ADDISON PLACE DENTAL PRACTICE

SCOPE OF PRIVACY NOTICE

This privacy notice applies to anyone who interacts with us about our products and services (‘you’, ‘your’), in any way (for example, by email, through our website, or by telephone). We will give you further privacy information if necessary for specific contact methods or in relation to specific products or services.

This privacy notice applies to you if you ask us about, buy or use our products and services. It describes how we handle your information, regardless of the way you contact us (for example: by email, through our website, by phone, and so on). We will provide you with further information or notices if necessary, depending on the way we interact with each other, for example we developed an app we may give you privacy notices which apply just to a particular type of information which we collected through that app.

If you have any questions about this, please contact us at info@addisonplace.co.uk

HOW WE COLLECT PERSONAL INFORMATION

We collect personal information from you and from third parties (anyone acting on your behalf, for example, health-care providers and so on). Please see below for more information.

We collect personal information from you:

• through your contact with us, including by phone, by email, through our website, by post, by filling in a medical history or other forms, or face-to-face (for example, in medical consultations, diagnosis and treatment).

We also collect information from other people and organisations.

For all our patients, we may collect information from:

• your parent or guardian, if you are under 18 years old;

• a family member, or someone else acting on your behalf;

• doctors, other clinicians and health-care professionals, hospitals, clinics and other health-care providers;

• fraud-detection and credit-reference agencies

• brokers and other agents (this may be your broker if you have one, or your employer's broker if they have one); and

• those paying for the products or services we provide to you, including other insurers, public-sector commissioners and embassies.

CATEGORIES OF PERSONAL INFORMATION

We process two categories of personal information about you and (where this applies) your dependants:

• standard personal information (for example, information we use to contact you, identify you or manage our relationship with you); and

• special categories of information (for example, health information, information about your race, ethnic origin and religion that allows us to tailor your care, and information about crime in connection with checks against fraud or anti-money-laundering registers).

For more information about these categories of information, see below.

Standard personal information includes:

• contact information, such as your name, username, address, email address and phone numbers;

• the country you live in, your age, your date of birth.

• details of any contact we have had with you, such as any complaints or incidents;

• financial details, such as details about your payments and your bank details;

• the results of any credit or any anti-fraud checks we have made on you;

• information about how you use our products and services, such as insurance claims.

Special category information includes:

• information about your physical or mental health, including genetic information or biometric information (we may get this information from application forms you have filled in, from notes and reports about your health and any treatment and care you have received or need, or it may be recorded in details of contact we have had with you such as information about complaints or incidents, and referrals from your existing insurance provider, quotes and records of medical services you have received);

• information about your race, ethnic origin and religion (we may get this information to allow us to provide care that is tailored to your needs); and

• information about any criminal convictions and offences (we may get this information when carrying out anti-fraud or anti-money-laundering checks, or other background screening activity.

WHAT WE USE YOUR PERSONAL INFORMATION FOR

We process your personal information for the purposes set out in this privacy notice. We have also set out some legal reasons why we may process your personal information (these depend on what category of personal information we are processing). We normally process standard personal information if this is necessary to provide the services set out in a contract, it is in our or a third party’s legitimate interests or it is required or allowed by any law that applies. Please see below for more information about this and the reasons why we may need to process special category information.

By law, we must have a lawful reason for processing your personal information. We process standard personal information about you if this is:

• necessary to provide the services set out in a contract − if we have a contract with you, we will process your personal information in order to fulfil that contract (that is, to provide you and your dependants with our products and services);

• in our or a third party’s legitimate interests − details of those legitimate interests are set out in more detail below;

• required or allowed by law.

We process special category information about you because:

• it is necessary for an insurance purpose (for example, dealing with a claim made under an insurance contract, or relating to rights and responsibilities arising in connection with an insurance contract or law);

• it is necessary for the purposes of preventing or detecting an unlawful act in circumstances where we must carry out checks without your permission so as not to affect the outcome of those checks (for example, anti-fraud and anti-money-laundering checks or to check other unlawful behaviour, or carry out investigations with other insurers and third parties for the purpose of detecting fraud);

• it is necessary for a purpose designed to protect the public against dishonesty, malpractice or other seriously improper behaviour (for example, investigations in response to a safeguarding concern, a member's complaint or a regulator (such as

• the Care Quality Commission or the General Dental Council) telling us about an issue);

• it is in the public interest, in line with any laws that apply;

• it is information that you have made public; or

• we have your permission. As is best practice, we will only ask you for permission to process your personal information if there is no other legal reason to process it. If we need to ask for your permission, we will make it clear that this is what we are asking for and ask you to confirm your choice to give us that permission. If we cannot provide a product or service without your permission, we will make this clear when we ask for your permission. If you later withdraw your permission, we will no longer be able to provide you with a product or service that relies on having your permission.

LEGITIMATE INTEREST

We process your personal information for a number of legitimate interests, including managing all aspects of our relationship with you, for marketing, to help us improve our services and products, and in order to exercise our rights or handle claims. More detailed information about our legitimate interests is set out below.

Legitimate interest is one of the legal reasons why we may process your personal information. Taking into account your interests, rights and freedoms, legitimate interests which allow us to process your personal information include:

• to manage our relationship with you, our business and third parties who provide products or services for us (for example, to check that you have received a service that you’re covered for, to validate invoices and so on);

• to make sure that claims are handled efficiently and to investigate complaints (for example, we may ask your treatment provider for information to make sure we receive accurate information and to monitor the quality of your treatment and care);

• to keep our records up to date and to provide you with marketing as allowed by law;

• to develop and carry out marketing activities and to show you information that is of interest to you, based on our understanding of your preferences (we combine information you give us with information we receive about you from third parties to help us understand you better);

• for statistical research and analysis so that we can monitor and improve products, services, and websites, or develop new ones;

• to monitor how well we are meeting our clinical and non-clinical performance expectations in the case of health-care providers;

• to enforce or apply our website terms of use, our policy terms and conditions or other contracts, or to protect our (or our customers’ or other people’s) rights, property or safety;

• to exercise our rights, to defend ourselves from claims and to keep to laws and regulations that apply to us and the third parties we work with; and

• to take part in, or be the subject of, any sale, purchase, merger or takeover of all or part of the dental practice.

SHARING YOUR INFORMATION

We share your information within Addison Place Dental Practice, with relevant policyholders, with funders arranging services on your behalf, with people acting on your behalf (for example, brokers and other agents) and with others who help us provide services to you (for example, health-care providers and medical-assistance providers) or who we need information from to allow us to handle or confirm claims or entitlements (for example, professional associations). We also share your information in line with the law. For more information about who we share your information with, please see below.

We sometimes need to share your information with other people or organisations for the purposes set out in this privacy notice.

For all our patients, we share your information with:

• dentists, doctors, clinicians and other health-care professionals, hospitals, clinics and other health-care providers;

• suppliers who help deliver products or services on our behalf;

• people or organisations we have to, or are allowed to, share your personal information with by law (for example, for fraud-prevention or safeguarding purposes, including with the Care Quality Commission);

• the police and other law-enforcement agencies to help them perform their duties, or with others if we have to do this by law or under a court order;

• if we sell or buy any business or assets, the potential buyer or seller of that business or those assets; and

• a third party who takes over any or all of the Addison Place Dental Practice’s assets (in which case personal information we hold about our customers or visitors to the website may be one of the assets the third party takes over).

If we share your personal information, we will make sure appropriate protection is in place to protect your personal information in line with data-protection laws.

HOW WE STORE YOUR PERSONAL INFORMATION

Personal information about you is held in the practice’s computer system and, for older records, in manual filing room. The information is not accessible to the public and only authorised members of staff have access to it.

It is backed up both on site and remotely. Our computer system has secure audit trails and we back up information routinely.

HOW LONG WE KEEP YOUR PERSONAL INFORMATION

We keep your personal information in line with set periods calculated using the following criteria.

• How long you have been a customer with us, the types of products or services you have with us, and when you will stop being our customer.

• How long it is reasonable to keep records to show we have met the obligations we have to you and by law.

• Any time limits for making a claim.

• Any periods for keeping information which are set by law or recommended by regulators, professional bodies or associations.

• Any relevant proceedings that apply.

If you would like more information about how long we will keep your information for, please contact us at info@addisonplace.co.uk

Data Breach

Should there be a breach of patient confidentiality, the data controller must notify the ICO without delay, and if possible within 72 hours of becoming aware.

The patient must also be informed if a breach has a high risk of affecting their privacy rights.

Your Rights

You have the right to access your information and to ask us to correct any mistakes and delete and restrict the use of your information. You also have the right to object to us using your information, to ask us to transfer of information you have provided, to withdraw permission you have given us to use your information and to ask us not to use automated decision-making which will affect you. For more information, see below.

You have the following rights (certain exceptions apply).

• Right of access: the right to make a written request for details of your personal information and a copy of that personal information

• Right to rectification: the right to have inaccurate information about you corrected or removed

• Right to erasure ('right to be forgotten'): the right to have certain personal information about you erased

• Right to restriction of processing: the right to request that your personal information is only used for restricted purposes

• Right to object: the right to object to processing of your personal information in cases where our processing is based on the performance of a task carried out in the public interest or we have let you know the processing is necessary for our or a third party’s legitimate interests.

• Right to data portability: the right to ask for the personal information you have made available to us to be transferred to you or a third party in machine-readable formats

• Right to withdraw consent: the right to withdraw any consent you have previously given us to handle your personal information. If you withdraw your consent, this will not affect the lawfulness of Addison Place Dental Practice’s use of your personal information prior to the withdrawal of your consent and we will let you know if we will no longer be able to provide you your chosen product or service

• Right in relation to automated decisions: you have the right not to be subject to a decision based solely on automated processing which produces legal effects concerning you or similarly significantly affects you, unless it is necessary for entering into a contract with you, it is authorised by law or you have given your explicit consent. We will let you know when such decisions are made, the lawful grounds we rely on and the rights you have.

Please note: Other than your right to object to the use of your data for direct marketing, your rights are not absolute: they do not always apply in all cases and we will let you know in our correspondence with you how we will be able to comply with your request.

If you make a request, we will ask you to confirm your identity if we need to, and to provide information that helps us to understand your request better. If we do not meet your request, we will explain why.

In order to exercise your rights please contact info@addisonplace.co.uk