Privacy and Digital Marketing Policy
1. Life Chiropractic Clinics are committed to safeguarding the privacy of our customers, website visitors and service users.
2. Life Chiropractic Clinics are to be considered a data controller for the purposes of this policy and in compliance with the General Data Protection Regulation, effective from 25 May 2018 (“GDPR”)
3. Life Chiropractic Clinics are registered with the Information Commissioners Office
Data Protection Officer
4. Life Chiropractic Clinics have decided that a Data Protection Officer is not required to be compliant with GDPR
5. Life Chiropractic Clinics hold and process data under varying legal basis (See Appendix One; legal basis) Our most common processes are detailed as follows:
Data process: Record cards and patient financial information
Type of Data / Location: Specialist data: Record cards including: name, address, phone number, email, medical history, diagnosis, treatment information and payment details
Legal Basis: Legal Requirement
Details About the Data: Digital documents; stored securely.
Retention Period: 8yrs
Data process: Booking System; Reminder Texts and Emails
Type of Data / Location: Digital, cloud based: Including name, address, phone number, email address and date of birth
Legal Basis: Contract
Details About the Data: Capable; Server Based Software held on encrypted servers onsite within our clinic locations.
Retention Period: 8yrs
Data process: CRM; Newsletter
Type of Data / Location: Digital, Cloud Based: Including name, email address, clinic they attend
Legal Basis: Consent
Details About the Data: Mailchimp: Cloud based Consent for marketing with new and exisiting patients
Retention Period: Annual check – re opt-in/out
Data process: Survey Data
Type of Data / Location: Digital, Cloud Based: Including name, email address
Legal Basis: Consent
Details About the Data: Survey Monkey: Consent to use data on taking
Retention Period: Data deleted after use
Data process: Direct Debit Processing
Type of Data / Location: Digital, Cloud Based: Including name, address, bank account details, email address
Legal Basis: Consent
Details About the Data: Natwest PayAway Consent on taking prepayment plan. Details held by Natwest PayAway
Retention Period: Data deleted 1yr after expiry of plan
Data process: Testimonials
Type of Data / Location: Online – public domain, YouTube and our website
Legal Basis: Consent
Details About the Data: Held by internal marketing department.
Retention Period: 8yrs or Removed by request of client
6. Life Chiropractic Clinics also process data in terms of;
a) Staff and subcontractor details; name, profile pictures and employment details. In this instance the legal basis for processing is the performance of a contract between you and us
b) Testimonials, see clauses 16-19
c) Photographs at events; we reserve the right to use pictures taken at events for promotion and social media as part of a contractual basis on attendance, subject to your rights to opt out
7. Life Chiropractic Clinics website does not directly process any data, however it does process some data through indirect means, such as by utilising cookies (See Definitions; cookie), integrating with CRM booking software and using website tracking software
8. Life Chiropractic Clinics website has a SSL certificate to add a greater level of security
9. We can not vouch for the safety or security of data published on an external link or via social media accounts. We remind all users to act with caution when posting.
10. Life Chiropractic Clinics do not store or process data directly on the website. The website does not contain logins for staff or members of the public to use.
a) identify you when you visit our website and as you navigate our website
b) determine if you are logged onto our website
c) secure our website and services generally
d) help us to analyse and enhance the use and performance of our website and services; and
e) store your website use preferences.
13. Website users are able to refuse to accept or block cookies through their browser security settings at any time. Blocking cookies may reduce usability or the number of features available on our website.
14. Life Chiropractic Clinics do not store, save or collect personal information from the website through cookies.
Tracking Spftware and CRM Intergration
15. Life Chiropractic Clinics website uses tracking software to monitor its visitors to better understand how they use it. This software is provided by Google Analytics and Google Search Console. The information gathered relating to our website is used to create reports about the use of our website and to understand usage for further development.
16. Life Chiropractic Clinics may process testimonials and include the full name, of the author of a testimonial
17. Life Chiropractic Clinics reserve the right to copy, screen shot and use comments made about Life Chiropractic Clinics in a public arena, such as on social media and Google Reviews
18. Testimonials may be shared on Life Chiropractic Clinics website, social media, paper and/or digital marketing. They may also be shared with, employees and service users
19. Life Chiropractic Clinics reserve the right to use anonymised testimonials or testimonials without use of identifiable data, where consent is not recorded following provision of a testimonial
20. Although this website includes quality, safe and relevant external links, users are still advised to adopt a policy of caution before clicking any external web links mentioned throughout this website. (External links are clickable text / banner / image links to other websites etc.)
21. Life Chiropractic Clinics cannot guarantee or verify the contents of any externally linked website despite their best efforts. Users should therefore note that they click on external links at their own risk and this website and its owners cannot be held liable for any damages or implications caused by visiting any external links mentioned
22. Shortened URL links might be used on social media or on Life Chiropractic Clinics website
23. Communication, engagement and actions taken through external social media platforms that this website and its owners participate on are subject to the terms and conditions as well as the privacy policies held with each social media platform respectively
24. Users are advised to use social media platforms wisely and communicate / engage upon them with due care and caution in regard to their own privacy and personal details. Neither this website nor its owners will ever ask for personal or sensitive information through social media platforms. Users wishing to discuss sensitive details should do so through primary communication channels such as by telephone or email
25. Life Chiropractic Clinics website may use social sharing buttons which help share web content directly from web pages to the social media platform in question. Users are advised before using such social sharing buttons that they do so at their own discretion and note that the social media platform may track and save your request to share a web page through your social media platform account
26. Life Chiropractic Clinics reserve the right to publish comments, testimonials and posts made on social media in unedited form. We use automated social media walls, social share functions on our website to reflect up to date social media engagement. Website users are reminded that engagement with these functions are at their own risk
27. Users are advised to take caution and use good judgement before clicking any shortened URLs published on social media platforms by Life Chiropractic Clinics. Despite the best efforts to ensure only genuine URLs are published, many social media platforms are prone to spam and hacking and therefore this website and its owners cannot be held liable for any damages or implications caused by visiting any shortened links.
Email Marketing and Contact
28. Life Chiropractic Clinics operates an email marketing program, used to inform visitors about products and services. Users can subscribe through an online automated process should they wish to do so at their own discretion. Some subscriptions may be manually processed through prior written agreement with the user
29. Subscriptions are taken in compliance with UK Spam Laws detailed in the Privacy and Electronic Communications Regulations 2003 as well as GDPR
30. Email marketing campaigns published by Life Chiropractic Clinics may contain tracking facilities within the actual email, linked to our website tracking. This information is used to refine future email campaigns and supply the user with more relevant content based around their activity
31. In compliance with UK Spam Laws and the Privacy and Electronic Communications Regulations 2003, subscribers are given the opportunity to un-subscribe at any time through an automated system. This process is detailed at the footer of each email campaign. If an automated un-subscription system is unavailable, clear instructions on how to un-subscribe will be detailed instead.
Providing Your Data to Others
32. From time to time Life Chiropractic Clinics may contact your GP, insurance provider and/or other healthcare professionals about the status of your care. Life Chiropractic Clinics will gain consent from you that it is satisfactory for us to do this, however we reserve the right to do so should it be considered that there is a legal or vital interest to do so
33. Life Chiropractic Clinics reserve the right to breach confidentiality and share personal data where there is a public safety, legal obligation or vital interest to do so
34. Life Chiropractic Clinics may process any personal data identified in this policy for the establishment, exercise or defence of legal claims (whether administrative or out of court) and for the purposes of obtaining or maintaining insurance coverage, managing risks or obtaining professional advice.
35. Life Chiropractic Clinics might disclose personal data to our subcontractors or employees on your approval. We may also disclose some personal data on your request to other practitioners for referrals.
36. Financial transactions relating to our services are handled by Natwest Bank. We will share transaction data with any payment services or professional accountants on in so far of processing and refunding payments, dealing with complaints and queries and to satisfy our wider financial and/or insurance obligations.
You can find information about the payment services providers’ privacy policies and practices at Natwest Bank.
Your Rights: Retaining and Deleting Information
37. Personal data that we process, for any purpose, shall not be kept for longer than is necessary for that purpose or those purposes
38. Life Chiropractic Clinics respect your rights under GDPR (See definitions, Your rights). Please contact firstname.lastname@example.org at any time to instruct us should you feel that your rights are being infringed or for requests for further information
39. You have the right to confirmation as to whether or not we process your personal data. purposes of the processing, the categories of personal data concerned and the recipients of the personal data
40. You have the right to request copies of data held by Life Chiropractic Clinics, providing the rights and freedoms of others are unaffected
41. Requests for copies of data should be made to email@example.com. Life Chiropractic Clinics will confirm receipt of your request.
42. The first copy will be provided free of charge. Additional copies may be subject to a reasonable fee. Pursuant to GDPR, Life Chiropractic Clinics reserve the right to charge for requests that are vexatious or require additional administration.
Your Rights to Correct, Erase, Object to, Restrict Data and Withdraw Consent
43. 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
44. 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; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The 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
45. 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
46. 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
47. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose
48. 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
49. 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.
50. You have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal
51. Life Chiropractic Clinics reserve the right to change and/or vary our website, services and/or policies at any time. Please check our website to see any latest variation.
52. Life Chiropractic Clinics is owned and operated by Life Chiropractic Clinics (Registered Company Address in England and Wales: Burgandy Court, 64-66 Springfield Road, Chelmsford Essex, CM2 6JY, Company number: 06016523.)
53. Our Wickford Clinic is owned and operated by Gospodinov Health Ltd (Registered Company Address in England and Wales: 4 Capricorn Centre, Cranes Farm Road, Basildon, Essex SS14 3JJ. Company number: 10830281.)
54. Please contact us via firstname.lastname@example.org or or by post at the above address should you need to contact us about anything within this policy.
[Policy last updated MAY 2018 – Version 1.1]
APPENDIX ONE – Definitions:
1. “ Cookie” – 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. 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. 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.
2. Legal Basis – the legal bases of the processing under the GDPR are:
(i) Consent: the individual has given clear consent for you to process their personal data for a specific purpose.
(ii) Contract: the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract.
(iii) Legal obligation: the processing is necessary for you to comply with the law (not including contractual obligations).
(iv) Vital interests: the processing is necessary to protect someone’s life.
(v) Public task: the processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law.
(vi) Legitimate interests: the processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.
3: Your Rights
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.