Personal data
The data we collect about you
Personal data means any information relating to an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
Personal data that we may collect, use, store, and share (where appropriate) about you includes, but is not limited to personal data
Data We may collect
Contact details
• Title, first name, surname, preferred name, address, post code, mobile number, alternate contact number, personal and work email addresses, GP contact details
• Characteristics information (such as gender, age and date of birth)
• National insurance number, NHS number, unique identification number
• Next of kin and their contact number, relationship to you and if they are a patient at the practice
• Occupation
Dental and health records
• Clinical records made by dentists and other dental professionals involved with your care and treatment
• Notes of conversations with you about your care
• Communication records with you such as letters and emails
• X-rays, clinical photographs, digital scans of your mouth and teeth, and study models
• Treatment plans and consent
• Correspondence from other health professionals or institutions involved in your care
• Medical and dental history
• Dates of your appointments and reminders
• Details of any complaints and/or feedback that you make and how these complaints were dealt with
Financial information
• Fees charged by us and the amounts you have paid
• Exemption details (NHS only)
Security Information
• CCTV images
Technical Data
Data about your use of a practice’s website:
• Internet Protocol (IP) address
• Login data
• Details about your browser
• Length of visit to pages on a website
• Page views and navigation paths
• Details about the number of times you use a website
• Time zone settings on the devices a patient uses to access a website, social media channels and patient portal
• Third party cookies which monitor activity throughout a website using third-party providers. Please note that you can always set your browser to only accept essential cookies
How your personal data is collected
We collect personal information about you from the following sources:
• You – when you enquire about our care and service; join a dental practice; register online; complete a registration or medical history form
• Another practitioner when they refer you for treatment at one of our practices. Occasionally patients are referred to us from other official sources such as NHS clinics or hospitals
• From another practice if it joins us
• Direct conversations, correspondence and interactions with patients or family members, assessments by professionals
involved in your care
• Data provided by financial institutions working in partnership with us
How we use your personal data
We need all the categories of information above primarily to allow us to perform our contract with you [*] and to enable us to comply with legal obligations [**]. In some cases, we may use your personal information to pursue legitimate interests [***], provided your interests and fundamental rights do not override those interests.
The situations in which we will process your personal information are listed below. We have indicated by asterisks the purpose or purposes for which we are processing or will process your personal data.
Where a legitimate interest is involved, we state what the legitimate interest is
We will only use your personal data when the law allows us to.
Most commonly, we will use the personal information we collect about you to:
• Maintain clinical records and provide dental treatment, prevention
and oral health advice [*] and [**]
• Refer you to other dentists or doctors and health professionals as required [***]
• Carry out financial transactions and for debt recovery [***]
• Send information to the General Dental Council or other authority as required by law [**]
• Communicate with you [***]:
• establish your preference for how we contact you about your dental care
• appointment reminders, treatment plans and estimates, changes to dental appointments and provision of dental
care at your practice
• with your next of kin in an emergency
• to inform you of products and services available at our practices
• conduct patient surveys or to find out if patients are happy with the treatment received in order to continually
improve the care and service a patient receives from us for quality control purposes
• Where we request your consent to the collection, processing and transfer of your personal data for a specific purpose e.g. to receive notifications, newsletters, surveys or marketing, you have the right to withdraw consent for that specific processing at any time.
To withdraw your consent, you should contact the practice manager in writing. Once we receive your notification that you
have withdrawn your consent, we will no longer process your information for the purpose or purposes that you originally
agreed to
• Analyze and understand the effectiveness of our marketing activities [***]
• Ensure your safety when you visit a dental practice where there is CCTV [***]
• Undertake dental research or dental education. We will discuss this with you and seek your consent. Depending on the purpose and if possible, we will anonymize your information. If this is not possible we will inform you and discuss your options [***]
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you, or we may be prevented from complying with our legal obligations.
We will only use your personal information 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 we need to use your personal information 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 information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
How we use particularly sensitive personal information
“Special categories” of particularly sensitive personal information, such as information about your health, racial or ethnic origin, require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.
We may process special categories of personal information in the following circumstances:
• In limited circumstances, with your explicit written consent
• Where we need to carry out our legal obligations or exercise rights in connection with employment
• Where it is needed in the public interest
• Where deemed necessary by us in accordance with the Law
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