THE VALE CLINIC PRIVACY POLICY

This Privacy Policy describes how and when I collect, use, and share information when you attend an appointment at my clinic, purchase a product from me, contact me, or otherwise use my services.  This is to comply with the General Data Protection Regulations (GDPR) 2018.

It tells you how The Vale Clinic protect and use information that has been gathered from you. By using this website, you consent to the terms described in the most recent version of this Privacy Policy.  This policy may change so please check this page from time to time to ensure you are happy with any changes.

Information I Collect

To aid your treatment or as part of purchasing something from my business you will normally provide me with certain information, such as your name, email address, postal address, medical information and payment information.  I will store your information on hard copy as well as an electronic patient record and diary system which is fully password protected.  When you make a card payment in clinic, your payment information is processed by a third-party payment processor – I use Izettle. If you have any questions regarding secure transactions, please contact me.

What type of information do I collect from you?  

Personal and non-personal data.

What is personal data, and how is it collected?

Personal data is information that identifies you as an individual. I collect your personal data mostly through my contact with you, and the data is usually provided by you, but in some instances, I may receive data about you from other people/organisations such as a general practitioner. 

I obtain information about you in a variety of ways when you use The Vale Clinic website, for example,

• when you complete the contact form
• when you purchase a product from the store or engage with other forms within the website.
• When you conduct a transaction with us, The Vale Clinic’s affiliates, or others
• In some places on this website you have the opportunity to send personal information about yourself, to elect to receive particular information, to purchase access to products or services, or to participate in an activity.
• Medical information includes your personal details, medical history, treatment notes, new patient consent forms, consent to treatment forms, correspondence with other medical professionals in regards to your care, prescription sent to a third party e.g. for bespoke orthotics manufacture, photos of the foot relating to your care, video recording from gait analysis.  Consent will be sought from you prior to taking any of the above actions.
• Medical data will be kept confidential at all times, with the exception of providing information to meet legal requirements where requested by authorised persons.

• When I collect information about you in support of a transaction, such as debit or credit card information

What is non- personal data, and how is it collected and used?

• Non-personal data is information that cannot identify you. If you visit this website to read information, such as information about one of our services, we may collect certain non-personal information about you from your computer’s web browser. Because non-personal information cannot identify you or be tied to you in any way, there are no restrictions on the ways that we can use or share non-personal information. as explained below – use of cookies. 

Website recording – Use of ‘cookies’

• Like many other websites, Thevaleclinic.com uses cookies. ‘Cookies’ are small pieces of information sent by an organisation to your computer and stored on your hard drive to allow that website to recognise you when you visit. They collect statistical data about your browsing actions and patterns and do not identify you as an individual. For example, we use cookies to store your country preference. This helps to improve The Vale Clinic website and deliver a better more personalised service. 
• It is possible to switch off cookies by setting your browser preferences. Turning cookies off may result in a loss of functionality when using our website. 
• The main cookies used on this website is mailchimp, google analytics and google maps. 

To find out more information on Google Analytics’ privacy policy visit here http://www.google.com/analytics/learn/privacy.html

How your data is stored

• Your personal data is held in both hard copy and electronic formats.  Electronic data, including emails, is stored on our servers which are located in the UK on our software suppliers’ servers.

Information Sharing and Disclosure

• Information about my patients/customers is important to my business. In general terms, I process your data in order to manage my professional relationship with you and I will only collect the information I need to provide you with The Vale Clinic’s services.
• I share your personal information for very limited reasons and in limited circumstances, as follows:
• Medical professionals –   With your consent I will share information with medical professionals such as your GP or consultant to allow continuity of care.
• Service providers – For some processing purposes, I engage certain trusted third parties to perform functions and provide services to my business, such as external reception services. I will share your personal information with these third parties, but only to the extent necessary to perform these services.
• Business transfers – If I sell or merge my business, I may disclose your information as part of that transaction, only to the extent permitted by law and with your consent.
• Compliance with laws – I may collect, use, retain, and share your information if I am legally required to.

I rely on a number of legal bases to collect, use, and share your information, including:

• where it is necessary for the purposes of the provision of health care as needed to provide my services, such as when I use your information to fulfil your podiatry assessment and treatment, or to provide customer support;
• if necessary, to comply with a legal obligation or court order or in connection with a legal claim, such as retaining information about your purchases if required by tax law;
• when you have provided your affirmative consent, which you may revoke at any time, such as by signing up for my mailing list;
• Send you communications, which you have requested and that may be of interest to you.  These may include information about campaigns, promotions of our associated companies’ goods and services.

Please be reassured that I will not release your information to third parties beyond the company for them to use for their own direct marketing purposes, unless you have requested me to do so, or I am required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crime.

When you are using our secure store pages, your payments are processed by a third-party payment processor, who specialises in the secure online capture and processing of credit/debit card transactions – I use PayPal.  If you have any questions regarding secure transactions, please contact me.

Marketing

From time to time I may wish to send you direct marketing material which may include product offers and newsletters. If you are happy for me to do this please indicate in what forms you would like to receive this information:

• Mail 
•  Email    
• Text     
• Phone     
• None

I may also use your information to:

• Contact you regarding queries raised in the contact form;
• Progress an order you have submitted and send you information directly related to this;
• Seek your views or comments on the services we provide;
• Notify you of changes to The Vale Clinic’s services;

Data Retention

I retain your personal information only for as long as necessary to provide you with my services and as described in my Privacy Policy. However, I may also be required to retain this information to comply with my legal and regulatory obligations, to resolve disputes, and to enforce my agreements. The retention of podiatry records is normally a minimum of 8 years, after the last appointment.  For customers who are not patients but may have bought products from my business I will keep any data you may have provided for a minimum of 6 years in line with tax legislation.

 Links to other websites

The Vale Clinic website may contain links to other websites run by other organisations. This privacy policy applies only to this website‚ so I encourage you to read the privacy statements on the other websites you visit.  I cannot be responsible for the privacy policies and practices of other sites even if you access them using links from my website.

In addition, if you linked to my website from a third-party site, I cannot be responsible for the privacy policies and practices of the owners and operators of that third-party site and recommend that you check the policy of that third-party site.

16 or Under

Protecting the privacy of children aged 16 or under, is important to The Vale Clinic. If you are aged 16 or under‚ please ask your parent/guardian’s permission whenever you input your personal information into any registration forms or contact forms on the Vale Clinic website.

Transfers of Personal Information Outside the EU

As part of the services offered to you through this website, the information which you provide may be stored and processed in other countries outside the European Union (“EU”) through third party hosting services. As a result, I may transfer your personal information to a jurisdiction with different data protection and government surveillance laws than your jurisdiction. 

These countries may not have similar data protection laws to the UK. By submitting your personal data, you’re agreeing to this transfer, storing or processing. If I transfer your information outside of the EU in this way, I will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this Policy.

If you use The Vale Clinic services while you are outside the EU, your information may be transferred outside the EU in order to provide you with those services.

Your Rights

You have a number of rights in relation to your personal information. While some of these rights apply generally, certain rights apply only in certain limited cases. I describe these rights below:

• Access. You have the right to access and receive a copy of the personal information I hold about you by contacting me using the contact information below.
• Change, restrict, delete. You may also have rights to change, restrict my use of, or delete your personal information. In the case of health records these are normally exempt from change and deletion requests. 
• Object. You can object to (i) my processing of some of your information based on my legitimate interests and (ii) receiving marketing messages from me after providing your express consent to receive them. In such cases, I will delete your personal information unless I have compelling and legitimate grounds to continue using that information or if it is needed for legal reasons.
• Complain. If you wish to raise a concern about my use of your information (and without prejudice to any other rights you may have), you have the right to do so with the Information Commissioner www.ico.org.uk

How to Contact Me

For purposes of the GDPR, I, Ronke Tinker, am the data controller of your personal information. If you have any questions or concerns, you may contact me at info@thevaleclinic.com. Alternately, you may send your correspondence to:

The Vale Clinic Office, 11 Elmhurst Road, Reading, Berkshire, RG1 5JA.

Review of this Policy

This policy is under regular review, first version published January 2019.