This privacy notice explains why A&S collects information about you and how that information may be used.

Health care professionals who provide you with care maintain records about your health and any treatment or care you have received previously (e.g. NHS Trust, GP Surgery, Walk-in clinic, Dental hospital referrals etc). These records are used to help to provide you with the best possible healthcare.

NHS health care records may be electronic, on paper or a mixture of both, and we use a combination of working practices and technology to ensure that your information is kept confidential and secure. Records A&S hold about you may include the following information:

• Details about you, such as your name, address, carers, legal representative and emergency contact details. 
• Any contact the surgery has had with you, such as appointments, clinic visits, emergency appointments, etc.
• Notes and reports about your health
• Details about your treatment and care. Results of investigation such as radiographs etc.
• Relevant information from other health professionals, relatives or those who care for you. 
• To ensure you receive the best possible care, your records are used to facilitate the care you receive. Information held about you may be used to help protect the health of the public and to help us manage the NHS. Information may be used within A and S for clinical audit to monitor the quality of the service provided.

Some of this information will be held centrally and used for statistical purposes. Where we do this, we take strict measures to ensure that individual patients cannot be identified. Sometimes your information may be requested to be used to be used for research purposes- the surgery will always gain your consent before releasing the information for this purpose.

GDPR rules do not dictate how long we should keep personal data; It is up to each organisation to justify this, based on your purposes for processing. As the data which we hold is for healthcare purposes, we are required to keep patient records for a minimum of 11 years or in the case of a young person, until they reach the age of 25 years, whichever is the longest. 

We are committed to protecting your privacy and will only use information collected lawfully in accordance with:

• Data Protection Act 1998 and General Data Protection Regulations 2016
• Human Rights Act 1998
• Common Law Duty of Confidentiality
• Health and Social Care Act 2012
• NHS Codes of Confidentiality, Information Security and Records Management
• Information; To share or Not to Share Review

Every member of staff who works for an NHS organisation has a legal obligation to keep information about you confidential. 

We will only ever use or pass on information about you if others involved in your care have a genuine need for it, and this would only ever be for the purpose of your individual care. We will not disclose your information to any third party without your permission unless there are exceptional circumstances (i.e. life or death situations), where the law requires information to be passed on and / or in accordance with the new information sharing principle, following Dame Fiona Caldicott’s information sharing review (Information to share or not to share), where “The duty to share information can be as important as the duty to protect patient confidentiality.” This means that health and social care professionals should have the confidence to share information in the best interests of their patients within the framework set out by the Caldicott principles. They should be supported by the policies of their employers, regulators and professional bodies.

Our patients’ data may be used for in-house auditing and training purposes; however, data will always be anonymised I these instances and any information gathered will never be shared outside of the practice. This auditing forms a part of our quality assurance programme, which is required in line with certain legal regulations to which we are bound. We never gather or disclose data outside of the practice or our partner organisations for statistical purposes or otherwise; our data processing is purely for our patients’ individual care needs.

We may also have to share your information, subject to strict agreements on how it will be used, with the following organisations:

• NHS Trusts / Foundation Trusts
• GP’s
• NHS Commissioning Support Units
• Clinical Commissioning Groups
• Social Care Services
• Health and Social Care Information Centre (HSCIC)
• Local Authorities
• Education Services
• Fire and Rescue Services
• Police & Judicial Services
• Voluntary Sector Providers
• Private Sector Providers
• Other ‘data processors’ which you will be informed of.

You will be informed who your data will be shared with and in some cases asked for explicit consent for this to happen when this is required.

We may also use external companies to process personal information, such as for archiving purposes. These companies are bound by contractual agreements to ensure information is kept confidential and secure and they do not have any right to disclose your data elsewhere.

You have a right under the Data Protection Act 1998 and The General Data Protection Regulations to request access to view or to obtain copies of what information the surgery holds about you and to have it amended should be it be inaccurate. In order to request this, you need to do the following:

• Your request must be made in writing by letter or email to A&S Dental Surgeons LTD
• Your letter of request must be signed by the patient wishing to access a copy of their records. You will be provided with your data within 1 month of the request. You may also request an explanation of your records/data if you fell you may require it.
• We will not charge a fee for copies of patients’ personal data unless the request is ‘manifestly unfounded or excessive’. The data controller may charge a reasonable administrative-cost fee if further copies are requested.
• If a request is ‘manifestly unfounded or excessive’ data controllers can charge a fee or refuse to respond but will need to be able to provide evidence of how the conclusion that the request is manifestly unfounded or excessive was reached.
• We are required to respond to you within one month of receipt of your request.
• You will need to give adequate information (for example full name, address, date of birth, NHS number and details of your request) so that your identity can be verified and your records located.

Should you have any concerns about how your information is managed at A&S Dental Surgeons LTD, please contact the practice manager. If you are still unhappy following a review by A&S, you can complain to the Information Commissioners Office (ICO) via their website (www.ico.gov.uk).

If you are happy for your data to be extracted and used for the purposes described in this privacy notice then you do not need to do anything. If you have any concerns about how your data is shared then please contact the practice.

It is important that you tell reception if any of your details, such as your name, address or date of birth have changed in order for this to be amended. You have a responsibility to inform us of any changes so our records are accurate and up to date for you.

The Data Protection Act 1998 requires organisations to register a notification with the Information Commissioner to describe the purpose for which they process personal and sensitive information.

This information is publicly available on the Information Commissioners Office website: www.ico.org.uk

The practice is registered with the Information Commissioners Office (ICO).

A&S Dental Surgeons has a telephone system that automatically records all conversations. Like many other organisations, this is a standard practice that allows the recording of telephone calls for quality monitoring, training, compliance and security purposes.

Purpose of this telephone recording policy

In order to maintain high standards and protect the public, staff and associates we need to record all telephone calls received into the business and retain them for future reference.

We shall ensure that the use of these recordings is fair and that we comply with the requirements of the relevant legislation.

This includes:

•   The Regulation of Investigatory Powers Act 2000;

•   The Telecommunications (Lawful Business Practice) (Interception of Communications Regulations) 2000;

•    Communications Act 2003;

•    General Data Protection Regulation and Data Protection Act 2018;

•    The Human Rights Act 1998.

Scope of policy

Under normal circumstances a call will not be retrieved or monitored unless:

•   It is necessary to investigate a complaint;

•   It is part of a management ‘spot check’ that customer service standards are being met;

•   There is a threat to the health and safety of staff or visitors or for the prevention or detection of crime;

•   It is necessary to check compliance with regulatory procedures; or

•   It will aid standards in call handling through use in training and coaching our staff. However, this will only be permitted if the recording is edited so that the caller remains anonymous and the member of staff who was party to the call agrees to its being used in this way.

Collecting information

Personal data collected during recording activities will be processed fairly and lawfully in accordance with the General Data Protection Regulation and Data Protection Act 2018.

It will be:

•   Adequate, relevant and not excessive;

•   Used for the purpose(s) stated in this policy only and not used for any other purposes;

•   Accessible only to managerial staff after securing permission from the Managing Director;

•   Treated confidentially;

•   Stored securely;

•   Not kept for longer than necessary and will be securely destroyed once the issue(s) in question have been resolved.

•   Advising callers that calls are being monitored/recorded

Subject Access Requests (SAR)

Subject Access Requests can be made in writing or via email (management@aandsdental.co.uk) by a patient to have access to their telephone calls, if available, it should be noted that recordings are only kept for 3 months. 

Access to the recordings is only allowed to satisfy a clearly defined business need and reasons for requesting access must be formally authorised only by the manager/s. All requests for call recordings should include the following:

• The valid reason for the request

• Date and time of the call if known

• Telephone extension used to make/receive the call

• External number involved if known

• Where possible, the names of all parties to the telephone call

• Any other information on the nature of the call

Complex:

2x 30min @ £60.00 each

2x 40min @ £80.00 each

2x 30min @ £60.00 each

Over 3-month period

Hamera Kauser & Sarah Berry

Practice Managers

Should you have any concerns about how your information is managed by the practice please contact the Practice Managers at the following address:

A and S Dental Surgeons LTD

65 Duckworth Lane

Bradford, West Yorkshire 

BD9 5EU

If you are still unhappy following a review by the Practice you can then complain to the Information Commissioners Office (ICO):

• Website: www.ico.org.uk
• Emails: casework@ico.org.uk,
• Telephone: 0303 123 1113 (local rate) or 01625 545 745