Colosseum Dental UK Limited (“Colosseum”) 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 patients 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
Colosseum Dental UK Limited.
Our limited company registered in England under company number 5947797.
Registered address: Staverton Court, Staverton, Cheltenham GL51 0UX.
Main trading address: The Beehive, City Place, Gatwick, West Sussex RH6 0PA.
Data Protection Officer: Laura Colton.
Email address: DPO@Colosseumdental.co.uk.
Telephone number: 01293 515500.
Postal Address: The Beehive, City Place, Gatwick, West Sussex RH6 0PA.
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, contact details, medical history, dental health records 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, the Privacy Notice may be supplemented by specific information provided to patients during the course of their dealings with your organisation and particularly in the context of any specific disclosures of their personal data but you can always contact us to find out more or to ask any questions using the details in Part 12.
b) The right to access the personal data we hold about you. Part 11 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 12 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 have. Please contact us using the details in Part 12 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 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 with you, and that data is processed using automated means, you can ask us for a copy of that personal data e.g. to re-use with another service or business in many cases.
h) Rights relating to automated decision-making and profiling. We do not use your personal data for automated decision-making or 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 12.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
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.
You can contact them by phone on 0303 1231113
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):
- Date of birth;
- Email address;
- Telephone number;
- Business name;
- Job title;
- Payment information;
- Information about your preferences and interests;
- Medical history information;
- Social habits;
- Dental health information;
- Dental assessments;
- Dental needs;
- Past dental treatments;
- Assessments and treatment information from Colosseum. Your personal data is obtained from the following third parties:
- Referring care providers.
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. Your personal data will be used for the following purposes:
- Supplying our services to you. Your personal details are required in order for us to enter into a contract with you to carry out our NHS dental contract;
- Personalising and tailoring our services for you.
- Communicating with you. This may include responding to emails or calls from you;
- Supplying you with information by email and post that you have opted-in to (you may unsubscribe or opt-out at any time by informing the practice manager);
- Public services through NHS Dental services;
- Compliance with legal obligations – this ground does not afford you the same breadth of rights available where public task or legitimate interests are relied upon
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, phone, text or post with information, news, and offers on our services.
We will always work to protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
7. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary so we may use it for the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods:
- 11 years from last appointment;
- Until the age of 25 – whichever is longer.
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.
We will only transfer your personal data for certain treatment and only with your consent to countries that the European Commission has deemed to provide an adequate level of personal data protection. More information is available from the European Commission.
Please contact us using the details below in Part 12 for further information about the particular data protection mechanism used by us when transferring your personal data to a third country.
9. Automated Decision Making and Profiling
We do not undertake automated decision making or profiling.
10. Do You Share My Personal Data?
We will not share any of your personal data with any third parties for any purposes, subject to one important exception and only with your consent.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority such as CQC or the GDC, insurers and/or legal advisors or NHS England.
If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.
If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 8.
Professionals employed or engaged by Us may disclose personal data in accordance with their professional Codes of Conduct where such disclosures are lawful.
Personal data may be transferred in the context of the sale or transfer of all or any part of Our business.
Personal data is also disclosed when we refer you to other practices, we will only refer with your consent.
11. How Can I Access My Personal Data?
If you want to know what personal data we have 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 12. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
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 30 days of receiving it. 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.
Subject Access Rights are not absolute but are subject to a number of limitations contained in the GDPR.
12. 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 for the attention of Laura Colton:
Email address: DPO@Colosseumdental.co.uk.
Telephone number: 01293 515500.
Postal Address: Colosseum Dental UK Ltd, The Beehive, City Place, Gatwick, West Sussex RH6 0PA.
13. Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be made available in paper format in practice or on our website www.colosseumdental.co.uk