Privacy Policy
In accordance with the General Data Protection Regulation (GDPR), we have implemented this privacy notice to inform you, our clients, of the types of data we process about you. We also include within this notice the reasons for processing your data, the lawful basis that permits us to process it, how long we keep your data for and your rights regarding your data. This notice applies to any data subjects/clients.
A. Data protection principles
Under GDPR, all personal data obtained and held by us must be processed according to a set of core principles. In accordance with these principles, we will ensure that: a) processing is fair, lawful and transparent b) data is collected for specific, explicit, and legitimate purposes c) data collected is adequate, relevant and limited to what is necessary for the purposes of processing d) data is kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without delay e) data is not kept for longer than is necessary for its given purpose f) data is processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures g) we comply with the relevant GDPR procedures for international transferring of personal data.
B. Types of data held
We keep several categories of personal data on our clients/data subjects in order to carry out effective and efficient processes. We keep this data in our software database relating to each client/data subject and we also hold the data within all Debbie Thomas Ltd computer portals which are relevant to your treatment.
Specifically, we hold the following types of data, as appropriate to your status: a) personal details such as name, address, phone numbers b) emergency contact details of a family member or friend c) your photograph d) your gender e) medical information f) CCTV footage.
C. Collecting your data
You provide several pieces of data to us directly on each appointment that you attend including consultations.
Personal data is kept in our software database, in your client profile that is set up when you make your first booking, including a consultation. If you are aged 16 or under, please get your parent/guardian’s permission before you provide any personal information to us. Users of this nature and without this consent are not allowed to provide us with personal information.
D. Lawful basis for processing
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The law on data protection allows us to process your data for certain reasons only. In the main, we process your data in order to comply with a legal requirement or in order to effectively manage your treatment plans with the clinic.
The information below categorises the types of data processing, appropriate to your status, we undertake and the lawful basis we rely on.
Activity requiring your data/lawful basis
Making reasonable adjustments for disabled data subjects/Legal obligation.
Maintaining comprehensive up to date personal records about you to ensure, amongst other things, effective correspondence can be achieved and appropriate contact points in the event of an emergency are maintained/Our legitimate interests.
Gaining expert medical opinion when making decisions about your treatment plan, if needed/Our legitimate interests
Dealing with legal claims made against us/Our legitimate interests.
Preventing fraud/Our legitimate interests.
Ensuring our administrative and IT systems are secure and robust against unauthorised access/ Our legitimate interests.
E. Special categories of data
Special categories of data are data relating to your: a) health.
We carry out processing activities using special category data:
a) to determine reasonable adjustments that may be needed.
Most commonly, we will process special categories of data when the following applies:
a) you have given explicit consent to the processing
b) we must process the data in order to carry out our legal obligations
c) we must process data for reasons of substantial public interest
d) you have already made the data public.
F. Failure to provide data
Your failure to provide us with data may mean that we are unable to fulfil our requirements for entering into a contract with you, this contract enables us to proceed with treatments.
G. Protecting your data
We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such.
H. Retention periods
We only keep your data for as long as we need it for, which will be at least for the duration of your time with us a client, with us though in most/all cases we will keep your data as long as necessary and potentially after you no longer visit the clinic, in order that should you return as a client in the future, we have a history of your treatments. Some data retention periods are set by the law. Our retention periods are: Retention periods can vary depending on why we need your data, as set out below:
I) Automated decision making
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Automated decision making means making decision about you using no human involvement e.g. using computerised filtering equipment. No decision will be made about you solely on the basis of automated decision making (where a decision is taken about you using an electronic system without human involvement) which has a significant impact on you.
J. Client/data subject rights
You have the following rights in relation to the personal data we hold on you:
a) the right to be informed about the data we hold on you and what we do with it;
b) the right of access to the data we hold on you. More information on this can be found in our separate policy on Subject Access Requests;
c) the right for any inaccuracies in the data we hold on you, however they come to light, to be corrected. This is also known as ‘rectification’;
d) the right to have data deleted in certain circumstances. This is also known as ‘erasure’;
e) the right to restrict the processing of the data;
f) the right to transfer the data we hold on you to another party. This is also known as ‘portability’; g) the right to object to the inclusion of any information;
h) the right to regulate any automated decision-making and profiling of personal data.
K. Consent
Where you have provided consent to our use of your data, you also have the right to withdraw that consent at any time. This means that we will stop processing your data.
L. Making a complaint
If you think your data subject rights have been breached, you are able to raise a complaint with the Information Commissioner (ICO).
You can contact the ICO at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF or by telephone on 03031 231113 (local rate) or 01625 545745.
M. Data protection compliance
Our Data Protection Officer is: Jo Kaleta, Operations Director, Tephone 020 7118 9000, Debbie Thomas Ltd, 25 Walton Street, London SW3 2HU.
Cookies Policy
Most websites you visit will use cookies in order to improve your user experience, by enabling that website to ‘remember’ you, either for the duration of your visit (using a ‘session cookie’) or for repeat visits (using a ‘persistent cookie’). Most cookies are harmless and are purely designed and installed to help your online experience.
Some people find the idea of a website storing information on their computer or mobile device a bit intrusive, particularly when this information is stored and used by a third party without them knowing. Although this is generally quite harmless, if you prefer, it is possible to block some or all cookies, or even to delete cookies that have already been set; but you need to be aware that you might lose some functionality for those websites where you do this.
If you don’t want to receive cookies, you can modify your browser so that it notifies you when cookies are sent to it, or you can refuse cookies altogether. You can also delete cookies that have already been set.
If you wish to restrict or block web browser cookies which are set on your device, then you can do this through your browser settings; the Help function within your browser should tell you how to do this.
A cookie is a simple text file that is stored on your computer or mobile device by a website’s server. Only that server will be able to retrieve or read the contents of that cookie. Each cookie is also unique to each of your web browsers. The cookie will contain anonymous information, such as a unique identifier and the site name and some digits and numbers.
Cookies do lots of different jobs, like letting you navigate between pages efficiently, and generally improving your experience of a website. Cookies make the interaction between you and the website faster and easier. If a website doesn’t use cookies, it will think you are a new visitor every time you move to a new page on the site, and this can lead to slower page load times.
Cookies may be set by the website you are visiting (‘first party cookies’) or they may be set by other websites who run content on the page you are viewing (‘third party cookies’).
First party cookies are set by the website you are visiting, and they can only be read by that site. Third party cookies are set by a different organisation to the owner of the website you are visiting. For example, like many other website owners, we use an analytics tool from Google, which allows us to view general information about how users interact with our website. We use this information to improve the online experience for our website visitors.
The website you are visiting may also contain content embedded from external social media websites and these sites may also set their own cookies. We plan to introduce various social media onto our website – such as, for example; YouTube, Facebook, LinkedIn, Pinterest, Google + and Twitter – in future. Their respective use of cookies will not affect you unless you click on their respective icons/links.
The website you are visiting may also have links to other third party websites. We may introduce links on our page to other websites. Please note that our cookies policy only relates to the cookies that are found on our website, and that the management of other websites is outside of our control. However, we will make reasonable attempts to ensure that we are not directing you to visit websites that might use cookies in a disreputable fashion. It is your responsibility to read the cookies policy for every website you visit if you wish to understand how each intends to use them.
Some websites also use cookies to enable them to target advertising or marketing messages based, for example, on your location and/or browsing habits. We do not use these types of cookies on our website.
Session cookies are stored only temporarily during a browsing session and are deleted from the user’s device when the browser is closed.
Persistent cookies are saved on your computer for a fixed period (usually a year or longer) and are not deleted when the browser is closed. Persistent cookies are used where we need to know who you are for more than one browsing session.
The Information Commissioner’s Office is the UK’s independent authority set up to uphold information rights in the public interest, promoting openness by public bodies and data privacy for individuals. If you are interested in finding out more about guidance and best practice with regards to the use of cookies on websites, please visit their website at www.ico.org.uk
Alternatively, you may wish to visit www.aboutcookies.org which contains comprehensive information on how to manage cookies for a wide variety of desktop browsers.
We also recommend that our website users visit the BBC cookies web page. You will find a lot of useful information at www.bbc.co.uk/privacy/cookies
We welcome feedback from our users: please contact info@dthomas.com with any helpful comments and criticisms. We will use this information to help us to improve the way we use cookies on our website for the benefit of all users.
