Privacy Policy

The Privacy Policy is also available as a notice in my office, alongside Terms of Business .

Transparency requirement:

The General Data Protection Regulation (Regulation (EU) 2016/79) (GDPR) requires me to tell you about the use of personal data held in my office for my clients, the legal justification for doing so, the lawful basis for processing (e.g. consent).

My office respects your privacy and is committed to protecting your personal data. I am involved in your direct care. My administrative staff support your direct care. They have signed a confidentiality agreement as part of their employment.

This privacy policy will inform you as to how we ( me and my staff ) look after your personal data and sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. The terms set out in this privacy policy are available on my website, >www.drgafzal.com, referred to as the “Site”.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

Alexander Salem is the data control Officer and responsible for your personal data. He is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact him on 07967250876.

This policy is updated from time to time. The latest version updated on 25th May 2018 is published on the website. All updated versions of the policy will be published on this page of the Site.

Information we (my staff, myself) may collect from you:

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). When you visit my WebSite or correspond with us by phone, e-mail or otherwise you may give us information that would be classed as personal data about you and others you are acting on behalf of. We may collect, use, store and transfer different kinds of personal data about you when you do so which we have grouped together as follows:

a. Identifying Data which includes the referred young person’s first name, last name, username or similar identifier, date of birth and gender, parents’ names, marital status, title, their addresses if different than the young person’s.

b. Contact Data which includes your billing address, home address, email address and telephone numbers.

c. Health Data which includes any information about your health including your medical history and/or current health status including but not limited to data regarding test results, diagnoses and medications.

d. Financial Data which includes your bank account and payment card details, it is not stored after a given transaction is completed.

e. Insurance details & Transaction Data includes details about payments from you

f. Communications Data which includes your preferences in communication.

Except for data about your health, and the above-mentioned items (a to f), I do not collect any Special Categories of Personal Data (as defined in GDPR) about you. This includes details about your race or ethnicity, religious or philosophical beliefs, sex life or sexual orientation (unless as part of your health data), political opinions, or trade union membership. Nor do I collect any information about criminal convictions and offences.

Where we need to collect personal data under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter with you (for example, to provide you services). In this case, we may have to cancel our contract you have with us, but we will notify you if this is the case at the time.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your work with us.


Keeping your data secure

We know that data security is important to you and it is therefore important to us. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, I limit access to your personal data, except on an as needed basis to my staff, they will only process your personal data on my instructions in accordance with this policy and they are subject to a duty of confidentiality. If you give permission, we will send information to other third parties, i.e. insurance companies ,who have a business need to know.

Your data will be stored in a locked filing cabinet in my office which stays locked when not in use, and in my computer (desk top and lap top), which is secure /protected, or as a password protected file in a secure dropbox.

I will be utilising an external secretary who will temporarily have access to dictation and letter typed from the dictation regarding your care. These files will be deleted from that secretary’s system once posted or e-mailed to people you consent to having a copy, such as your GP. Copies of the letters will remain in the drop box.

My secretary will retain your payment details, such as insurance company policy numbers, until you are discharged from my care.

You will be asked to sign a consent form at your first appointment to allow me to process your data in this manner and to confirm whether you wish me to utilise e-mail to communicate with you rather than post.

If we post letters with your identifiable information to you, or your GP, it will be sent by recorded mail.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.


How we will collect your data

We use different methods to collect data from and about you including through:

a. Direct interactions.
You may give us any of the categories of data identified above by filling in registration forms or by corresponding with us by phone, e-mail or otherwise. This includes personal data you provide when you:
● register to use our service;
● make a request for our services;
● give us feedback.

b. Automated technologies:
We do not use cookies on our web site

c. Third parties Contact, Financial and Transaction Data (if applicable)
from providers of technical, payment and delivery services i.e. your bank account, credit card details. We don’t store that data after the transaction is completed.

Why we will use your data
The lawful bases for processing personal data are set out in Article 6 of the General Data Protection Regulation (GDPR). We may process your personal data on more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below. At least one of these must apply whenever we process personal data:

a. Consent:
you have given clear consent for us to process your personal data for a specific purpose i.e. identification , communication , treatment record , payment.

b. Contract:
the processing is necessary for the contract we have with you (for example, to deliver health related services to you and to manage our relationship with you),

c. Legal obligation:
the processing is necessary for us to comply with a legal or regulatory obligation (not including contractual obligations).

d. Vital interests:
the processing is necessary to protect someone’s health.  We also need to satisfy specific conditions for using your health data. We rely upon the following ground in this regard:

e. Healthcare provision:
the processing of data concerning your health is necessary for us to provide you with a medical diagnosis and/or healthcare treatment.

Click here to find out more on the Information Commissioner’s Office website about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data other than as described below. However, where we do ask for your consent (for example in processing data relating to your health) we will do so in order to comply with the principle that any processing must be lawful, fair and transparent.
Please see our terms and conditions for more information on this.

Disclosing your personal data
We may have to share your personal data with the parties below in order to provide our services to you. We require all third parties to respect the security of your personal data and to treat it in accordance with the law, and when they are processing personal data on our behalf we do not allow the third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. Examples of our third parties include:

a. Psychologists, Therapists, Educationists, Nutritionists, GP Practice, Other medical specialists for the performance of any service we request from them for you with your agreement;

b. Your Insurance Provider , with your consent

c. Our Data Processor is PPS, it provides IT and system administration services.

We do not transfer your personal data outside the European Economic Area (EEA).


Cookies

We do not use cookies to record your visits to our website


Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

How long we will keep your data
We will retain your data for 26 years, as required by law for psychiatric records In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the link below to access the Information Commissioner’s Office website to find out more about these rights:

a. Request access to your personal data.

b. Request correction of your personal data, corrections are made, notes on why the corrections were made are kept in the record

c. Complete erasure of Health Data is not allowed.

d. Object to processing of your personal data.

e. Request restriction of processing your personal data.

f. Request transfer of your personal data.

g. Right to withdraw consent.

If you wish to exercise any of the rights set out above, please Contact us. If you are unhappy with how we are processing your personal data, you have the right to complaint to the Information Commissioner Officer.

The Information Commissioner can be contacted at:

Wycliffe House,
Water Lane,
Wilmslow,
Cheshire
SK9 5AF
https://ico.org.uk/concerns/

No fee required 
You will not have to pay a fee to access your personal data (or to exercise any of the other rights).

What we may need from you
 
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Parents of young persons under 10 can request information, unless the young person is Gillick Competent. The young person 13 and above, must provide consent for release of their information.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.