Privacy Policy

Last updated: September 28, 2023

Woodside Dental Practice processes personal data that relate to patients and is therefore required by law to comply with the General Data Protection Regulations (GDPR), which protects the privacy of individual personal data and ensures that they are processed fairly and lawfully. 

The Practice is committed to ensuring that it complies with the GDPR and applies ethical principles to all aspects of its work to protect the interests of employees and patients and maintain the confidentiality and security of any personal data held in any form by the practice. 

Data Protection Principles

To do this, Woodside Dental Practice will comply with the eight data protection principles. In summary, these state that personal data shall be:

  • Fairly and lawfully processed;
  • Processed for limited purposes (i.e. obtained only for specified and lawful purposes and further processed only in a compatible manner);
  • Adequate, relevant and not excessive;
  • Accurate and up to date;
  • Not kept for longer than is necessary;
  • Processed in line with the individual’s rights;
  • Secure;
  • Not transferred to countries outside the EU without adequate protection.

We also recognise the rights of individuals under GDPR:

  • The right to be informed
  • The right of access
  • The right to rectification
  • The right to erasure
  • The right to restrict processing
  • The right to data portability
  • The right to object
  • Rights in relation to automated decision making and profiling

Who is responsible?

This Data Protection, Confidentiality and Information Security Policy applies to all practice employees and any others who have legitimate rights to access and use the practice’s information systems. 

Compliance with the GDPR and this policy is the responsibility of all practice employees and everyone who has access to practice records. A breach of this policy, whether deliberate or through negligence, could lead to disciplinary action being taken and possible investigation by the General Dental Council. A breach of the GDPR could also lead to criminal prosecution. 

The following table lists key responsibilities among the dental team 

Dental Team Member  Responsibility
Lynn Mann
(Practice Manager and Data Protection Officer)
Data Protection, Confidentiality and Information Security policy; deals with subject access requests made under the GDPR and requests made under the Freedom of Information Act (Scotland) 2002; training of staff regarding data protection and confidentiality
Jonathan McLean  Data controller (i.e. principal dentist who ‘owns’ a patient list)
All staff Compliance with the GDPR and this Data Protection, Confidentiality and Information Security policy

If you have any questions or comments about processing personal data or this policy, please contact the Practice Manager. 

What type of information do we hold?

To provide effective care for patients and provide care within the NHS system, the Practice processes personal data of patients. Personal data means practically any information about, or correspondence relating to, a named individual. It includes both facts (e.g. treatment a patient has had) and opinions (e.g. any concerns the patient or dental team might have about the patient’s dental health), including [amend, as appropriate]:

  • Personal information and contact details, including the patient’s name, address and date of birth;
  • Dental, social and medical histories (e.g. past or current medical conditions, current medication, the name of the patient’s GP, special needs);
  • Results of the examination of the patient’s mouth and oral health, including x-rays and clinical photographs;
  • Information about appointments;
  • Any treatments and their costs;
  • Any proposed care, including advice given to the patient and referrals the patient might need;
  • Any concerns that the patient or dental team might have;
  • Details of the patient’s consent for specific procedures;
  • Correspondence with other healthcare workers that relates to the patient’s care.

What procedures do we use to ensure your data is handled correctly?

To maintain a good patient–dental team relationship, it is essential that patients feel they can provide personal information to dental team members with the knowledge that this information will be kept securely and not shared unlawfully. It is also important that patients are able to provide, in confidence, full details of their medical, social and dental histories to facilitate safe and effective care. To achieve this, all staff must follow the procedures listed below.

  • Comply with the 8 data protection principles and the General Dental Council principles set out in the ‘Standards for the Dental Team’.
  • Undergo training in processing personal data and confidentiality.
  • Keep any personal data or confidential data that they hold, whether in electronic or paper format, securely, which includes:
  • Storing paper files with personal data in lockable filing cabinets that are locked when authorised staff are not present to monitor access;
  • Storing electronic files containing personal data on password-protected computer systems;
  • ‘Screen-locking’ unattended computers;
  • Not sharing computer passwords with unauthorised people, not writing down passwords and not keeping passwords on or near their computer;
  • Not forwarding emails containing personal data to internet email accounts as these are not secure;
  • Holding personal data on laptops only where there is a clear business necessity and permission is sought from the Practice Manager (if there is a necessity, ensure it is fully encrypted);
  • Avoiding carrying personal data on removable media (e.g. memory sticks);
  • Not using unlicensed software on Practice computers;
  • Ensuring windows and doors are secured if you are the last to leave the practice.
  • Practice good record-keeping, and ensure records are: 
  • Accurate;
  • Dated;
  • Contemporaneous;
  • Comprehensive;
  • Secure;
  • Legible and written in language that can be read and understood by others, and is not derogatory.
  • Maintain the confidentiality of any personal data by, for example:
  • Ensuring that personal information is not disclosed either orally or in writing, accidentally or otherwise, to any unauthorised third party (e.g. avoid working on personal data such as application forms on public transport, do not discuss identifiable information about patients with anyone outside the practice, including friends, family and schools, or leave messages about a patient’s care with an unauthorised third party or on an answering machine) (NB: this also applies after termination of employment);
  • Respecting patient privacy for discussions of a sensitive nature (e.g. discussion of medical information, payment, or asking patients for proof of exemption status);
  • Using personal data only for the purposes for which they are authorised in the relevant Data Protection registration.
  • Ensure patients know what information is to be shared, why it is being shared and the likely consequences of sharing (or not sharing) the information, and give patients the opportunity to withhold permission to share their information.
  • Share personal data only on a ‘need to know’ basis and following consent from the patient; for example:
  • To another health professional for the provision of effective care and/or treatment;
  • To ensure the provision of care under the NHS (e.g. payment claims, information for health boards).
  • Check that any personal information that you provide in connection with your employment is accurate and up to date, and inform the Practice Manager of any changes to this information.
  • Inform the Practice Manager who is responsible for ensuring compliance with the GDPR and this policy, of any suspected or actual breach of the GDPR or this policy.

Data Controllers 

Data controllers are those who hold personal records (e.g. dentists who are the ‘owner’ of their own patient list). All data controllers must follow the procedures detailed above for staff, and the procedures listed below.

  • Register with the UK Information Commissioner.
  • Keep the details of the registration up to date and renew this registration annually.

Data Sharing

To provide patients with appropriate care, we might need to share personal data with:

  • Another dentist or another health professional who is caring for the patient;
  • The patient’s GP;
  • A laboratory;
  • NHS payment authorities;
  • The Inland Revenue;
  • The Benefits Agency, if the patient is claiming exemption or remission from NHS charges;
  • A private dental scheme, if the patient is a member.

Disclosure Without Consent 

Exceptional circumstances might override the duty to maintain confidentiality. Where possible, we will inform the patient or staff member of requests to share personal information. The decision to disclose information must only be taken by senior staff. Examples include:

  • Situations where there is a serious public health risk or risk of harm to other individuals;
  • When information is required by the police to prevent or detect crime or to apprehend or prosecute offenders (if not providing the information would prejudice these purposes);
  • in response to a court order;
  • to enable a dentist to pursue a legal claim against a patient.

Lynn Mann is responsible for making the decision regarding whether personal data should be disclosed.

Data Breaches 

We will always aim to ensure that the information we hold is held securely. We will report any detected data breaches that are likely to result in a risk to the rights and freedoms of the individuals affected to the ICO within 72 hours of becoming aware of them. We will also notify the affected individuals if the breach is likely to result in a high risk to their rights and freedoms. We will also inform the ICO of any breach of confidentiality.

We will document all data breaches, even those that are not notifiable to the ICO, and will include information on the steps taken to mitigate any adverse effects and to ensure that the breach does not reoccur.

Data Subject Rights 

We recognise the rights of individuals under GDPR and we have processes in place to deal with relevant requests. We provide a Privacy Notice to comply with an individual’s right to be informed. Where an individual requests access to their information, we will provide this free of charge, and in an electronic and commonly used format within one month of the request, unless we deem the request to be unreasonable or excessive. If we refuse a request for access, we will inform the individual of our decision, and the reasons for it, within one month of their request. We will also inform the individual that they have the right to appeal to the ICO and to seek legal advice.

Where an individual notifies us that the information we hold about them is incorrect, we will rectify this. Where an individual asks us to delete their information, we will consider this based on the type of information and any legal or professional obligations to retain the data. Where we cannot delete the information, we will inform the individual of this within one month of their request. Where an individual asks us to transfer their information to another dental practice, we will ensure that this is done in a confidential and secure manner. Individuals also have the right to object to data processing or to ask for this to be restricted. 

We do not use personally identifiable information in automated decision-making or data profiling.

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