Pro-Physio Health Ltd - Privacy and cookies policy
1.1 We are committed to safeguarding the privacy of our website visitors and service users in this policy we explain how we will handle your personal data.
1.3 Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information. You can access the privacy controls via www.prophysiohealth.co.uk
How we use your personal data
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) In the case of personal data that we did not obtain directly from you, the source and specific categories of that data
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
2.2 We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is consent
2.3 We may process your account data (“account data“).The account data may include your name and email address. The source of the account data is you or your referrer .The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent.
2.4 We may process your information included in your personal profile on our website (“profile data“).The profile data may include your name, address, telephone number, email address, gender and date of birth. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is consent.
2.5 We may process your personal data that you or your referrer provided in the course of the use of our services (“service data“).The service data may include medical history and referral source. The source of the service data is you or your referrer The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent
2.6 We may process information that you post for publication on our website or through our services (“publication data“). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent
2.7 We may process information contained in any enquiry you submit to us regarding products and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services to you. The legal basis for this processing is consent.
2.8 We may process information relating to transactions, including purchases of goods and services, that you enter into with us such as Physiotherapy treatment or Physiotherapy products (“transaction data“).The transaction data may include your contact details, your card and Bank details and the transaction details. This does not happen on our web site but via our PDQ Barclays machine at the Fairlands Medical Centre or via bank transfers. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and Pro-Physio Health Ltd and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.
2.9 We may process information that you provide to us for the purpose of subscribing to our email notifications (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications. The legal basis for this processing is consent
2.10 We may process information contained in or relating to any communication that you or your referrer send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
2.11 This data may be processed for record keeping and audit. The legal basis for this processing is consent
2.12 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
2.13 Please do not supply any other person’s personal data to us, unless we prompt you to do so or you are a parent or guardian of a minor
3.1 We do not carry out automated decision making or profiling
Providing your personal data to others
4.1 We may disclose your personal data to our insurers and/or professional advisers in so far as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.
4.2 Financial transactions for our services may be handled by our payment services providers, HSBC and Barclays. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds..
4.3 In addition to the specific disclosures of personal data set out in this Section 4, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
4.4 Pro-Physio Health Ltd agree to supply access to your medical records on receipt of a signed and dated request
International transfers of your personal data
5.1 We do not transfer personal data to countries outside the European Economic Area (EEA).
5.2 Our facilities (treatment rooms) are in the UK. In the future we may add additional offices. The European Commission has made an “adequacy decision” with respect to the data protection laws of the UK. Transfers to other countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission OR the use of binding corporate rules.
5.3 The hosting facilities for our website are situated in the UK. The European Commission has made an “adequacy decision” with respect to the data protection laws of the UK. Transfers to other countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.
5.4 All our marketing and sales are currently situated in the UK. The European Commission has made an “adequacy decision” with respect to the data protection laws of the UK. Transfers to other countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.
5.5 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
Retaining and deleting personal data
6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary or as directed by our Professional body, The Chartered Society of Physiotherapists and the legal requirements required for holding personal data.
6.3 We will retain and delete your personal data as follows:
(a) personal data category information will be retained for , adults 6 years, children 10 years following assessment or initial contact at the end of which period it will be deleted from our systems.
6.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
(a) the period of retention of personal data will be determined based by the legal requirement of medical record keeping, currently 8 years for adult records and 25 years for minors. This will be updated as further information is issued by ICO.
6.5 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
7.1 We may update this policy from time to time by publishing a new version on our website.
7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
7.3 We may notify you of changes to this policy by email
8.1 You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:
(a) No payment fee
(b) the supply of appropriate evidence of your identity for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address.
8.2 We may withhold personal information that you request to the extent permitted by law.
8.3 You may instruct us at any time not to process your personal information.
8.4 In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.
8.1 In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
8.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
8.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
8.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
8.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
8.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
8.8 You have the right to object to our processing of your personal data for direct marketing purposes. If you make such an objection, we will cease to process your personal data for this purpose.
8.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
8.10 To the extent that the legal basis for our processing of your personal data is consent, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
8.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
8.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
8.13 You may exercise any of your rights in relation to your personal data by written notice to us in addition to the other methods specified in this Section 8.
Third party websites
9.1 Our website may include hyperlinks to, and details of, third party websites including TM3 which is our on-line clinical software which stores personal data, treatment records and invoicing/accountancy records. TM3 is GDPR compliant and for any further information on our use of TM3 please visit: https://www.tm3practicemanagement.com/contact-us/
9.2 We have no control over and are not responsible for, the privacy policies and practices of third parties.
Personal data of children
10.1 Our website and services are targeted at persons over the age of 16, services are provided for Minors with parental consent
10.2 If we have reason to believe that we hold personal data of a person under that age in our databases, without parental or guardian consent this information will be deleted at your request.
11.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
Acting as a data Controller
12.1 In respect of personal data, we do not act as a data processor; instead, we act as a data controller.
13.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
13.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
13.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
Cookies that we use
16.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can, however, obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
16.2 Blocking all cookies will have a negative impact upon the usability of many websites.
16.3 If you block cookies, you will not be able to use all the features on our website.
18.1 This website is owned and operated by Pro-Physio Health Ltd (Companies House: 9949215)
18.2 We are registered in England and Wales and our registered office is at Fairlands Medical Centre, Guildford, Surrey, GU3
18.3 Our principal place of business is at Fairlands Medical Centre, Guildford, Surrey, GU3 3NA and West Byfleet Health Centre, Madeira Road, West Byfleet, KT14 6DH
18.4 You can contact us:
(a) by post, using the registered office address given above.
(b) using our website contact form
(c) by telephone, on the contact number published on our website from time to time
(d) by email, using the email address published on our website from time to time.
Data protection officer
19.1 Our data protection officer’s contact details are: Nick Varns (Senior Physiotherapist and Director) firstname.lastname@example.org