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Policy Name: Data Protection

Statement of Intent:

We fully endorse and adhere to the principles of the General Data Protection Regulation (GDPR).

This policy applies to the processing of personal data in manual and electronic records kept by us in connection with our human resources function as described below. It also covers our response to any data breach and other rights under the GDPR.

This policy applies to the personal data of patients, job applicants, existing and former employees, workers and self-employed contractors.

Achieving good governance by:  

-Giving careful consideration on how information/data is handled and ensure that any information that is produced or given to a third party is not in breach of General Data Protection Regulation (2018).

-Providing non-confidential information on the practice and its services through the practice website and practice leaflets.

– Establishing and maintaining a policy to ensure compliance with the Freedom of Information Act.

-Enable patients to request access to their medical records.

-Displaying our statement on confidentiality & freedom of information with regards to how it affects patients on our website and included in new patient registration pack.

-Recognising where there is a genuine need to share patient information with other health organisations and doing so in a controlled manner consistent with the interests of the patient.

-Securely maintaining accurate, complete and detailed records in respect of each person using the service.

-Keeping records relating the employment of staff.

-Keeping records of the overall management of the regulated activities.

-Under GDPR, all personal data obtained and held by us must be processed according to a set of core principles. In accordance with these principles, we will ensure that:

  1. processing will be fair, lawful and transparent
  2. data be collected for specific, explicit, and legitimate purposes
  3. data collected will be adequate, relevant and limited to what is necessary for the purposes of processing
  4. data will be kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without delay
  5. data is not kept for longer than is necessary for its given purpose
  6. data will be processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures
  7. we will comply with the relevant GDPR procedures for international transferring of personal data

Types of data held on employees

We keep several categories of personal data on our employees in order to carry out effective and efficient processes. We keep this data in a personnel file relating to each employee and we also hold the data within our computer systems, for example, our holiday booking system.

Specifically, we hold the following types of data:

  1. personal details such as name, address, phone numbers
  2. information gathered via the recruitment process such as that entered into a CV or included in a CV cover letter, references from former employers, details on your education and employment history etc.
  3. details relating to pay administration such as National Insurance numbers, bank account details and tax codes
  4. medical or health information
  5. information relating to your employment with us, including a) job title and job description b) your salary and your wider terms and conditions of employment
  6. details of formal and informal proceedings involving you such as letters of concern, disciplinary and grievance proceedings, your annual leave records, appraisal and performance information
  7. internal and external training modules undertaken

All the above information is required for our processing activities. More information on those processing activities are included in our privacy notice for employees, which is available from your manager.

Employee rights 

You have the following rights in relation to the personal data we hold on you:

  1. the right to be informed about the data we hold on you and what we do with it.
  2. the right of access to the data we hold on you. More information on this can be found in the section headed “Access to Data” below and in our separate policy on Subject Access Requests”.
  3. the right for any inaccuracies in the data we hold on you, however they come to light, to be corrected. This is also known as ‘rectification’.
  4. the right to have data deleted in certain circumstances. This is also known as ‘erasure’.
  5. the right to restrict the processing of the data.
  6. the right to transfer the data we hold on you to another party. This is also known as ‘portability’.
  7. the right to object to the inclusion of any information.
  8. the right to regulate any automated decision-making and profiling of personal data.

 More information can be found on each of these rights in our separate policy on employee rights under GDPR

Types of data held on patients

In order to provide patients with a high standard of dental care and attention, we need to hold some personal information.  This personal data comprises of:

  • past and current medical and dental condition; personal details such as age, NI number, address, telephone number and your general medical practitioner
  • radiographs, clinical photographs and study models
  • information about the treatment that we have provided or propose to provide and its cost
  • notes of conversations/incidents that might occur for which a record needs to be kept
  • records of consent to treatment
  • any correspondence relating to you with other health care professionals, for example in the hospital or community services.

 We need to keep comprehensive and accurate personal data about our patients in order to provide them with safe and appropriate dental care.  We also need to process personal data about them in order to provide care under NHS arrangements and to ensure the proper management and administration of the NHS. We will process personal data that we hold about patients in the following way:

We will retain dental records while they are a practice patient and after they cease to be a patient, for at least eleven years or for children until age 25, whichever is the longer. Personal data about patients is held in the practice’s computer system.  The information is not accessible to the public and only authorised members of staff have access to it via password entry.  Our computer system has secure audit trails and we back up information routinely. Archived paper records are stored within locked fireproof metal filing cabinets within the building. In order to provide proper and safe dental care, we may need to disclose personal information about patients to:

  • general medical practitioner
  • the hospital or community dental services
  • other health professionals caring for them
  • NHS payment authorities
  • the Inland Revenue
  • the Benefits Agency, where patients are claiming exemption or remission from NHS charges
  • Private dental schemes of which patients are a member.

Disclosure will take place on a ‘need-to-know’ basis, so that only those individuals/organisations who need to know in order to provide care to patients and for the proper administration of Government (whose personnel are covered by strict confidentiality rules) will be given the information.  Only that information that the recipient needs to know will be disclosed. In very limited circumstances or when required by law or a court order, personal data may have to be disclosed to a third party not connected with a patient’s health care. In all other situations, disclosure that is not covered by this Code of Practice will only occur when we have patient’s specific consent.  Where possible patients will be informed of these requests for disclosure.

Patients have the right of access to the data that we hold about them and to receive a copy.  Access may be obtained by making a request in writing with proof of identity. We will provide a copy of the record within 28 days of receipt of the request and an explanation of the record should you require it.

If patients do not wish personal data that we hold about them to be disclosed or used in the way that is described in this Code of Practice, they must discuss the matter with the dentist. Patients have the right to object, but this may affect our ability to provide them with dental care.

In order to protect the personal data of relevant individuals, those within our business who must process data as part of their role have been made aware of our policies on data protection.

We have also appointed employees with responsibility for reviewing and auditing our data protection systems. Namely, the practice manager Natalie Morgan


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