Privacy Notice (Under the General Data Protection Regulations 2018)
This privacy statement documents how SPORTS CLINICAL complies with European Union data protection requirements. It applies to our services, website, bookings system, social media platforms and you can access this policy from our website homepage menu. We may change this privacy statement from time to time, therefore, please continue to check the website page to ensure you are happy with any changes.
This document refers to personal data, which is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain.
The General Data Protection Regulation 2018 (GDPR) which is EU wide and far more extensive than its predecessor the Data Protection Act, along with the Privacy and Electronic Communications Regulations (PECR), seek to protect and enhance the rights of EU data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU and its storage within the EEA.
1 – SPORTS CLINICAL
Based at Default Blue House, 16 Torgate Lane, Bassingham, Lincoln, Lincolnshire, LN5 9HF, UK, which, hereafter for the purposes of this Privacy Notice will be referred to as SPORTS CLINICAL, is pleased to provide the following information:
2 – Who we are
Practitioners at SPORTS CLINICAL, consult, assess and treat health conditions and provide a multimodal service, including neurological and soft tissue therapies. Practitioners at SPORTS CLINICAL may also provide other treatments, about which our staff will be pleased to provide more details.
3 – Personal Data
a) For the purposes of providing treatment, Practitioners may require detailed medical information. We will only collect what is relevant and necessary for your treatment. When you visit SPORTS CLINICAL, we will make notes which may include details concerning your medication, treatment and other issues affecting your health. This data is always held securely, is not shared with anyone not involved in your treatment, although for data storage purposes it may be handled by pre-vetted staff who have all signed an integrity and confidentiality agreement. To be able to process your personal data it is a condition of any treatment that you give your explicit consent to allow Practitioners to document and process your personal medical data. Contact details provided by you such as telephone numbers, email addresses, postal addresses may be used to remind you of future appointments and provide reports or other information concerning your treatment via mail, telephone, Email or text/ SMS as in compliance and as requested.
b) For marketing purposes, SPORTS CLINICAL may also use the contact details provided by you to respond to your enquiries, including making telephone contact and emailing information to you which SPORTS CLINICAL believes may be of interest to you, including health information, rehab details and exercises and practice newsletters if applicable.
c) In making initial contact with SPORTS CLINICAL you consent to SPORTS CLINICAL maintaining a marketing dialogue with you until you either opt out (which you can do at any time) or we decide to desist in promoting our services. SPORTS CLINICAL may occasionally also act on behalf of its patients in the capacity of data processor, when we may promote other practitioners based at our premises, who may not be employed by us. Practitioners do not broker your data and you can ask to be removed from our marketing database by emailing or phoning the practice using the contact details provided at the end of this Privacy Notice.
d) Some basic personal data may be collected about you from any marketing forms and/or surveys you complete, from records of our correspondence and phone calls and details of your visits to our website, including but not limited to, personally identifying information like Internet Protocol (IP) addresses.
f) SPORTS CLINICAL will only collect the information needed so that we can provide you with the services you require, the business/ clinic does not sell or broker your data. Information will be taken for booking appointments, adding details to the waiting list, medical history/ health record, medical reports/letters, CV’s and applications, references and interview notes, photographs and video for postural assessments and for invoicing.
4 – Legal basis for processing any personal data
To meet our contractual obligations obtained from explicit Patient Consent and legitimate interest to respond to enquiries concerning the services provided.
5 – Legitimate interests pursued by SPORTS CLINICAL
To promote treatments for patients with all types of health problems.
6 – Consent
Through agreeing to this privacy notice you are consenting to SPORTS CLINICAL processing your personal data for the purposes outlined. You can withdraw consent at any time by using the postal, email address or telephone number provided at the end of this Privacy Notice.
7 – Disclosure
SPORTS CLINICAL will keep your personal information safe and secure, and only staff engaged in providing your treatment will have access to your patient records, although our administration staff will have access to your contact details so that they can make appointments and manage your account. Practitioners will not disclose your Personal Information unless compelled to, in order to meet legal obligations, regulations or valid governmental requests. SPORTS CLINICAL may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of its staff.
8 – Retention Policy
SPORTS CLINICAL will process personal data during the duration of any treatment and will continue to store only the personal data needed for eight years after the contract has expired to meet any legal obligations. After eight years all personal data will be deleted, unless basic information needs to be retained by us to meet our future obligations to you, such as erasure details. Records concerning minors who have received treatment (under parental consent and attendance) will be retained until the child has reached the age of 25.
9 – Data storage
All Data is held in the United Kingdom. SPORTS CLINICAL does not store personal data outside the EEA. All data storage services used by SPORTS CLINICAL are fully GDPR compliant and available on request.
10 – Your rights as a data subject
At any point whilst SPORTS CLINICAL is in possession of, or processing your personal data, all data subjects have the following rights:
• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.
In the event that SPORTS CLINICAL refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge. At your request SPORTS CLINICAL can confirm what information it holds about you and how it is processed.
11 – You can request the following information:
• Identity and the contact details of the person or organisation (SPORTS CLINICAL) that has determined how and why to process your data.
• Contact details of the data protection officer, where applicable.
• The purpose of the processing as well as the legal basis for processing.
• If the processing is based on the legitimate interests of SPORTS CLINICAL and information about these interests.
• The categories of personal data collected, stored and processed.
• Recipient(s) or categories of recipients that the data is/will be disclosed to.
• How long the data will be stored.
• Details of your rights to correct, erasure, restrict or object to such processing.
• Information about your right to withdraw consent at any time.
• How to lodge a complaint with the supervisory authority (ICO).
• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
• The source of personal data if it wasn’t collected directly from you.
• Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
12 – To access what personal data is held, identification will be required
SPORTS CLINICAL will accept the following forms of identification (ID) when information on your personal data is requested: a copy of your driving licence, passport or birth certificate, together with a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If SPORTS CLINICAL is dissatisfied with the quality, further information may be sought before personal data can be released. All requests should be made to email@example.com or by phoning +44 (0)7773 814488 or writing to us at SPORTS CLINICAL, Default Blue House, 16 Torgate Lane, Bassingham, Lincoln, Lincolnshire, LN5 9HF. If you do not hear back from us within five days, please try another form of contact.
13 - External Links
Although this website only looks to include quality, safe and relevant external links, users are advised adopt a policy of caution before clicking any external web links mentioned throughout this website. (External links are clickable text / banner / image links to other websites, similar to; SEO Local Research or www.searchengineready.co.uk.)
We cannot guarantee or verify the contents of any externally linked website despite our best efforts. Users should therefore note they click on external links at their own risk and we cannot be held liable for any damages or implications caused by visiting any external links mentioned.
14 - Social Media Platforms
Communication, engagement and actions taken through external social media platforms that this website and its owners participate on are custom to the terms and conditions as well as the privacy policies held with each social media platform respectively.
Users are advised to use social media platforms wisely and communicate / engage upon them with due care and caution in regard to their own privacy and personal details. SPORTS CLINICAL will never ask for personal or sensitive information through social media platforms and encourage users wishing to discuss sensitive details to contact them through primary communication channels such as by telephone or email.
This website may use social sharing buttons which help share web content directly from web pages to the social media platform in question. Users are advised before using such social sharing buttons that they do so at their own discretion and note that the social media platform may track and save your request to share a web page respectively through your social media platform account.
15 - Shortened Links in Social Media
SPORTS CLINICAL through their social media platform accounts may share web links to relevant web pages. By default, some social media platforms shorten lengthy urls.
Users are advised to take caution and good judgement before clicking any shortened urls published on social media platforms by this website and its owners. Despite the best efforts to ensure only genuine urls are published many social media platforms are prone to spam and hacking and therefore SPORTS CLINICAL cannot be held liable for any damages or implications caused by visiting any shortened links.
16 - Children’s Online Privacy Protection Act Compliance
We are in compliance with the requirements of the Children’s Online Privacy Protection Act. We will not intentionally collect any information from anyone under 13 years of age. Our website, products and services are all directed at people who are at least 13 years old or older, with only the direct permission of their parents or legal guardians.
If you are under 13 years of age you MUST obtain parental consent before posting a comment on our blog or social media platforms.
NOTE: You should avoid entering personally identifiable information to the actual comment field of any blog, post or comments that you submit on this website or social media links.
17 – Complaints
In the event that you wish to make a complaint about how your personal data is being processed by SPORTS CLINIICAL you have the right to complain to us. If you do not get a response within 30 days, you can complain to the ICO.
The details for each of these contacts are:
DPO, SPORTS CLINICAL, Default Blue House, 16 Torgate Lane, Bassingham, Lincoln, Lincolnshire, LN5 9HF
Telephone: +44 (0)7773 814488 Email: firstname.lastname@example.org
Wycliffe House, Water Lane, Wilmslow, SK9 5AF Telephone +44 (0) 303 123 1113 Website: https://ico.org.uk
ADDITIONAL STATEMENT - COVID-19 Revised (11th June 2020)
When treatment sessions resume, with reference to COVID-19 there will be an additional declaration form to complete stating that:
a) There has not been in contact with anyone with Covid-19, in the last 14 days, to your knowledge
b) There have not been any Covid-19 symptoms: - dry cough, temp over 37.8°C, loss of smell and/or taste
c) Should the client contract the virus you must inform your therapist as soon as possible
d) Should the client contract the virus we are obliged to inform NHS Track & Trace
There will also be a signed declaration from the therapist stating the same declaration
All first-time and follow-up consultations will be carried out either on the phone or via video conferencing to determine the need for face-to-face appointments.
NB: There is no variation required to the GDPR policy statement. However, there is the relevant clause on the consent form regarding NHS Track &Trace wish we must adhere to.
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