The practice aims to meet the requirements of the Data Protection Act 2018, the United Kingdom General Data Protection Regulation (UK GDPR), the guidelines on the Information Commissioner’s (ICO) website as well as our professional guidelines and requirements.
The data controller is Cupar Dental & Implant Centre Ltd, information governance is handled by our practice team.
This Privacy Notice is available on the practice website at www.cupardental.co.uk and at reception or by email if you contact reception@cupardental.co.uk and by calling 01334 655752.
You will be asked to provide personal information when joining the practice. The purpose of processing your personal data is to provide you with optimum dental health care and prevention.
The categories and examples of data we process are:
- Personal data for the provision of dental health care
- Personal data for the purposes of providing treatment plans, recall appointments, reminders or estimates
- Personal data such as details of family members for the provision of health care to children or for emergency contact details
- Personal data for the purposes of employed and self-employed team members employment and engagement respective
- Personal data for the purposes of direct mail/email/text to inform you of important announcements or about new treatments or services
- Personal data – IP addresses so that we can understand our patients better and inform our marketing approach as well as improve the web site experience
- Special category data including health records for the purposes of the delivery of health care and meeting our legal obligations
- Special category data including health records
- Special category data to meet the requirements of the Equality Act 2010
- Special category data details of criminal record checks for employees and contracted team members
We minimise the data that we keep, and do not keep it for longer than necessary.
We never pass your personal details to a third party unless we have a contract for them to process data on our behalf and will otherwise keep it confidential. If we intend to refer a patient to another practitioner or to secondary care such as a hospital, we will gain the individual’s permission before the referral is made and the personal data is shared. Your data will be shared with the NHS if you are having NHS treatment.
- Personal data is stored in the UK whether in digital or hard copy format
- Personal data is obtained when a patient joins the practice, when a patient is referred to the practice and when a patient subscribes to an email list
For full details or where your data is stored, please ask to see Information Governance Procedures (M 217C).
We have established the following lawful bases for processing your data:
Our lawful bases for processing personal data:
- The legitimate interests of the dental practice
- Processing is necessary for the performance of a contract with the data subject or to take steps to enter into a contract
- Consent of the data subject
- To comply with our legal obligations
Our Article 9 conditions for processing special category data:
- Processing is necessary for health care purposes
- Processing necessary for identifying or keeping under review the existence or absence of equality of opportunity or treatment between groups of people with the view to enabling such equality to be promoted or maintained
- We obtain consent of the data subject to process criminal record checks
The reasons we process the data include:
- To maintain your contemporaneous clinical records
- To provide you with dental treatment, prevention and oral health advice
- To carry out financial transactions with you
- To send your personal data to the General Dental Council or other authority as required by law
- To communicate with you as and when required including appointment reminders, treatment plans, estimates and other communications about your treatment or the practice
- To communicate with your next of kin in an emergency
- If a parent or carer to communicate with you about the person you parent or care for
- To refer you to other dentists or doctors and health professionals as required
- To obtain criminal record disclosures for team members
- For debt recovery
- To continually improve the care and service you receive from us
The personal data we process includes:
Your name, address, gender, date of birth, medical history, dental history, family medical history, family contact details, marital status financial details for processing payment, your doctor’s details and details of treatment at the practice. We may process more sensitive special category data including ethnicity, race, religion, or sexual orientation so that we can meet our obligations under the Equality Act 2010, or for example to modify treatment to suit your religion.
The retention period for special data in patient records is a minimum of 11 years and may be longer for complex records or to meet our legal requirements. The retention period for other personal data is 2 years after it was last processed. Details of retention periods are available in the Record Retention (M 215) procedure available from the practice.
We obtain your personal details when you enquire about our care and service, when you join the practice, when you subscribe to our newsletter or register online, when you complete a registration or medical history form and when another practitioner refers you for treatment at our practice. Occasionally patients are referred to us from other official sources such as NHS clinics or hospitals.
You have the following personal data rights:
- The right to be informed about the collection and use of your personal data
- The right of access – to have a copy of the data we hold about you. Generally, we will not charge for this service
- The right to rectification – to correct the data we have if it is inaccurate or incomplete
- The right to deletion of your personal data (clinical records must be retained for a certain time period)
- The right to restrict processing of your personal data
- The right to data portability – to have your data transferred to someone else
- The right to object to the processing of your personal data
- Rights in relation to automated decision making and profiling
Further details of these rights can be seen in our Information Governance Procedures (M 217C) or at theInformation Commissioner’s website. Here are some practical examples of your rights:
- If you are a patient of the practice you have the right to withdraw consent for important notifications, newsletters, surveys or marketing. You can inform us to correct errors in your personal details or withdraw consent from communication methods such as telephone, email or text. You have the right to obtain a free copy of your patient records within one month
- If you are not a patient of the practice you have the right to withdraw consent for processing personal data, to have a free copy of it within one month, to correct errors in it or to ask us to delete it. You can also withdraw consent from communication methods such as telephone, email or text
We have carried out a Privacy Impact Assessment in Sensitive Information Map, PIA and Risk Assessment (M 217Q) and you can request a copy from the details below. The details of how we ensure security of personal data is in our Security Risk Assessment (M 217M) and Information Governance Procedures (M 217C).
Using our website and online forms
You can contact us, refer a patient, or register as a new patient using the forms on this website. The new patient form asks for your name, date of birth, email address, mobile number, address and postcode, the type of care you are looking for, whether you are exempt from NHS dental charges, the names and dates of birth of any family members you would like to register with you, whether you have any difficulty using stairs, whether you need an interpreter and which language, and your preferred day and time for an appointment.
We ask for these details because the purpose is to register you as a patient and create your record in our practice management system before your first visit. We would need this information in any case, so collecting it once through the form saves a longer exchange of emails and makes your first appointment quicker. Only your contact details are required. If you would rather not use the form, you can phone the practice on 01334 655752, email reception@cupardental.co.uk, or call in and we will take your details with you.
Our lawful bases are that processing is necessary to take steps at your request before entering into a contract for dental care, and the legitimate interests of the practice. Where your answers relate to your health or your access needs, we rely on the health care condition in Article 9 of the UK GDPR. If you give us details of family members, including children, please only do so if you are their parent or legal guardian, or are otherwise entitled to provide them.
The following organisations act as our data processors under contract and may handle this information on our behalf, and may only process it on our instructions: Hostinger, which hosts this website; Resend, which delivers the completed form to our practice inbox; Google Workspace, which provides our practice email; and Dentally, our practice management system, where your patient record is created.
To protect the forms from automated abuse we record the date and time of each submission and a one way encrypted version of the sender IP address. We also keep a copy of the completed form on the website server as a backup, so that an enquiry or registration is not lost if an email fails to arrive. That copy is held in a folder that is blocked from public access, and it is used only to recover a submission that did not reach us.
Cookies and website analytics
A cookie is a small file stored on your device by a website. This website uses a small number of essential cookies that are needed for pages and forms to work. These do not identify you personally and cannot be switched off.
We would also like to use Google Analytics to count visitors and see which pages are used most, so that we can improve the site. Google Analytics sets its own cookies and is provided by Google, who act as our processor for this. These analytics cookies are only set if you press Accept on the cookie message when you first visit. If you press Reject, no analytics cookies are set, nothing is stored on your device, and Google Analytics cannot recognise you or link your visit to any other visit. A single anonymous signal is still sent so Google knows to discard the visit rather than measure it.
You can change your mind at any time using the Cookie Settings link at the bottom of any page. We have also enabled IP anonymisation, so your full IP address is not stored by Google Analytics. We do not use analytics data to identify individual patients, and we do not use it for advertising.
Comments, suggestions and complaints
Please contact the IG Lead at the practice for a comment, suggestion or a complaint about your data processing at reception@cupardental.co.uk, by calling 01334 655752, or by writing to or visiting the practice at 7 Castle Street, Cupar, Fife KY15 4AU. We take complaints very seriously.
If you are unhappy with our response or if you need any advice you should contact the Information Commissioner’s Office (ICO). Their telephone number is 0303 123 1113, you can also chat online with an advisor. The ICO can investigate your claim and take action against anyone who’s misused personal data. You can also visit their website for information on how to make a data protection complaint.
Related practice procedures
You can also use these contact details to request copies of the following practice policies or procedures:
- Data Protection and Information Security Policy (M 233-DPT), Consent Policy (M 233-CNS)
- Sensitive Information Map, PIA and Risk Assessment (M 217Q), Information Governance Procedures (M 217C), Record Retention (M 215)
If you have an enquiry or a request, please contact us at Cupar Dental & Implant Centre Ltd, 7 Castle Street, Cupar, Fife KY15 4AU.
Email: reception@cupardental.co.uk
Phone: 01334 655752