Privacy Policy

Forever Dental and Skin – Privacy Policy

Welcome to BD Care Limited (trading as Forever Dental and Skin)’s privacy policy.

Forever Dental and Skin respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our practice and the practice website and tell you about your privacy rights and how the law protects you.

  1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Forever Dental and Skin collects and processes your personal data, including any data you may provide through this website when you subscribe to one of our membership plans. This Privacy Notice is available on the practice website at www.foreverdentalandskin.co.uk, at reception and by email if you contact info@foreverdentalandskin.co.uk.  

We have a separate privacy policy for children – please refer to our Privacy Notice for Children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

Murray Pratt is the controller and responsible for your personal data.

Astrid Pratt is the Information Governance Lead and 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 Astrid Pratt using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact Astrid Pratt, our Information Governance Lead, in the following ways:

Full name of legal entity: BD Care Limited (trading as Forever Dental and Skin)

Email address: info@foreverdentalandskin.co.uk

Postal address: 68 The Street, Ashtead, Surrey, KT21 1AW

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 2 August 2019.

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 relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

  1. The data we collect about 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).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Contact data (such as first name, last name, marital status, date of birth, gender, address, email address and telephone number) for the purposes of: (i) corresponding with you (for example, regarding your appointments and treatment); and (ii) for the purposes of direct mail/email/text/marketing.
  • Special category data concerning health (including health records, medical history, medication, your doctor’s name and address, warning cards or bracelets, alcohol and drug use) for the purposes of the delivery of safe health care and meeting our legal obligations.
  • Treatment data (such as photos, moulds, X-rays, clinical findings) for the purposes of providing you with the best treatment.
  • Financial data (such as credit card details, bank account information, credit history, employment status) for the purposes of processing your payment for treatment(s).
  • Transaction data (such as details about payments to and from you and other details of products and services you have purchased from us).
  • Technical data (such as internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website).
  • Usage data (such as information about how you use our website, products and services) for the purposes of improving the way we provide our treatment and services.
  • Marketing and communications data (such as your preferences in receiving marketing from us and our third parties and your communication preferences) for the purposes of direct mail/email/text/marketing.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

If you fail to provide personal data

Where we need to collect personal data by law, or 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 into with you (for example, to enable you to subscribe to a membership plan). In this case, we may have to cancel your subscription request, but we will notify you if this is the case at the time.

  1. How is your personal data collected?

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

  • Direct interactions. This includes information you give us (including information you give to our Clinical Lead, Specialists, Dentists, Hygienists and Therapists who are contracted to work for us). You may give us information about you by filling in forms on our website www.foreverdentalandskin.co.uk or any website wholly owned by Forever Dental and Skin, or by corresponding with us by phone, email, in person or otherwise.
  • Personal data is obtained when a patient joins the practice, when a patient is referred to the practice and when a patient subscribes to an email list, and is updated each time an existing patient visits the practice.
  • Automated technologies or interactions. This includes information we automatically collect about you. With regard to each of your visits to our website we may automatically collect technical data about your equipment, browsing actions and patterns and your usage data (as described above). We collect this personal data by using cookies and other similar technologies. Please see our cookies policy [LINK] for further details.
  • Third parties or publicly available sources.
    • Our Clinical Lead, Specialists, Dentists, Hygienists and Therapists are third parties working for us as contractors, however, they are contractually bound to us with regard to obligations of confidentiality in the same way as our employees and by professional obligations of confidentiality.
    • You may have been referred to us for treatment from third parties (e.g. Invisalign) and we will therefore receive contact data, special category data concerning health, treatment data and/or financial data from them.
    • We are also working closely with third parties (including, for example, business partners, subcontractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
    • We use third-party analytics services (such as Google Analytics) to evaluate your use of the website, compile reports on activity, collect demographic data, analyse performance metrics, and collect and evaluate other information relating to our website and internet usage. These third parties use cookies and other technologies to help analyse and provide us with data.
  1. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Performance of a contract. Where we need to process your data to perform the contract we are about to enter into or have entered into with you or to take steps at your request before entering into such a contract.
  • Where you have given your consent for us to process your data for one or more specific purposes (e.g. through the Communication Consent Form or the Consent for Clinical Photography Form). You have the right to withdraw consent at any time by contacting us.
  • Legitimate interest. Where we need to process your data for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Our legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests.
  • Compliance with a legal obligation. Where we need to process your personal data to comply with a legal obligation that we are subject to.

For consent relating to children and people who may not have mental capacity to give consent, please contact us using the details above for a copy of our Children and Adults at Risk Safeguarding Policy.

The reason for processing special category data such as patients’ health data is:

  • The processing is necessary for the purposes of preventative or occupational medicine, for assessing the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or management of health or social care systems and services on the basis of Union or Member State law or a contract with a health professional; and
  • Data is processed by or under the responsibility of a professional subject to the obligation of professional secrecy under Union or Member State law or rules established by national competent bodies or by another person also subject to an obligation of secrecy under Union or Member State law or rules established by national competent bodies.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for 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 in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new patient, discuss relevant treatments and provide you with our services

(a) Contact

(b) Special category

(c) Treatment

Performance of a contract with you

To check your employment and financial status for payment plans

(a) Contact

(b) Financial

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To process payments

(a) Contact

(b) Financial

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Keeping you informed of our latest offers and other services we provide

(c) To obtain reviews and feedback on your experience of our services

(a) Contact

(b) Special category

(c) Marketing and communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

(d) Consent

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) 

(a) Contact

(b) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Contact

(b) Special category

(c) Treatment

(d) Technical

(e) Usage

(f) Marketing and Communications

(a) Necessary for our legitimate interests (to study how patients use our products/services, to develop them, to grow our business and to inform our marketing strategy)

(b) Consent

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of patients for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Marketing by us

We offer individuals real choice and control. Our consent procedures put individuals in charge to build customer trust and engagement.

Our consent for marketing requires a positive opt-in, we don’t use pre-ticked boxes or any other method of default consent. We make it easy for people to withdraw consent, tell you how to and keep contemporaneous evidence of consent. Consent to marketing is never a precondition of a service.

You will receive marketing communications from us if you have requested information from us, if you have signed up via our contact form on the website or if you have signed a Communication Consent Form and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us and used by us for the purposes  of communicating with you relating to your appointments or treatment, and you will continue to receive messages about your appointments and treatment from us in accordance with your instructions on your Communication Consent Form.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookies Policy [LINK TO YOUR COOKIE POLICY].

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 using the details set out above.

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.

  1. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.

  • Our Clinical Lead, Specialists, Dentists, Hygienists and Therapists.
  • Private health insurance companies (at your request if you are using private health insurance).
  • Credit reference agencies.
  • Equipment providers and laboratories such as Align Tech, Nimrodental, Crown 24, Ken Poland, Schreiber & Low, Harley Dental Lab and Cosmetic Ceramics.
  • Accountants, lawyers and other professional advisers.
  • Professional compliance organisations such as CODE and iComply.
  • Data transfer platforms such as Dropbox and WeTransfer.
  • Our online payment platform Stripe.
  • Our telephone system provider BT.
  • Our website host 1&1.
  • Our practice management and CRM software provider Software of Excellence.
  • Our email marketing provider MailChimp.
  • Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others such as Facebook.
  • Analytics and search engine providers that assist us in the improvement and optimisation of our site such as Google.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our 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.

If we intend to refer a patient to another practitioner or to secondary care such as a hospital we will gain your consent before the referral is made and the personal data is shared.

  1. Data transferred outside the EU

Personal data is stored in the EU whether in digital or hard copy format.

Personal data is stored in the US in digital format when the data storage company is certified with the EU-US Privacy Shield.

  1. Data security

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, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

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.

  1. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

The retention period for special category data in patient records is a minimum of 10 years and may be longer for complex records in order to meet our legal requirements. The retention periods for other personal data is two years after it was last processed.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we will 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.

  1. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. In particular, you have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we will not be able to provide you with the services. You have the right to obtain a free copy of your patient records within one month of submitting a request.

If you are not a patient of the practice you have the right to withdraw consent for processing personal data, to have a free copy of it within one month of submitting a request, to correct errors in it or to ask us to delete it. You can also withdraw consent from communication methods such as telephone, email or text.

If you wish to exercise any of the rights set out above, please contact us using the details set out above.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

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.

Time limit to respond

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

Related practice procedures

You can also request copies of the following practice policies or procedures:

  • Data Protection and Information Security Policy (M 233-DPT), Consent Policy (M 233-CNS)
  • Privacy Impact Assessment (M 217Q), Information Governance Procedures (M 217C), Record Retention (M 215)