Privacy Policy for Neuro Physio Kent Ltd

This is the privacy policy of Neuro Physio Kent. In this document, "we", "our", or "us" refer to Neuro Physio Kent Limited.
We are a Physiotherapy practice specialising in the rehabilitation and treatment of people with neurological and vestibular impairments.
Our registered office is: 2 Lakeview Stables,  St. Clere, Sevenoaks TN15 6NL. Company Number: 8055487
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Introduction
*         This is a notice to inform you of our policy about all information that we receive and record about you. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.
*         As healthcare professionals we take seriously the protection of your privacy and confidentiality and we hereby undertake to do that. Also, we understand that all our clients and visitors to our website are entitled to know that their personal data will not be used for any purpose unintended by them, and will not accidentally fall into the hands of a third party.
*          We hereby undertake to preserve the confidentiality of all information you provide to us, with electronic data being password protected and paper data stored in a locked fireproof environment. This policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).
*           The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. We do this now, by requesting that you read the information provided at www.knowyourprivacyrights.org

The basis on which we process information about you
The law requires us to determine under which of the following six defined bases we process different categories of your personal information, and to notify you of the basis for each category.
  
Information we process because we have a patient consent form signed by you.
When you become our patient, we will ask you to sign a consent form, this is deemed a contract between you and us. (In the event of the client having been deemed not to have capacity, the consent form may be signed by a person having power of attorney for the client regarding health & well being issues. In this instance all provisions of this policy will apply to the client.)
We shall continue to process this information until the ‘contract’ ends. Please note however that we have a statutory requirement to retain your information and any relevant notes on your treatment for a period of 8 years.

Information we process with your consent
Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our services, you provide your consent to us to process information that may be personal information.
Wherever possible, we aim to obtain your explicit consent to process this information.
Sometimes you might give your consent implicitly, such as when you write to us requesting a response.
Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally.
If we need to liaise with other medical professionals, ie. your GP or Consultant regarding your treatment and care this will be discussed with you. 

We will continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by writing to us at our registered office or by e-mail at info@neurophysiokent.com. If you do so, we shall not be able to provide our services further.

Information we process for the purposes of legitimate interests
We may process information on the basis there is a legitimate interest, either to you or to us, for doing so.
Where we process your information on this basis, we do so after having given careful consideration to:-
*         whether we could achieve the same objective by other means
*         whether processing (or not processing) might cause you harm
*         whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so
For example, we may process your data on this basis for the purposes of:
*         record-keeping for the proper and necessary administration of our business
*         protecting and asserting your rights, our rights, or the rights of any other third party
*         insuring against or obtaining professional advice that is required to manage business risk
*         protecting your interests where we believe we have a duty to do so

Information we process because we have a legal obligation
We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation.
For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.
As mentioned above, we also have a statutory duty to retain your information and notes for 8 years.
Both of the above points may include your personal information.

 Specific uses of information you provide to usJob application and employment
If you send us information in connection with a job application, we may keep it for up to three years in case we decide to contact you at a later date.
If we employ you, we collect personal information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, we will keep your file for six years before destroying or deleting it.

Contacting us 
When you contact us, whether by telephone, by post, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need. Also, any information sent to us via the contact form on the website will be kept secure and handled appropriately.

We record your request and our reply in order to increase the efficiency of our business and to refer to in the future if the need arises.
We may keep personally identifiable information associated with your message, such as your name and email address, phone number so as to be able to track our communications with you to provide a high quality service.

Use of information we collect through automated systems when you visit our website - Cookies

Our website uses cookies. They are placed by the software which operates on our servers, and by the software operated by third parties whose services we use.

If you choose not to use cookies or you prevent their use through your browser settings, you will lose some of the functionality of our website

Your web browser should allow you to delete any cookies you choose and may allow you to prevent or limit their use.    

Retention period for personal data
Except as otherwise mentioned in this privacy notice, we keep your personal information for 8 years as required by our statutory body, which is a legal requirement. or for as long as required by us:
*    to provide you with the services you have requested;
*    to comply with other law, including for the period demanded by our tax authorities;
*    to support a claim or defence in court. 

 Access to your personal information
*     At any time you may obtain a copy of any information we hold on you or update or request that we remove personally identifiable information that we hold about you. Send us a request at info@neurophysiokent.com
*    After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.
*     When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting your request or otherwise taking any action. This is important to safeguard your information.

How you can complain about our privacy policy
*      If you are unhappy with our privacy policy or if you have any complaint with respect to how we process your personal information then please tell us by email: info@neurophysiokent.com.
*     If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
*     If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner's Office. This can be done at https://ico.org.uk/concerns/  

Compliance with the law 
Our privacy policy has been compiled so as to comply with the laws of the legal jurisdictions in the UK and the European Union.

Review of this privacy policy
We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.
If you have any question regarding our privacy policy, please contact us.

Neuro Physio Kent Ltd, March 2020