This notice does not form part of any contract to provide services. We may update this notice at any time.
As a Data Subject, under the Data Protection (Jersey) Law 2018 you have rights. Please note that certain rights only apply where processing is justified by specific legal bases, and certain circumstances concerning legal and regulatory matters can restrict the extent of certain rights.
You have the right to:
- To be informed about how we collect and use your data. (Right to be informed).
- To ask to have access to the data we hold on you, mostly known as a Data Subject Access Request. (Right of access). These requests are free unless, for example, what was being asked required a very excessive or disproportionate amount of effort to complete.
- To request corrections to the data we hold on you. (Right of rectification). Such as if you have changed your phone number and what we have is incorrect.
- To ask for personal data held about you to be erased. (Right to erasure). This is often known as the “right to be forgotten”, where you would wish to withdraw your consent for any data we have about you being used for further processing.
- To request the restriction or suppression of the processing of your personal data (Right to restriction of processing). When you submit a request to us under your other rights, you may also ask to restrict further processing on your data until we have completed your original request.
- To request that all data we hold on you be provided to you in a format that you can reuse for your own purposes. (Right to data portability). For example, for the purposes of you intending to give your dental records to another dentist.
- To object to the processing of personal data. (Right to object). For example, objecting to a Data Controller using your email address for the purposes of direct marketing emails if they had not adequately informed you about that intention beforehand. (There are also related rights to object regarding your data being used for historical, scientific, legitimate, or public-functions' purposes).
- To not be subject to a decision purely based on automated profiling or processing that has a legal or significant effect. (Rights related to automated decision-making including profiling). For example, a company using artificial intelligence to purely make legal decisions on your suitability for a service without having a member of staff making the actual final decision.
What information do we collect about you?
We may collect the following kinds of information about you. Note this list is not exhaustive. We collect data classified as both Personal and Special Categories of Personal Information.
- Personal details. For example your name, date of birth, gender, Jersey Social Security number, address, telephone number, email address, and occupation.
- Emergency contact information such as next of kin.
- Information about your dental and general health, including clinical records made by dentists and other dental professionals involved with your care and treatment.
- X-rays, clinical photographs, digital scans of your mouth and teeth, and study models.
- Medical and dental histories.
- Treatment plans and consent.
- Notes of conversations with you about your care.
- Correspondence from other health professionals or institutions involved in your care.
- Details of the fees we have charged, payments exemptions, the amounts you have paid and some payment details.
- Feedback and complaints.
- Online profile and social media information and activity, based on your interactions with us.
- For statistics and performance monitoring purposes, our website may collect for example Internet Protocol (IP) address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.
How we obtain your information
You may give us information about you through the following:
Filling in forms given to you at our practice or on our website.
By corresponding with us by phone, e-mail or otherwise.
Through the technology you use to access our services.
We receive information from third parties - this includes information you provide when you visit our website for the purpose of booking an appointment with us, participate in social media functions on our site, and when you report a problem with our website.
We currently use Google Analytics, (this is being reviewed as of November 2020).
You can set your browser not to accept cookies and also remove cookies from your browser when it is closed. Please consult the help guides and provider website for the browser you use.
How do we use your information?
We will only use your 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. To provide you with the dental care and treatment that you need, we would require up-to-date accurate information about you. We will seek your preference for how we contact you about your dental care. Our usual methods are SMS, telephone, email or letter.
- Where we need to comply with a legal or regulatory 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. Such as to find out if you are happy with the treatment you received for quality control purposes.
- We may contact you (with your consent) to conduct patient surveys or to inform you of products and services available at our practices. We may use your information for our own analysis to understand the effectiveness of our marketing activities.
We may also use your personal information in the following situations, which are considered to be rare:
- Where we need to protect your interests (or someone else’s interests).
- Where it is needed in the public interest or for official purposes.
- Archiving your sensitive personal data for use in the public or scientific interest. Also, this data may be used in for historical and statistical purposes. If we wish to use your information for dental research or dental education, we will discuss this with you and seek your consent. Depending on the purpose and if possible, we will anonymise your information. If this is not possible we will inform you and discuss your options.
Sharing your information
Your information is normally used only by those working at the practice but there may be instances where we need to share it – for example, with:
- Your doctor
- The hospital or community dental services or other health professionals caring for you
- Dental laboratories
- Payment authorities
- Government departments and agencies, where you are claiming exemption or remission from charges
- Private dental schemes of which you are a member
- Debt collection companies.
We also share your information with third parties in order to deliver the following services to you:
- Managing new enquiries from our website
- Contacting you to check if you wish to remain a client of ours
- Sending reminders for your dental appointments
- Processing on-line booking appointments
- Collecting feedback from our patients
- Managing email communications to our patients
- Providing troubleshooting and support services for our various IT systems.
We will only disclose your information on a need-to-know basis and will limit any information that we share to the minimum necessary. We also have third party agreements in place to protect your information.
In certain circumstances or if required by law, we may need to disclose your information to a third party not connected with your health care, including enforcement or government agencies.
Some of your information may be transferred out of the European Economic Area (EEA), primarily for creating medical devices such as crowns. Where information is transferred outside of the European Economic Area (“EEA”), we require that appropriate safeguards are in place and we use contracts that require the recipient to protect your Personal Data to the same standards as it would be within Jersey or the EEA.
How we keep your information safe
We employ administrative, electronic and physical security measures to ensure that the information that we collect about you is protected from unauthorised access, and protected against unlawful processing, accidental loss, destruction and damage.
This includes (but is not limited to):
- Password protection
- Locked cabinets/rooms
- Virus and firewall protection
- Computer encryption
- Back-up procedures
How long will we keep your information?
We keep your dental records for 11 years. Other records (for example financial transactions) may have a variety of different retention dates, based on business or legal and regulatory requirements.
How to contact us
Requests to us exercising your rights, or related queries or complaints, can be either written, emailed or verbal. Depending on the nature of your request, we may later request further written correspondence to complete it (such as to help us confirm your identity as a security measure to prevent disclosure to someone who has no right to receive your data).
For your convenience, these requests can be sent to email@example.com . Alternatively, call us on +44(0) 1534 743849.
Or write to the following address:
If you are unhappy with how we have dealt with your request, please contact us to discuss further. If following those discussions you are still unsatisfied, you also have the right to complain to the Jersey Office of the Information Commissioner (JOIC). They can be contacted as follows:
Online complaint form - https://jerseyoic.org/make-a-complaint/
Calling 01534 716530 (8:45am to 5pm, Monday to Friday)
If you wish to learn further about your rights under the Data Protection (Jersey) Law 2018, please consider this page on the JOIC website - https://jerseyoic.org/resource-room/information-rights/?audience=individuals