Scope of the policy

This policy applies to the work of homeopath Sarah Davison at Thrive Homeopathy (hereafter referred to as ‘SD’). The

policy sets out the requirements that SD has in order to gather personal information for

professional purposes. The policy details how the personal information of SD’s patents will be gathered, stored and

managed in line with data protection principles and the General Data Protection Regulation. The

policy is reviewed on an ongoing basis to ensure that the SD is compliant. This policy should be

read in tandem with the SD’s Privacy Policy (below).

Why this policy exists

This data protection policy ensures that SD:

• complies with data protection law and follows good practice

• protects the rights of patients

• is open about how she stores and processes patients’ data

• protects herself from the risks of a data breach.

Data protection principles

The General Data Protection Regulation identifies 8 data protection principles.

Principle 1 – Personal data shall be processed lawfully, fairly and in a transparent manner

Principle 2 – Personal data can only be collected for specified, explicit and legitimate purposes

and not further processed in a manner that is incompatible with those purposes.

Principle 3 – The collection of personal data must be adequate, relevant and limited to what is

necessary compared to the purpose(s) data is collected for.

Principle 4 – Personal data held should be accurate and, where necessary, kept up to date. Every

reasonable step must be taken to ensure that personal data that are inaccurate are erased or

rectified without delay.

Principle 5 – Personal data which is kept in a form which permits identification of individuals shall

not be kept for longer than is necessary.

Principle 6 – Personal data must be processed in accordance with the individuals’ rights.

Principle 7 – Personal data must be processed in a manner that ensures appropriate security of

the personal data, including protection against unauthorised or unlawful processing and against

accidental loss, destruction or damage, using appropriate technical or organisational measures.

Principle 8 – Personal data cannot be transferred to a country or territory outside the European

Union unless that country or territory ensures an adequate level of protection for the rights and

freedoms of individuals in relation to the processing of personal data. Certain of these principles

are expanded upon in the sections that follow.

Lawful, fair and transparent data processing

SD requests/ gathers personal information from patients and potential patients for the purpose of

consulting with them and providing them with advice and guidance on homeopathic treatments.

The forms used to gather personal information will contain a privacy statement informing patients

why the information is being requested and what the information will be used for. Patients will be

asked to provide acceptance that their data needs to be gathered and held in order for treatment to

be provided. A record of this acceptance along with patient information will be securely held.

Processed for Specified, Explicit and Legitimate Purposes

Patients will be informed how their information will be used and SD will seek to ensure that

patients’ information is not used inappropriately. Appropriate use of information provided by

patients includes:

• Communicating with patients in order to make, change or cancel consultations

• Assessing the conditions and issues reported by patients and devising and prescribing

relevant remedies and therapies.

SD will ensure that patients’ information is managed in such a way as to not infringe an individual

patient’s rights which include:

• 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.

Adequate, Relevant and Limited Data Processing

SD’s patients will only be asked to provide information that is relevant to support consultations and

prescription. This includes:

• Name

• Date of birth

• Gender

• Postal address

• Email address

• Telephone number

• Medical history

• Emotional history

• Family medical history

There may be occasional instances where a patient’s information needs to be shared with a third

party due to an accident or incident involving statutory authorities. Where it is in the best interests

of the patient or of SD, in these instances where SD has a substantiated concern, then consent

does not have to be sought from the patient.

Accuracy of Data and Keeping Data up to Date

SD has a responsibility to ensure that patients’ information is kept up to date. Patients will be

required to let SD know if any of their personal information changes.

SD Data Protection & Privacy Policy V1 © Thrive Homeopathy 2018

Accountability and Governance

SD is responsible for ensuring that her practice remains compliant with data protection

requirements and can provide evidence that it has. For this purpose, those from whom data is

required will be asked to provide written acceptance. The evidence of this acceptance will then be

securely held as evidence of compliance.

Secure Processing

SD has a responsibility to ensure that data is both securely held and processed. This includes:

• using strong passwords for information held within computer systems

• restricting access to computer and paper-based files

• using password protection on laptops and PCs that contain or access personal information

• using password protection or secure cloud systems

• providing adequate virus-protection and firewall software to secure computer-based

systems.

Subject Access Request

SD’s patients are entitled to request access to the information that is held by the SD. The request

needs to be received in the form of a written request to SD.

On receipt of the request, the request will be formally acknowledged and dealt with within 14 days

unless there are exceptional circumstances as to why the request cannot be granted. SD will

provide a written response detailing all information held on the member. A record shall be kept of

the date of the request and the date of the response.

Data Breach Notification

Were a data breach to occur, action shall be taken to minimise the harm. SD will inform any

patients where she believes their personal information has been compromised. Where necessary,

the Information Commissioner’s Office would be notified.

If a patient contacts SD to say that they feel that there has been a breach by SD, she will ask the

patient to provide an outline of their concerns. If the initial contact is by telephone, SD will ask the

patient to follow this up with an email or a letter detailing their concern. The concern will then be

investigated fully and a response made to the patient. Breach matters will be subject to a full

investigation, records will be kept and all those involved notified of the outcome.

Policy review date: 1 April 2020

PRIVACY POLICY

I take the privacy rights of my patients very seriously. This privacy policy sets out how I deal with

your ‘personal information’, that is, information that could identify, or is related to the identity of, an

individual.

What personal information do I collect?

In order to treat you, I will ask you to provide certain information. This includes:

• Name

• Gender

• Date of birth

• Home address

• Email address

• Telephone number

• Medical history

• Emotional history

• Family medical history

To this, over time, I will add details of the conditions for which you have consulted me and the

remedies and other therapies that I have prescribed or recommended.

How do I collect this personal information?

All the information collected is obtained directly from you. This is usually at the point of your initial

consultation. The information is collected via a patient questionnaire form, and a consent &

registration form, which I ask you to complete prior to or at the initial consultation. At the point at

which you provide your personal information, I will also request that you provide acceptance for me

to store and use your data, as this data is necessary for me to provide treatment, and is part of the

contract between us. Subsequently, I will add to this initial information with details of the

consultations you hold with me.

How do use this personal information?

• I use your personal information to analyse the conditions for which you have consulted me and to

prescribe remedies and other therapies.

• I will communicate with you by email, other digital methods, by telephone and by post.

With whom do I share your personal information?

I do not share your personal information. If there is a need to share it, I will get your consent first

How long do I keep your personal information?

I need to keep your information for as long as you continue to consult me. Since patients often

return for more consultations after a period of absence, I will keep your information for seven years

after your last consultation. At that point, your file will be securely destroyed and any digital

information will be erased from my computer systems.

How your information can be updated or corrected

To ensure that I have accurate and up-to-date information, you need to inform me of any changes

you believe I should make to the personal information I hold. You can do this by contacting me by

any of the methods previously described. Under data protection legislation, you have the right to

inspect the personal information I hold about you. You can make a request to do so by contacting

me and I will endeavour to respond within 14 working days.

How do I store your personal information?

My patient files are paper-based and are held securely within my consulting room. I take steps to

protect your personal information against loss or theft, as well as unauthorised access, disclosure,

copying, use, or modification.

Your intake forms (consent & registration form & patient questionnaire form) is also held on my

laptop, which is password protected and encrypted.

Your email address, and any information exchanged via email of a personal nature (prescription

details or emails from you outlining symptoms) is held securely on the servers of my email provider

Fastmail. To find out more about Fastmail’s security policy go to https://www.fastmail.com/help/

ourservice/security.html

Changes to this policy

This policy may change from time to time. If I make any material changes, I will make you aware of

them.

Contact

If you have any queries about this policy, need it in an alternative format, or have any complaints

about my privacy practices, please contact me:

Sarah Davison

Flat 3, 48 Cleveland Square, London, W2 6DB

07850 519373

sarah@thrivehomeopathy.com

SD Data Protection & Privacy Policy V1 © Thrive Homeopathy 2018  l    Policy review date: 1 April 2020