Privacy and cookies

The practice aims to meet the requirements of the Data Protection Act 2018, the General Data Protection Regulation (GDPR), the guidelines on the Information Commissioner’s website as well as our professional guidelines and requirements.

The data controller is Dr Hanel Nathwani, the practice manager is the information Governance Lead.

This Privacy Notice is available on the practice website at www.smileroomsmiltonkeynes.co.uk, at reception, by email if you contact mk@smilerooms.co.uk by calling the practice on 01908 731 705.

You will be asked to provide personal information when joining the practice. The purpose of us processing this data is to provide optimum health care to you.

The categories of data we process are:

• Personal data for the purposes of staff and self-employed team member management
• Personal data for the purposes of direct mail, email, text or marketing
• Special category data including health records for the purposes of the delivery of health care
• Special category data including health records and details of criminal record checks for managing employees and contracted team member

We never pass your personal details to a third party unless we have a contract for them to process data on our behalf and will otherwise keep it confidential. If we intend to refer a patient to another practitioner or to secondary care such as a hospital we will gain the individual’s permission before the referral is made and the personal data is shared.

Personal data is obtained when a patient joins the practice, when a patient is referred to the practice and when a patient subscribes to an email list

The lawful basis for processing special category data such as patients’ and employees’ health data is:

• Processing is necessary for the purposes of preventative or occupational medicine, for assessing the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or management of health or social care systems and services on the basis of Union or Member State law or a contract with a health professional

The lawful basis of processing personal data such as name, address, email or phone number is:

• Consent of the data subject
• Processing is necessary for the performance of a contract with the data subject or to take steps to enter into a contract

The retention period for special data in patient records is a minimum of 10 years and may be longer for complex records in order to meet our legal requirements. The retention period for staff records is 6 years. The retention periods for other personal data is 2 years after it was last processed. Details of other retention periods are available in the Record Retention procedure available from the practice.

You have the following personal data rights:

• The right to be informed
• The right of access
• The right to rectification
• The right to erasure (clinical records must be retained for a certain time period)
• The right to restrict processing
• The right to data portability
• The right to object

Further details of these rights can be seen in our Information Governance Procedures or at the Information Commissioner’s website. Here are some practical examples of your rights:

• If you are a patient of the practice you have the right to withdraw consent for important notifications, newsletters, surveys or marketing. You can inform us to correct errors in your personal details or withdraw consent from communication methods such as telephone, email or text. You have the right to obtain a free copy of your patient records within one month.

• If you are not a patient of the practice you have the right to withdraw consent for processing personal data, to have a free copy of it within one month, to correct errors in it or to ask us to delete it. You can also withdraw consent from communication methods such as telephone, email or text.

We have carried out a Privacy Impact Assessment and you can request a copy from the details below. The details of how we ensure security of personal data is in our Security Risk Assessment and Information Governance Procedures.

Comments, suggestions and complaints

Please contact Dr Hanel Nathwani at the practice for a comment, suggestion or a complaint about your data processing at mk@smilerooms.co.uk or 01908 731 705 or by writing to or visiting the practice at Fortuna House, 651 S Fifth Street, Milton Keynes, MK9 2PQ. We take complaints very seriously.

If you are unhappy with our response or if you need any advice you should contact the Information Commissioner’s Office (ICO). Their telephone number is 0303 123 1113, you can also chat online with an advisor. The ICO can investigate your claim and take action against anyone who’s misused personal data. You can also visit their website for information on how to make a data protection complaint.

Related practice procedures

You can also use these contact details to request copies of the following practice policies or procedures:

• Data Protection and Information Security Policy, Consent Policy
• Privacy Impact Assessment ,Information Governance Procedures

Cookie

What are cookies

As is common practice with almost all professional websites, this site uses cookies, which are tiny files that are downloaded to your computer, to improve your experience. This page describes what information they gather, how we use it and why we sometimes need to store these cookies. We will also share how you can prevent these cookies from being stored however this may downgrade or ‘break’ certain elements of the site’s functionality. For more general information on cookies see the Wikipedia article on HTTP Cookies at https://en.wikipedia.org/wiki/HTTP_cookie

How we use cookies

We use cookies for a variety of reasons detailed below. Unfortunately, in most cases, there are no industry standard options for disabling cookies without completely disabling the functionality and features they add to this site. It is recommended that you leave on all cookies if you are not sure whether you need them or not, in case they are used to provide a service that you use.

Disabling cookies

You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this). Be aware that disabling cookies will affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionality and features of this site. Therefore, it is recommended that you do not disable cookies.

The cookies we set

In order to provide you with a great experience on this site, we provide the functionality to set your preferences for how this site runs when you use it. In order to remember your preferences, we need to set cookies so that this information can be called whenever you interact with a page which is affected by your preferences.

What are the different types of cookies?

Different cookies are used to perform different functions. We detail below our use of cookies. You do have choices about how cookies are used. We use cookies that are essential and first party; they are set by the web server of the visited page and share the same domain. These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information. Third Party Cookies for advertising and performance; in some special cases we also use cookies provided by trusted third parties. The following section details which third party cookies you might encounter through this site. This site uses Google Analytics cookies which is one of the most widespread and trusted analytics solutions on the web. These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance. For more information on Google Analytics cookies, see the official Google Analytics page (https://support.google.com/analytics/answer/6004245) Targeting cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet devices. If you do not allow these cookies, you will experience less targeted advertising. We also use social media buttons and/or plugins on this site that allow you to connect with your social network in various ways, such as sharing pages or links. For these to work the following social media sites (if available) Facebook, Instagram, Twitter, YouTube, Google+ will set cookies through our site which may be used to enhance your profile on their site or contribute to the data they hold for various purposes outlined in their respective privacy policies. Our website also contains a Facebook Pixels Code: A pixel refers to the code that is placed on your computer in order to trigger a cookie. We sometimes use this methodology to allow us to deliver more relevant messages to you. For SEO (search engine optimisation) purposes, from time to time we test new features and make subtle changes to the way that the site is delivered. When we are still testing new features these cookies may be used to ensure that you receive a consistent experience whilst on the site, whilst ensuring we understand which optimisations our users appreciate the most. Session cookies and persistent cookies; our website is hosted on servers that use two different types of cookies. The first type is known as a ‘session-based’ cookie and is allocated to your computer only for the duration of your visit to our website. It helps you to move around the website faster. This cookie automatically expires when you close down your browser, or complete a task (such a form completion). The second type of cookie is known as a ‘persistent’ cookie. These cookies will remain on your computer for a period of time set for each cookie. These cookies allow us to collect data on behaviours such as how many times you visited a page.

How to refuse or opt out of cookies

Most browsers and websites automatically accept cookies but provide controls that allow you to block or delete them. This site has an “implied consent” policy for these cookies, which assume the user has set their cookies on their browser to active. A cookie policy banner is visible until the user acknowledges it and accepts the banner (they can also click on it to read more). If you wish to block cookies from your browser software, please check the browser help menu for relevant instructions. Take care to ensure that you select the correct type and version of your browser software. Unfortunately, if you choose to decline cookies, some of the interactive features and some functionality of our websites and our services may not be available to you. We advise regular users of our websites and services to accept cookies from us.

How to change your browser settings to disable cookies

Microsoft Internet Explorer 6, 7, 8 (Windows XP/Vista)

1. Select Tools from the main task bar, then Internet Options.
2. Click the Privacy tab.
3. Choose the settings you want.
4. Click OK.

Microsoft Internet Explorer 8,9 (Windows 7)

1. Click on the Settings cog icon (top right).
2. Click on Internet Options.
3. Click on Privacy and choose your options.
4. Click Apply and then OK.

Firefox 3.0+, 4.0+, 5.0+,6.0+

1. Choose Tools from the main task bar, then options.
2. Click the privacy tab.
3. Choose the settings you want.
4. Click OK.

Safari 5 & 6

1. Choose Safari from the main task bar, then preferences.
2. Click on the privacy panel.
3. Choose the settings you want.
4. Click X to close

Google Chrome

1. Click the menu icon and select Settings from the list.
2. Click the Show the advance settings.
3. Click Content Settings in the Privacy section.
4. Choose the settings you want.
5. Click X to close.

Mobile Devices iOS

1. From the home screen, choose Settings.
2. Select Safari.
3. Click Accept Cookies.
4. Choose your preferred settings.

Android

1. Start the browser application.
2. Click the Menu button.
3. Select the More option, then Settings.
4. Tick or clear Accept cookies.

Windows Phone 7

1. From the home screen, click on the right arrow.
2. Scroll down to Settings.
3. Swipe across and select Internet Explorer.
4. Tick or clear Accept cookies.

More information

By using our site, as per the EU Cookie Law (https://ec.europa.eu/ipg/basics/legal/cookies/index_en.htm) you are agreeing to these cookies being stored by your browser and their data being shared with the aforementioned services. If there is something that you aren’t sure whether you need or not, it’s usually safer to leave cookies enabled in case it does interact with one of the features you use on our site. However, if you are still looking for more information then you can contact us at email address: mk@smilerooms.co.uk