you attend an appointment at our clinic, purchase a product from us, contact us, or
otherwise, use our services. This is to comply with the General Data Protection
Regulations (GDPR) 2018.
The Finchley Foot Clinic is committed to complying with the 6 principles relating to the
processing of personal data under the GDPR in all that we do. These principles are:
1. Lawfulness, fairness & transparency.
2. Purpose limitation.
3. Data minimisation.
5. Storage limitation.
6. Integrity and confidentiality.
1. Personal Information We Collect
To aid your treatment or as part of purchasing something from our business you will
normally provide us with certain information, such as your name, telephone number, email
address, postal address, date of birth, general practitioner’s details, medical information
and payment information. We will store your information on an electronic patient record
and diary system which is fully password protected. The information is collected by staff
member of the clinic and/or receptionist. The data is collected in person through personal
connection by any of our staff. We also collect data through our email, messaging
services, via telephone and through other similar communication systems.
2. Why We Need Your Information and How We Use It
We 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 healthcare as needed to
provide our services, such as when we use your information to fulfil your podiatry
• If an individual chooses not to give us this personal information, it may delay or
prevent us from meeting our obligations. It may also mean that we cannot perform
services the patient has requested. It could mean the necessity to cancel a product
or service. Any data collection that is optional would be made clear at the point of
• When you have provided your affirmative consent, which you may revoke at any
time, such as by signing up for our mailing list;
• 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
3. Marketing we undertake for our business
From time to time we may wish to send you direct marketing material which may include
product offers and newsletters. We will ask you if you are happy for us to do this at the
time of our initial contact.
4. Information Sharing and Disclosure
Information about our patients is important to our business. We share your personal
information for very limited reasons and in limited circumstances, as follows:
• Medical professionals. With your consent we will share information with medical
professionals such as your GP or consultant to allow continuity of care.
• Service providers. We engage certain trusted third parties to perform functions and
provide services to our business, such as external reception services, biomechanics
laboratories. We will share your personal information with these third parties, but
only to the extent necessary to perform these services.
• Business Transfers. If We sell or merge our business, We may disclose your
information as part of that transaction, only to the extent permitted by law and with
• Compliance with laws. We may collect, use, retain, and share your information if we
are legally required to.
5. Data Retention
We retain your personal information only for as long as necessary to provide you with our
retain this information to comply with our legal and regulatory obligations, to resolve
disputes, and to enforce our 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 our business we will keep any data you may have
provided for a minimum of 6 years in line with tax legislation.
6. Transfers of Personal Information Outside the EU
We may store and process your information through third-party hosting services in the US
and other jurisdictions. As a result, we may transfer your personal information to a
jurisdiction with different data protection and government surveillance laws than your
jurisdiction. If we are deemed to transfer information about you outside of the EU, we rely
on Privacy Shield as the legal basis for the transfer, as iCloud is Privacy Shield certified.
7. 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. We describe these
• Access. You have the right to access and receive a copy of the personal information
we hold about you by contacting us using the contact information below.
• Change, restrict, delete. You may also have rights to change, restrict our 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) our processing of some of your information based on
our legitimate interests and (ii) receiving marketing messages from us after
providing your express consent to receive them. In such cases, we will delete your
personal information unless we 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 our 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 us
For purposes of the GDPR, I, Margarita Taglia, am the data controller of your personal
information. If you have any questions or concerns, you may contact me by e-mail:
firstname.lastname@example.org. Alternatively, you may mail me at:
Finchley Foot Clinic
66 Nether Street
London N12 7NG
Last updated 5th or May 2018