Tel: 0207 467 8556 Email: secretary@christosdimitriou.co.uk

10 Harley Street London W1G 9PF

Privacy Policy

GENERAL DATA PROTECTION REGULATION (GDPR) PRIVACY NOTICE

BACKGROUND:

Dr Dimitriou and CD Practice Limited, of whom he is a Director, understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our clients and will only use personal data in ways that are described here and in a way that is consistent with our obligations and your rights under the law.

1. Information About Us

CD Practice Limited, is registered in England and Wales with company number 08899166 and registered address at 925 Finchley Road, London, NW11 7PE.
Main trading address: 10 Harley Street London, W1G 9PF
Email address: secretary@christosdimitriou.co.uk
Telephone number: 07720 558940 (Practice Manager, Sara St John Perry)
Postal Address: 10 Harley Street, London, W1G 9PF

We seek to comply with the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”)

2. What Does This Notice Cover?

This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

3. What is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

The personal data that we use is set out in Part 5, below.

4. What Are My Rights?

Under the GDPR, you have the following rights, which we will work to uphold:

1. The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions.

2. The right to access the personal data we hold about you.

3. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us to find out more.

4. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us to find out more.

5. The right to restrict (i.e. prevent) the processing of your personal data.

6. The right to object to us using your personal data for a particular purpose or purposes.

7. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.

8. Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

5. What Personal Data Do You Collect?

We collect and maintain different types of personal information in respect of those individuals who seek to be, are, or were patients, including the personal information contained in:

  • · Booking appointments
  • · Adding details to the clinic patient list or waiting list
  • · Medical reports/letters

In addition to the examples listed above, personal information also includes information such as Name; Date of birth; Gender; Address; Email address; Telephone and mobile number; Business name; Job title; Profession; Payment information; marital status; Insurance details and any other information necessary to CD Practice business purposes, which is disclosed in the Terms and Conditions.

As a general rule, we collect personal information directly from you. In most circumstances where the personal information that we collect about you is held by a third party, we will obtain your permission before we seek out this information from such sources (such permission may be given directly by you, or implied from your actions). An example of this would be sending information to your insurance company to process your medical expenses claim.

From time to time, we may use the services of third parties and may also receive personal information collected by those third parties in the course of the performance of their services for us. In that case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.

Where permitted or required by applicable law or regulatory requirements, we may collect information about you without your knowledge or consent.

6. How Do You Use My Personal Data?

Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data will be used for the following purposes:

1. Providing and managing your account.

2. Supplying our services to you. Your personal details are required in order for us to enter into a contract/ licence agreement with you.

3. Personalising and tailoring our services for you.

4. Communicating with you. This may include responding to emails or calls from you.

5. With your permission and/or where permitted by law, we may also use your personal data for purposes relating only to our business, which may include contacting you by email, telephone or post with information or news such as a change in pricing or our terms and conditions.

7. How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal contact details (including name, address, dob, gender and telephone numbers) will therefore be kept for a fixed period of 2 years following the last consultation. Your medical records will be kept in line with the law and national guidance. Information on how long records are kept can be found at: https://digital.nhs.uk/article/1202/Records-Management-Code-of-Practice-for-Health-and-Social-Care-2016

Your medical records relating to mental health, including your consultation letters will be kept for 20 years after discharge or date that you were last seen and will be reviewed prior to destruction.

8. How and Where Do You Store or Transfer My Personal Data?

We will only store or transfer your personal data in the UK. This means that it will be fully protected under the GDPR. If you require personal data to be transferred outside of the UK e.g. transferring medical notes or a referral letter to a new caregiver then we will forward such data directly to you, by secure email, and ask you to forward on personally as necessary.

We endeavour to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to protect your personal information from loss and unauthorised access, copying, use, modification or disclosure.

9. Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes except under the following limited circumstances.

1. We may be required to share certain personal data, which might include yours

  • · as permitted or required by applicable law or regulatory requirements. In such a case, we will not disclose more personal information than is required under the circumstances;
  • · to comply with valid legal processes such as search warrants, subpoenas or Court orders;
  • · as part of CD Practice Limited’s  regular reporting activities;
  • · to protect the rights and property of CD Practice Limited;
  • · during emergency situations or where necessary to protect the safety of a person or group of persons;
  • · where the personal information is publicly available; or
  • · with your consent where such consent is required by law.

2. We may share your personal information with other parties who require such information to assist us with establishing, managing or terminating our client relationship with you and who supply services on our behalf. These may include payment processing and delivery of medications. In some cases, those third parties may require access to some of your personal data that we hold.

3. If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.

10. How Can I Access My Personal Data?

1. If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

2. All subject access requests should be made in writing and sent to the email or postal addresses shown.

3. We may charge you a fee to access your personal information; however, we will advise you of any fee in advance. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) further fees may be charged to cover our administrative costs in responding.

4. We will respond to your subject access request within 14 working days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of progress.

5. When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you.

6. Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed or erased in accordance with our record retention obligations and practices.

7. If we cannot provide you with access to your personal information, we will try to inform you of the reasons why, subject to any legal or regulatory restrictions.

11. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Sara St John Perry Practice Manager):

Email address: secretary@christosdimitriou.co.uk
Telephone number: 07720 558940

Postal Address: 10 Harley Street, London, W1G 9PF

12. Changes to this Privacy Notice

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Information relating to any changes will be made available via email.

Please contact us for more information

Contact