Privacy Statement for Windsor Audiology Centre (WAC)

INTRODUCTION

We take the confidentiality of patient information very seriously at Windsor Audiology Centre. The Law determines how we can use the personal information we collect. This is underpinned by the Common law of Confidentiality together with legislation we must comply with including:

Data Protection Act 1998
Human Rights Act 1998
General Data Protection regulation(GDPR) May 2018

We hold personal and confidential information for a number of purposes. This notice sets out in general terms a summary of the type of information we hold about our clients and what it is used for.

We need this information to allow us to contact clients to book relevant appointments.

INFORMATION HELD

Our clients include those referred from our ENT colleagues, medical secretaries, direct contact from the public and other medical practitioners such as neurologists and GPs.

The information may include (but is not limited to) the following:

Name, address, telephone numbers, date of birth, email address
Appointment details
Correspondence, journal notes and reports
Investigations, test results and hearing aid information

We may then use this information to produce a report to send to the original referrer or to enable us to order a hearing aid direct from a manufacturer.

We need this information for the following reasons:

To help inform the decisions we need to make about your care
To ensure that your treatment is safe and effective, including any advice that may be provided as part of your care
To help us work effectively with other organisations who may be involved in your care

Opting out

In order for this to happen we need all hearing aid clients to sign their hearing aid quote letter giving consent to send name to the supplier as well as keeping details on our NOAH database. All hearing aid dispensers and/or scientists employed by WAC will keep any personal data on their laptops provided by WAC. Each laptop is to be password protected and to have Norton antivirus software installed, as well as all software to be updated regularly when prompted to do so.

All other clients to sign a consent form giving permission to send a report to the original referrer, which may well be the registration form supplied by the hospital/clinic the client is attending.

All patients seen by a WAC clinician will have their ID checked and searched on Noah database to ensure no duplicates exist.

Samples of registration forms attached from The Bridge clinic and BMI

All clients will need to opt in and agree before reports and orders can take place. Sufficient information should be given to the client to ensure they are fully informed before they consent. An explanation will need to take place as to what information needs to be shared and this needs to be clearly documented.

Consent to methods of communication need to be agreed with each client and recorded on Noah at the initial visit. The methods are email, text, telephone, recorded call or post, which the client can choose to opt out of any or all.

A separate marketing opt-in box to be pointed out to the hearing aid clients.

The details of where we hold their information needs to be pointed out to the clients. Windsor Audiology are responsible for ensuring our clients details are looked after properly and ensuring it is kept confidential at all times and in accordance with the data protection law. Personal information supplied to us by medical agencies or from the clients may be used in connection with their treatment and care, including any medical examinations, tests or assessments, or payment of fees, including billing, invoicing and settlement of their account. If a client is late paying their fees we may need to disclose their name and address to credit reference or debt collection agencies WAC may share medical information with and obtain information about our clients only after seeking prior consent.

If WAC was ever sold to a third party, all the clients records would be transferred to the new owners and we would inform our clients of the new contact details. The reason for the transfer would be to minimise disruption to all the clients and to preserve medical records to ensure continuity of care.

WAC will not otherwise disclose any information about our clients to anyone else without gaining consent.

Security of data

All paper documents with any client’s details will be disposed of in the appropriate shredding/confidential waste boxes at each clinic/hospital site.

Reports on clients to be stored only on a laptop which is password protected and for a maximum of one year, then down loaded onto a separate heard drive January each year, kept for 8 years then disposed of. Any sharing of these documents via email should be done via Egress.

Windsor Audiology Centre have reviewed the purposes of our processing activities and selected the most appropriate lawful basis for each activity.

We have checked that the processing is necessary for the relevant purpose and we are satisfied that there is no other reasonable way to achieve that purpose.

We have documented our decision on which lawful basis applies to help us demonstrate compliance.

We have included information about both the purpose of the processing and the lawful basis for the processing in our notice.

We do not process special category data nor criminal offence data.

The lawful basis for processing our data is via consent from an individual who will have given clear consent for us to process their personal data for a specific purpose.

We do not have a designated Data protection officer, but if there are any concerns these can be raised either with the Windsor Audiology Centre Manager or a partner of the business.

Partners

Chris Aldren Consultant ENT Surgeon

Nigel Bleach Consultant ENT Surgeon

Stephen Wood Consultant ENT Surgeon

Review March 2019