Legal

Iris Physio Ltd Customer Privacy Notice

This privacy notice tells you what to expect us to do with your personal information.

  • Contact details
  • What information we collect, use, and why
  • Lawful bases and data protection rights
  • Where we get personal information from
  • How long we keep information
  • Who we share information with
  • Sharing information outside the UK
  • How to complain

Contact details

Telephone
07307369776

Email
admin@irisphysio.co.uk

ICO registration number: ZC140538

What information we collect, use, and why

We collect or use the following information to provide patient care, services, pharmaceutical products and other goods:

  • Name, address and contact details
  • Gender
  • Date of birth
  • Next of Kin details including any support networks
  • Emergency contact details
  • Photographs
  • Health information (including medical conditions, allergies, medical requirements and medical history)
  • Information about care needs (including disabilities, home conditions, medication and dietary requirements and general care provisions)
  • Test results (including psychological evaluations, scans, bloods, x-rays, tissue tests and genetic tests)
  • Payment details (including card or bank information for transfers and direct debits)
  • Insurance policy details
  • Records of meetings and decisions

We also collect the following special category information to provide patient care, services, pharmaceutical products and other goods. This information is subject to additional protection due to its sensitive nature:

  • Health information

We collect or use the following information for safeguarding or public protection reasons:

  • Name, address and contact details
  • Emergency contact details
  • Health information (including medical conditions, allergies, medical requirements and medical history)
  • Records of meetings and decisions

We also collect the following special category information for safeguarding or public protection reasons. This information is subject to additional protection due to its sensitive nature:

  • Health information

We collect or use the following personal information for patient app or portal functionality:

  • Names and contact details
  • Medical history
  • Payment details
  • Account information, including registration details
  • Information used for security purposes
  • Marketing preferences

We also collect the following special category information for patient app or portal functionality. This information is subject to additional protection due to its sensitive nature:

  • Health information

We collect or use the following personal information to comply with legal requirements:

  • Name
  • Contact information
  • Health and safety information
  • Financial information
  • Any other personal information required to comply with legal obligations
  • Insurance details
  • Safeguarding information

We also collect the following special category information to comply with legal requirements. This information is subject to additional protection due to its sensitive nature:

  • Health information

We collect or use the following personal information for dealing with queries, complaints or claims:

  • Names and contact details
  • Addresses
  • Payment details
  • Purchase or service history
  • Witness statements and contact details
  • Customer or client accounts and records
  • Financial transaction information
  • Information relating to health and safety (including incident investigation details and reports and accident book records)
  • Correspondence

We also collect the following special category information for dealing with queries, complaints or claims. This information is subject to additional protection due to its sensitive nature:

  • Health information

Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

  • Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.
  • Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.
  • Your right to erasure - You have the right to ask us to delete your personal information. Read more about the right to erasure.
  • Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.
  • Your right to object to processing - You have the right to object to the processing of your personal data. Read more about the right to object to processing.
  • Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability.
  • Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information to provide patient care, services, pharmaceutical products and other goods are:

  • Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Our lawful bases for collecting or using personal information for safeguarding or public protection reasons are:

  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
  • Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

Our lawful bases for collecting or using personal information for patient app or portal functionality are:

  • Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

Our lawful bases for collecting or using personal information to comply with legal requirements are:

  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:

  • Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
  • Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
    • We have a legitimate interest in responding properly to queries, investigating and resolving complaints, and defending claims made against us. We cannot respond to a complaint or defend a claim without access to the relevant clinical records, correspondence and payment history relating to that person. This benefits the person raising the query or complaint, who is entitled to a full and accurate response, as well as our practice and our professional indemnity insurers. We only use the information needed to deal with the matter, we keep it no longer than necessary, and the person is already aware that we hold their records as a patient of the practice. We do not consider this use to carry any undue risk of harm.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

Where we get personal information from

  • Directly from you
  • Family members or carers
  • Other health and care providers
  • Insurance companies
  • Employer organisations who commission occupational health or workplace assessments, who may provide us with an employee’s name, contact details, job role and the reason for referral before an assessment takes place.

How long we keep information

We keep your information for different lengths of time depending on what it is and why we hold it.

Clinical records: we keep adult patient records for 8 years after your last appointment with us. For patients under 18, we keep records until their 25th birthday, or until their 26th birthday if they were 17 at their last appointment. This follows the retention standards applied across UK healthcare.

Financial and payment records: we keep these for 6 years plus the current financial year, as required for tax purposes.

Enquiries that do not lead to treatment: we keep these for 12 months.

Complaints and claims records: we keep these alongside the related clinical record, or for longer where a claim remains open.

Marketing contact details: we keep these until you ask us to stop contacting you. We then keep a minimal record of your request so that we do not contact you again by mistake.

When these periods end, we securely delete or destroy the information.

Who we share information with

Data processors

Rehab Guru (practice management, clinical records and patient portal)
This data processor does the following activities for us: Provides our practice management system. They store patient records, clinical notes and exercise programmes, manage appointment booking, and provide the patient portal through which patients access their treatment plans.

Google Workspace (email and document storage)
This data processor does the following activities for us: Provides our email and document storage services, which we use for correspondence with patients, GPs, consultants and insurers, and for storing practice documents.

Netlify (website host)
This data processor does the following activities for us: Hosts our website, including the enquiry and contact forms through which people can get in touch with us.

Others we share personal information with

  • Other health providers (eg GPs and consultants)
  • Insurance companies, brokers and other intermediaries
  • Organisations we need to share information with for safeguarding reasons
  • Emergency services
  • Professional advisors
  • Local authorities or councils
  • Organisations we’re legally obliged to share personal information with

Duty of confidentiality

We are subject to a common law duty of confidentiality. However, there are circumstances where we will share relevant health and care information. These are where:

  • you’ve provided us with your consent (we have taken it as implied to provide you with care, or you have given it explicitly for other uses);
  • we have a legal requirement (including court orders) to collect, share or use the data;
  • on a case-by-case basis, the public interest to collect, share and use the data overrides the public interest served by protecting the duty of confidentiality (for example sharing information with the police to support the detection or prevention of serious crime);
  • If in England or Wales – the requirements of The Health Service (Control of Patient Information) Regulations 2002 are satisfied; or
  • If in Scotland – we have the authority to share provided by the Chief Medical Officer for Scotland, the Chief Executive of NHS Scotland, the Public Benefit and Privacy Panel for Health and Social Care or other similar governance and scrutiny process.

Sharing information outside the UK

Where necessary, our data processors may share personal information outside of the UK. When doing so, they comply with the UK GDPR, making sure appropriate safeguards are in place.

For further information or to obtain a copy of the appropriate safeguard for any of the transfers below, please contact us using the contact information provided above.

Organisation name: Google Workspace
Category of recipient: Email and cloud storage provider
Country the personal information is sent to: United States (and other countries where Google operates data centres)
How the transfer complies with UK data protection law: Addendum to the EU Standard Contractual Clauses (SCCs)

Organisation name: Netlify
Category of recipient: Website hosting provider
Country the personal information is sent to: United States
How the transfer complies with UK data protection law: Addendum to the EU Standard Contractual Clauses (SCCs)

How to complain

If you have any concerns about our use of your personal information, you can make a data protection complaint to us:

Email: admin@irisphysio.co.uk

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO’s address:

Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF

Helpline number: 0303 123 1113  Website: https://www.ico.org.uk/make-a-complaint