-Thames RG9 1TS, which hereafter for the purposes of this Privacy Notice will be referred to as the Osteopath, is pleased to provide the following information:
2 Who we are
The Osteopath diagnoses and treats health conditions. Treatments are carried out in accordance with the Institute of Osteopathy’s patient charter.
Our website address is: https://bencolyerosteopath.co.uk
3 Personal Data
For the purposes of providing treatment, the Osteopath may require detailed medical information. He will only collect what is relevant and necessary for your treatment. When you visit the practice, He 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. To be able to process your personal data it is a condition of any treatment that you give your explicit consent to allow the Osteopath 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 arrange appointments and provide reports or other information concerning your treatment. As part of the obligations of primary healthcare practitioners there may be circumstances related to your treatment, on-going care or medical diagnosis that will require the sharing of your medical records with other healthcare practitioners eg. GPs, consultants, surgeons and/or medical insurance companies. Where this is required the Osteopath will always inform you first unless he is under a legal obligation to comply. f) The Osteopath will only collect the information needed so that he can provide you with the services you require, and does not sell or broker your data. He does not use your contact details for marketing purposes.
4 Legal basis for processing any personal data
To meet the osteopath’s 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.
Through agreeing to this privacy notice you are consenting to the Osteopath 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.
The Osteopath will keep your personal information safe and secure, only the osteopath will have access to your patient records. The Osteopath 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
The Osteopath will keep your consultation/treatment records and any incidental personal data during the duration of your treatment with us. He will store your patient records and related personal data for eight years after your last treatment to meet our legal obligations. Records concerning minors who have received treatment will be kept until the child has reached the age of 25. After this time, he will keep these records in case you decide to return for further treatment, your records may be archived or we will delete them if requested to do so.
9 Data storage
All Data is held in the United Kingdom. Ben Colyer Osteopath does not store personal data outside the EEA.
10 Your rights as a data subject
At any point whilst the Osteopath is 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 he holds about you.
• Right of rectification – you have a right to correct data that he holds about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data he holds about you to be erased from his 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 he holds 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 the Osteopath refuses your request under rights of access, he will provide you with a reason as to why, which you have the right to legally challenge. At your request the Osteopath can confirm what information he 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 (Osteopath) 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 the Osteopath 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
The Osteopath 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 the Osteopath is dissatisfied with the quality, further information may be sought before personal data can be released. All requests should be made to firstname.lastname@example.org or by phoning 07799258883 or writing to us at the address further below.
In the event that you wish to make a complaint about how your personal data is being processed by The Osteopath you have the right to complain. If you do not get a response within 30 days, you can complain to the ICO.
The details for each of these contacts are:
Ben Colyer, 68 Ancastle Green, Henley-on-Thames RG9 1TS, Telephone: 07799 258883 or email
ICO , Wycliffe House, Water Lane, Wilmslow, SK9 5AF Telephone +44 (0) 303 123 1113 or email