Privacy Policy Finchley Foot Clinic

This Privacy Policy describes how and when we collect, use, and share information when

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.

4. Accuracy.

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

assessment and treatment, or to provide customer support;

• 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

collection.

• 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

law;

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

your consent.

• 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

services and as described in my Privacy Policy. However, we may also be required to

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

rights below:

• 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:

info@finchleyfootcare.co.uk. Alternatively, you may mail me at:

Finchley Foot Clinic

66 Nether Street

London N12 7NG

Last updated 5th or May 2018