LMSC is committed to complying with the Data Protection Act 1998, the General Data Protection Regulation (GDPR), General Medical Council (GMC), National Health Service (NHS) and other standards. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.
LMSC only keeps relevant information about patients to provide them with safe and appropriate health care. LMSC may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from 13.05.2018.
The person responsible for Data Protection is: Mr. Peter Sweeney, Information Governance Lead, who you can reach via – F.A.O. Peter Sweeney, 27 Harley Street, London, W1G 9QP (or by email – email@example.com)
We may collect the following information:
- Contact information including email address
- Demographic information such as postcode, preferences and interests
- Other information relevant to customer surveys and/or offers
- Information relating to health
We require this information to understand your health needs and provide you with a better service, and in particular for the following reasons:
- Internal record keeping.
- We may use the information to improve our products and services.
To facilitate patients’ health care, the personal information you provide may be disclosed to a doctor, health care professional, third party involved in delivering our services, hospital, NHS authorities, HMRC, or private insurance schemes of which the patient is a member. In all cases only relevant information is shared. In very limited cases, such as for identification purposes, or if required by law, information may have to be shared with a party not involved in the patient’s health care. In all other cases, information is never disclosed to such a third party without the patient’s written authority.
Hard copy and computerised records are stored, reviewed and updated securely and confidentially. Records are securely destroyed when no longer required. Confidential information is only seen by personnel who need to see it and the team are trained on our policies and procedures to keep patient information confidential.
All confidential information is sent via secure methods. Electronic communications and stored data are encrypted. All computerised clinical records are backed up and encrypted copies are kept off-site. No information or comments about patients are posted on social networking or blogging sites.
London Musculoskeletal Centre (LMSC) has appropriate procedures to ensure personal data breaches are detected, reported and investigated effectively, including procedures to assess and then report any breaches to the Information Commissioner’s Office (ICO) where the individual is likely to suffer some form of damage, e.g. through identity theft or confidentiality breach.
LMSC will report serious data breaches to the ICO within 72 hours of becoming aware of the essential facts. The practice will keep a log of all personal data breaches and record the basic facts, effects of the breach and remedial action taken.
Patients and team members can have access to view the original of their records free of charge. Copies of patient or team member records are provided following a written request to the Practice Manager: Mr Peter Sweeney, 27 Harley Street, London, W1G 9QP (or by email to firstname.lastname@example.org). The requested copies will be provided within 1 month on receipt of request.
A patient may challenge information held on record and, following investigation, should the information be inaccurate London Musculoskeletal Centre (LMSC) will correct the records and inform the employee or patient of the change in writing.
When the request for information is about the personal data of a child, LMSC will consider if the child is mature enough to understand their rights. If they do, then LMSC will consider responding directly to the child rather than the parent. If it is decided that the child is not mature enough to understand their rights, and there is some doubt about parental responsibility, proof of identity and evidence of parental responsibility will be requested. LMSC will update its privacy notice to ensure its gives information in a language that can be understood by a child on any processing of children’s personal data.
When the practice receives a third-party request for information on someone else’s behalf (e.g. from a solicitor) evidence of their permission will be requested, this could be a written authority to make a request or a power of attorney.
When LMSC receives a third-party request for information for a patient who lacks the mental capacity to manage their affairs LMSC will ask to see evidence of a Lasting Power of Attorney or the evidence of appointment by:
- The Court of Protection in England & Wales;
- The Sheriff Court in Scotland; and
- The High Court (Office of Care and Protection) in Northern Ireland
This policy should be read in conjunction with the Confidentiality Policy, and the Information Governance Procedure.
When we obtain consent for marketing such as email marketing, this consent is specific, granular, clear, prominent, opt-in, documented and easily withdrawn. We have a system used to record consent and implement appropriate mechanisms in order to ensure an effective audit trail.
If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing to or emailing us at email@example.com
Our procedures for deleting personal data in electronic or paper format are detailed in the Record Management Policy. If not related to necessary clinical or employment records we will delete personal data.
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
Our administrative system is cloud-based and makes use of geographically distributed data-centres. We may transfer your data to one of these databases outside your country of domicile, including countries which may not require an adequate level of protection for your Personal Data compared with that provided in the UK or EU. In such cases we have implemented and maintain technical and organisational measures to protect your information against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. Our Security Measures include encryption and contractual enforcement of ongoing confidentiality, integrity, availability and resilience of our systems and services.
Processing is necessary for the performance of our care for patients. Our lawful basis for processing data is:
- “6(1)(b) – Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;”
- “6(1)(c) – Processing is necessary for compliance with a legal obligation to which the controller is subject;”
- “6(1)(e) – Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;”
- The health care data we process is called special category data, our legal basis for processing it is:
- “9(2)(h) – Processing is necessary for the purposes of preventative or occupational medicine, for assessing the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or management of health or social care systems and services on the basis of Union or Member State law or a contract with a health professional.”
If we process data for marketing purposes we will only do so with explicit consent of the individual. Our lawful basis for this is:
- “6(1)(a) the data subject has given consent to the processing of his or her personal data for one or more specific purposes;”