GDPR 2018 PRIVACY NOTICE
This notice is to explain why I collect your personal data, and what I
do with it, and to ensure I am working in accordance with the revised
Data Protection Act 2018. Terms from the Act are indicated in bold
When you supply your personal details to me, when we communicate by
email, and when I take notes in the clinic, this information is stored
and processed for several reasons in line with the Data Protection Act
1. I need to collect personal information about you and your health in
order to provide you with the best possible treatment. I use your
presenting complaint and symptoms reported by you, along with any
relevant medical and family history, for the purposes of making a full
traditional diagnosis, formulating treatment strategy and treatment
planning. Your requesting treatment and our agreement to provide that
care constitutes in law an (unwritten) contract. You can, of course,
refuse to provide the information, but if you were to do that I would
not be able to provide treatment.
2. I have a 'Legitimate Interest' in collecting that information,
because without it I couldn't practice acupuncture effectively and
3. I keep records of your contact information because I think that it
is important that I can contact you in order to confirm your
appointments with me or to update you on matters related to your
medical care. I am unable to send or receive encrypted emails so you
should be aware that any emails I send or receive may not be protected
in transit. This includes prospective or current patients telling me
about their medical conditions by email. Any emails sent to me,
including file attachments, are monitored for viruses or malicious
software. Please be aware that you have a responsibility to ensure
that any email you send me is within the bounds of the law. This again
constitutes a 'legitimate interest', but this time it is your
4. I may use your date of birth to help identify patients with the
same name, so as to avoid mistakes being made as to safe and
appropriate treatment, for identification purposes if referring a
patient to another health practitioner, and for identification
purposes if writing to a registered medical practitioner so that they
correctly identify the patient.
5. I use your GP's name and address in the event that we need to
contact your GP including in an emergency, and because it is a
mandatory requirement in the British Acupuncture Code of Professional
6. I keep a record of any treatment given and details of progress of
your case, treatment reviews, information and advice, so as to enable
me to: review the full traditional diagnosis, treatment strategy and
planning; make an informed referral to any other health professional;
and to secure evidence in the event of criminal proceedings, civil
litigation, an insurance claim or complaint.
7. I keep accident records for any patients, visitors or staff who are
involved in accidents at my clinic in accordance with UK Health and
Safety legislation including the Reporting of Injuries, Diseases and
Dangerous Occurrences Regulations (RIDDOR), so as to comply with the
law and to secure evidence in the event of criminal proceedings, civil
litigation, an insurance claim or complaint.
8. I report any adverse incident occurrence to the British Acupuncture
Council, to help the BAcC develop its safe practice guidelines, as
well as to provide research data and information for the BAcC's
insurers and other interested parties.
9. I keep a permanent attendance register which records all
appointments for patients attending my clinic. This record of
attendance is required both for tax purposes and to secure potential
evidence in the event of a criminal prosecution, civil litigation,
insurance claim or complaint to my regulatory body, the British
10. Provided I have your consent (and this only needs to be verbal
consent), I may occasionally send you individualised health
information by email in the form of articles or advice. I will not
send out generalised leaflets or advertisements. You may withdraw this
consent at any time - just let me know by any convenient method.
I have a legal obligation to the British Acupuncture Council and the
GDPR to retain your records for 8 years after your most recent
appointment (or after you have reached age 25, if this is longer).
After this period you can ask me to delete your records if you wish.
Your clinical records are stored on paper, in individual paper files,
and in a secure cabinet in my home.
Your emails are stored within my firstname.lastname@example.org account, which is password protected.
I will never share your data with anyone who does not have a legal
right of access without your written consent.
You have the right to see what personal data of yours I hold (Subject
Access Request), and you can also ask me to correct any factual
errors. I am legally required to respond to any request from a client
to see their personal data within a timescale of 30 days.
On some occasions when I am not available I may refer you to an
acupuncture colleague. In that case I will ask you whether you agree
or object to information about your health being passed on to my
colleague and will act accordingly.
I want you to be absolutely confident that I am treating your personal
data responsibly, and that I will do everything I can to make sure
that the only people who can access that data have a legal requirement
to do so. In the case of my practice this would also apply when
referring to another health professional. Other than for emergency
treatment I will always ask you for your consent and will act
If you feel that I am mishandling your personal data in some way, you
have the right to complain. In the first instance, please contact
myself, the 'Data Controller', as I very much hope I would be able to
deal with any concerns you may have. However, you can also raise a
concern directly with the Information Commissioner's Office on https://ico.org.uk/concerns.