Privacy policy

BACKGROUND:

The Reform Clinic understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our customers and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

1. Information About Us

The Reform Clinic Limited is a limited company registered in Scotland under company number SC595798 with its registered address at 4/4, 460 Sauchiehall Street, Glasgow, G2 3JU, Scotland.
Main trading address: 7a The Craft Workshops, The Hidden Lane, 1103 Argyle Street, Glasgow, G3 8ND.
Data Protection Officer: Michael Nicholson.
Email address: info@reformclinic.com.
Telephone number: 07785768780.
Postal Address: 7a The Craft Workshops, The Hidden Lane, 1103 Argyle Street, Glasgow, G3 8ND.

2. What Does This Notice Cover?

This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data. 

3. What is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in Part 5, below

4. What Are My Rights?

Under the GDPR, you have the following rights, which we will always work to uphold:

a) The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
b) The right to access the personal data we hold about you. Part 10 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 11 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
h) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
i) Rights relating to automated decision-making and profiling.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.
Further information about your rights can also be obtained from the Information Commissioner’s Office.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

5. What Personal Data Do You Collect?

We may collect some or all of the following personal data (this may vary according to your relationship with us):
• Name;
• Date of birth;
• Gender;
• Address;
• Email address;
• Telephone number;
• Business name;
• Job title;
• Profession;
• Payment information;
• Information about your preferences and interests;
• Special categories of data relating to your treatment (this may include details of your current and former physical and mental health and information about any healthcare you have received or need);
• Emergency contact details, including next of kin.
• Background referral details.
If you provide personal information to us about other individuals (including health or financial information) you should inform the individual about the contents of this Privacy Notice. We will process such information in accordance with this Privacy Notice.

The confidentiality of your medical information is important to The Reform Clinic. We make every effort to prevent the unauthorised access to and use of information relating to your current or former physical and mental health. In doing so, The Reform Clinic complies with UK data protection law, including the Data Protection Act 2018, and all applicable medical guidelines issued by professional bodies.

6. How Do You Use My Personal Data?

Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. The personal data we collect will depend on your relationship with us. Your personal data may be used for one of the following purposes:

• We may use “special categories of personal information” (otherwise known as “special categories of data”) about you, such as information relating to your physical and mental health. For example, if you are a patient we will need to use information about your health in order to treat you.
• Supplying our products and services to you. Your personal details are required in order for us to enter into a contract with you.
• Personalising and tailoring our products and services for you.
• Communicating with you. This may include responding to emails or calls from you.
• Supplying you with information by email that you have opted-in to (you may unsubscribe or opt-out at any time by contacting us).
• If you provide personal information to us about other individuals (including financial or medical information) you should inform the individual about the contents of this Privacy Notice. We will process such information in accordance with this Privacy Notice.
• We may also use your personal data for marketing purposes to provide you with information about products or services which may be of interest to you where you have provided your consent for us to do so. If you no longer wish to receive marketing emails sent by us, you can click on the “unsubscribe” link that appears in all our emails, otherwise you can contact us using the details set out in Part 11 to update your contact preferences.

An automated decision is a decision made by computer without any human input, and there will be no automated decision-making in relation to your treatment. We may, however, decide to carry out automated-profiling in respect of your personal information, which is automated processing to evaluate certain characteristics in order for us to provide more tailored marketing. We may then focus our marketing to you depending on the outcome of that profiling. This could include targeted ads through social media platforms such as Facebook, Twitter and LinkedIn.

7. How Long Will You Keep My Personal Data?

We will only keep your personal data for as long as longer reasonably necessary to fulfil the relevant purposes for set out in this Privacy Notice and in order to comply with our legal and regulatory obligations.
If you would like further information regarding the period for which your personal data will be kept, please contact us.

8. How and Where Do You Store or Transfer My Personal Data?

We will only store or transfer your personal data in the UK. This means that it will be fully protected under the GDPR.

9. Do You Share My Personal Data?

From time to time, we may share your personal data with third parties. We may disclose your information to the third parties listed below for the purposes described in this Privacy Notice. This might include:

• A doctor, nurse, carer or any other healthcare professional involved in your treatment
• Other members of support staff involved in the delivery of your care
• Anyone that you ask us to communicate with or provide as an emergency contact, for example your next of kin or carer
• NHS organisations
• Other private sector healthcare providers
• Your GP
• Your dentist
• Your clinician
• Third parties who assist in the administration of your healthcare, such as insurance companies
• National and other professional research
• Government bodies, including Ministry of Defence and HMRC
• Any healthcare regulators
• The police and other third parties where reasonably necessary for the prevention or detection of crime
• Our insurers
• Debt collection agencies
• Credit referencing agencies
• Our third party service providers
• Selected third parties in connection with any sale, transfer or disposal of our business

We may communicate with these third parties in a variety of ways including, but not limited to, email, post, fax and telephone.

10. How Can I Access My Personal Data?

If you want to know what personal data we hold about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within 28 days. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

11. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:

Email address: info@reformclinic.com.
Telephone number: 07785768780.
Postal Address: 7a The Craft Workshops, The Hidden Lane, 1103 Argyle Street, Glasgow, G3 8ND.

12. Changes to this Privacy Notice

We may change this Privacy Notice from time to time to ensure it remains accurate. In the event that these changes result in any material difference to the manner in which we process your personal data then we will post an updated Privacy Notice on our website.

This Privacy Notice was last updated on 17 August 2018.