Harmony One - General Data Protection Regulation (GDPR) 2018 Privacy Notice
This website policy describes how Naas Osteopaths protects and makes use of the information you give the company when you use this website.
This policy is updated from time to time. The latest version is published on this page.
The website policy was updated on 14 June 2018
If you have any questions about this policy, please email firstname.lastname@example.org
1 – Naas Osteopaths, Located at
Phoenix Medical Clinic, 5 Sycamore House, Millennium Park, Naas, Co.Kildare, Ireland
which hereafter for the purposes of this Privacy Notice will be referred to as Naas Osteopaths, is pleased to provide the following information:
2 - Who we are
Naas Osteopaths diagnose and treat health conditions. Treatments are carried out in accordance with the Institute of Osteopathy’s patient charter http://www.iosteopathy.org/osteopathy/the-patient-charter/. The practice 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, Naas Osteopaths may require detailed medical information. We will only collect what is relevant and necessary for your treatment. When you visit our practice, 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 Naas Osteopaths 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. As part of our obligations as primary healthcare practitioners there may be circumstances related to your treatment, on-going care or medical diagnosis that will require the sharing of your medical records with other healthcare practitioners e.g GPs, consultants, surgeons and/or medical insurance companies. Where this is required we will always inform you first unless we are under a legal obligation to comply.
b) For marketing purposes, Naas Osteopaths may also use the contact details provided by you to respond to your enquiries, including making telephone contact and emailing information to you which the practice believes may be of interest to you.
c) In making initial contact with the practice you consent to Naas Osteopaths 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. Naas Osteopaths 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. Naas Osteopaths 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 the marketing forms and 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) Naas Osteopaths will only collect the information needed so that we can provide you with the services you require, the business does not sell or broker your data.
What data we gather From This Website
If you choose to complete the contact us form, we gather:
Your Name if you choose to complete the Contact Us form
Your Email address if you choose to complete the Contact Us form
Any query information you provide on the Contact Us form
Website usage data
How we use this data
We collect personally identifiable information, like names, and email addresses, etc., when voluntarily submitted by our visitors. The information you provide is used to fulfill your specific request. This information is only used to fulfill your specific request, unless you give us permission to use it in another manner, for example to add you to one of our mailing lists.
Specially, we may use data:
For internal records
To contact you in response to a specific query you have submitted
To customise the website for you
Cookies and how we use them
A cookie is a small file placed on your computer's hard drive. It enables our website to identify your computer as you view different pages on our website.
Cookies allow websites and applications to store preferences in order to present content, options or function that are specific to you. They also enable us to see information like how many use the website and what pages they tend to visit.
Analyse our web traffic using an analytics package. Aggregated usage data helps us improve the website structure, design, content and functions.
Test content on our website. For example, 50% of our users might see one piece of content, the other 50% a different piece of content.
Store information about your preferences. The website can then present you with information you will find more relevant and interesting.
To recognise when you return to our website. We may show your relevant content, or provide functionality you used previously.
Cookies do not provide us with access to your computer or any personal information about you, other than that which you choose to share with us.
However, please note that doing this may affect how our website functions. Some pages and services may become unavailable to you.
To learn more about cookies and how they are used, visit https://ico.org.uk/for-the-public/online/cookies
Controlling information about you
We will never lease, distribute or sell your personal information to third parties unless we have your permission or the law requires us to. Any personal information we hold about you is stored and processed in line with the Data Protection Act 1998 and will comply with the new GDPR (EU) as applied from May 25th 2018
Links from our site
Our website may contain links to other websites.
Please note that we have no control of websites outside the naasosteopaths.ie domain. If you provide information to a website to which we link, we are not responsible for its protection and privacy.
Always be wary when submitting data to websites. Read the site’s data protection and privacy policies fully.
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 naas Osteopaths
To promote treatments for patients with all types of health problems indicated for osteopathic care.
6 – Consent
Through agreeing to this privacy notice you are consenting to Naas Osteopaths 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
Naas Osteopaths will keep your personal information safe and secure, only staff engaged in providing your treatment will have access to your patient records, although our administration team will have access to your contact details so that they can make appointments and manage your account. Naas Osteopaths will not disclose your Personal Information unless compelled to, in order to meet legal obligations, regulations or valid governmental requests. The practice 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
Naas Osteopaths 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 will be retained until the child has reached the age of 25.
9 - Data storage
All Data is held in the Republic Of Ireland. Naas Osteopaths does not store personal data outside the EEA.
10 - Your rights as a data subject
At any point whilst Osteopaths are 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 Osteopaths 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 Harmony One Osteopaths 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 (Harmony One Osteopaths) 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 Harmony One Osteopaths 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 (DPC).
· 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
Harmony One Osteopaths will accept the following forms of identification (ID) when information on your personal data is requested: a copy of your driving licence, passport, birth certificate and 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 Harmony One Osteopaths 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 +353 (0) 851792222 or writing to us at the address further below.
In the event that you wish to make a complaint about how your personal data is being processed by Harmony One Osteopaths you have the right to complain to us. If you do not get a response within 30 days, you can complain to the DPC.
The details for each of these contacts are:
Jason Briody – Data Protection Officer (DPO) – Harmony One, Loughanure, Clane, Co.Kildare
Telephone +353(0) 851792222 Email firstname.lastname@example.org
DPC, 21 Fitzwilliam Square, Dublin 2, D02RD28, Ireland
Telephone +353 (0) 761 104 800 Email email@example.com
We gather and use certain information about individuals in order to provide products and services and to enable certain function on this website.
We also collect information to better understand how visitors use this website and to present timely, relevant information to them.