Mercer Dental Care is committed to protecting the privacy and security of the personal data we hold for our patients.

We are a data controller under the terms of the Data Protection Act 2017 and the requirements of the EU General Data Protection Regulation.

This privacy notice describes our procedures for ensuring that personal information is processed lawfully and fairly.

The purpose of collecting and storing personal data about our patients is to ensure we can:

• Provide, appropriate, safe and effective dental care, treatment and advice for all our patients
• Fulfil any contracts we hold in relation to their care
• For business administration of their care.

Personal data held for our patients

The personal data we process (processing includes obtaining the information, using it, storing it, securing it, disclosing it, and destroying it) for our patients includes:

• Name, title, address, date of birth
• Unique identification number
• Next of kin, emergency contact information
• Email address
• Phone numbers
• GP contact details
• Occupation
• Medical history
• Dental care records
• Photographs
• Family group
• Payment plan details
• Financial information
• Credit cards receipts
• Correspondence
• Details of any complaints received.

We keep an inventory of personal data we hold on our patients and this is available for patients on request. A list of personal information held is also included in our Privacy Notice that is given to all patients.

Disclosure to third parties

The information we collect and store will not be disclosed to anyone who does not need to see it.

We will share our patients’ personal information with third parties when required by law or to enable us to deliver a service to them or where we have another legitimate reason for doing so. Third parties we may share patients’ personal information with may include:

• Regulatory authorities such as the General Dental Council or the RQIA
• NHS Local Authorities
• Dental payment plan administrators
• Insurance companies
• Loss assessors
• Fraud prevention agencies
• In the event of a possible sale of the practice at some time in the future.

We may also share personal information where we consider it to be in a patient’s best interest or if we have reason to believe an individual may be at risk of harm or abuse.

Personal Privacy Rights

• Under the GDPR all individuals who have personal information held about them have the following personal privacy rights:
• Right to data subject access
• Right to have inaccuracies deleted
• Right to have information erased
• Right to object to direct marketing
• Right to restrict the processing of their information, including automated decision-making
• Right to data portability.
• Access may be obtained by making a request in writing to Mrs Janice Barr. We will require photographic evidence of your identity before being able to comply with the request. We will provide a copy of the record within 30 days of the request.

Legal basis for processing data held about patients

The GDPR requires us to state the legal basis upon which we process all personal data for our patients.
We will only use patients’ personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

• Where we need to perform the contract we have entered into with you
• Where we need to comply with a legal obligation
• Where it is necessary for our legitimate interests (or those of a third party) and
  your interests and fundamental rights do not override those interests
• Where we need to protect your interests (or someone else’s interests
• Where it is needed in the public interest or for official purposes.

Automated decision making

All individuals who have personal data held about them have a right to object to their personal data being subjected to automated decision making. Patients will always be asked to give specific, informed, verifiable, opt in consent for any processes involving automated decision making.

Consent

Mercer Dental Care always obtains specific, unambiguous opt in consent from all patients to whom we send direct marketing information.

We also obtain specific, unambiguous, opt in consent from our patients for obtaining photographs, treatment plans/treatment estimates and with other healthcare professionals who need to be involved in patient care, for example consultant/specialist/laboratory. For a new patient, we obtain consent for these things when the patient first attends the practice. For an existing patient, we ask the patient for consent when they attend for their recall appointment or for a treatment appointment. We refresh this consent annually when the patient completes a new medical history proforma.

Withdrawal of consent

Patients who have given their opt in consent have a right to withdraw their consent at any time. Patients are advised of their right to withdraw their consent for anything they wish to withdraw from in our privacy notice.

Data Breach

We have clear procedures in place to deal with any data breach and these are described in our Data Protection Policy. Should the breach involve a breach of confidentiality then we will notify the individual involved in addition to the Data Protection Authorities.

Retention period

This practice retains dental records and orthodontic study models while the patient is a patient of the practice and after they cease to be a patient, for at least eleven years, or for children until age 25, whichever is the longer.

Transferring personal data outside the EU

This practice may send any necessary laboratory work outside the EU. Laboratory work sent outside the EU will be labelled with the patient’s unique identifying number rather than the patient’s name. A record of the unique identifying number will be held at the practice.

Complaints

Our appointed compliance officer in respect of our data protection activities is Mrs Janice Barr. All individuals who have personal data held about them have a right to complain. All complaints concerning personal data should be made in person or in writing to Mrs Janice Barr, Mercer Dental Care, 97 Brunswick Road, Bangor BT20 3DW. All complaints will be dealt with in line with the practice complaints policy and procedures.

If patients are not satisfied with the result of our procedure then a complaint may be made to the Information Commissioner at www.ico.org.uk/concerns or by calling 030 3123 1113.