PRIVACY POLICY

OUR PRIVACY POLICY STATEMENT

This Privacy Policy explains how and why Stroud Sports Clinic Ltd (SSC) collects and uses personal information, and what we do to ensure it is kept private and secure.

This Policy sets out the following:

1. About SSC (and how to contact us)
2. Our relationship to our data processor
3. What information we collect
4. Why we need your information
5. How we use your information
6. Website visitors and cookies
7. Other recipients of information
8. Communications
9. Storing your data
10. Keeping your data safe
11. Your rights
12. Updates to this Policy
 
1. About SSC (and how to contact us)

Stroud Sports Clinic Ltd (SSC) is an independent private sports injury clinic offering a variety of physio, sports and holistic therapies as well as exercise prescription, personal training and strength and conditioning. Incorporated in England and Wales with number 07978817. Our registered office is at Ebley Wharf Mill, Ebley, Stroud, Gloucestershire, GL54SR. 

You can contact us with questions about this Policy or your personal data by writing to our office address, telephoning 01453 762369 or emailing info@stroudsportsclinic.com.

For the purposes of data protection law we will be a controller of your personal information in some situations (this means we make decision about how and why your information is used, and have a duty to ensure your rights are protected). In other situations we will be processor of your information (meaning we have no control of your information and only act on the instructions of your Service Provider).

2. Our relationship to our data processor

Our clinic uses Cliniko electronic medical records service (EMR) (www.cliniko.com) to store all data. This is an online service that we have ensured is compliant with all GDPR data regulations (to see how our EMR stores and processes your information, please follow the attached weblink https://www.cliniko.com/policies/privacy)

You can book an appointment by either navigating to our website, contacting the clinic via telephone or directly through reception or your therapist/practitioner. In order to effectively process any booking and to allow us to provide services to you, we need to gather certain personal data about you. This includes name, and contact information, acceptance of our privacy policy and pertinent medical data and treatment notes as recorded by your therapist.      

3. What information we collect

We may collect some or all of the following information on individuals who use our services:
  • Personal details (such as your name, address, date of birth, telephone number and email)
  • Relevant medical information (such as treatment notes, relevant medical history, third party medical information shared by you, assessment results and rehab/exercise programs.)
We may also store information about your payment history, including missed payments and unpaid debts. If you telephone us we may record that conversation for training or security purposes or in order to establish, defend or conduct a legal claim. We will also keep a record of correspondence (including emails and letters) between us and you. We do not store any financial information such as credit/debit card numbers.

4. Why we need your information

We will only use your information with your consent, or because we need to use the information:
  • To deliver our clinical services
  • Enter into, or perform, a contract with you
  • Comply with a legal duty
  • For our own (or a third party’s) lawful interests, provided your rights don’t override the these (this includes operating our business, and recovering unpaid debts)
In any event, your information will only be used for the purpose(s) it was collected for (or another closely related purpose, such as keeping records where necessary).

5. How we use your information

We use different types of information for different purposes. These are described below.

Identifying information and contact details

We collect basic information (such as your name and date of birth) in order to enable us to identify you and for to provide you with services. We also collect contact details so that we can contact you and send you relevant treatment information.

Health data and other sensitive information

In some cases SSC may request sensitive personal information (such as medical history or ethnicity). If you have any questions or concerns about your sensitive information, you should contact us directly.

Financial information

SSC will use your financial information to collect and process payments, and will act as a data controller in respect of this information. We do not charge subscriptions or other such fees unless specifically agreed with a patient.

If you fail to pay sums that are due (for example a treatment fee), SSC will contact you, In these situations we may use your information (including contact details, and information about your payment history and dealings with us) in connection with debt recovery or assignment. If this does occur, either us or the debt collection agency will contact and let you know. We may also share relevant information with HM Courts and Tribunals Service and our professional advisers.

6. Website visitors and cookies

Visitors to our website

We don’t normally collect or process personal information about visitors to our website unless they choose to provide information (such as booking an appointment or signing up to our newsletter). We may collect non-personal information about visitors to our website as this helps us optimise and improve the website. This information might include your internet protocol address, the browser being used to connect to our site, the device (e.g. its operating system) and the connection type (e.g. the Internet service provider used). However, none of this information will directly identify you.

Other websites

Our website may include hyperlinks to other websites. We are not responsible for the content or functionality of any of those external websites.  If an external website requests personal information from you, the information you provide will not be covered by this Policy. We suggest you read the privacy policy of any website before providing any personal information.

Google Analytics Cookies

We also use Google Analytics to track usage of our website and collect details of repeat visits. These cookies do not collect any personal information about you. Google Analytics Privacy 

The cookies will identify your browser, the times and dates that you interacted with our site and the marketing materials or referring pages that led you to our website. We use this information to compile reports (e.g. regarding the number of visitors to the site, where visitors have come to the site from and the pages they visited) and to help us improve the website. This information is anonymous and will not identify you.

7. Other recipients of information

We respect the privacy of your information and will never sell or trade your personal data.

We will share information with our EMR (our Data Processor) and subsequent third party providers because this is necessary in order for us to provide you with services (please see section 2 and 3 above for further details). If you have questions regarding SSC’s use of your data, you should contact us directly.

8. Communications

We may contact you by email, telephone or post with updates or information about your account with us, notifications regarding your payments and also with updates for classes, opening times and events and to our terms of business or this Policy.

Marketing communications

We do send marketing emails, which contain information about The Fifth Dimension and our services, to members we think might be interested in them. If you receive such an email, it could be because you are an existing client or have enquired about our services. 

If you receive marketing communications from us, you can change how you hear from us or unsubscribe at any time. You can do this emailing or by writing to Stroud Sports Clinic Ltd,The Fifth Dimension, Ebley Wharf Mill, Ebley, Stroud, Glos, GL54SR, emailing info@stroudsportsclinic.com or calling 01453 762369

If you have received a marketing communication in error and wish to complain then please contact info@stroudsportsclinic.com.

9. Storing your data

We only store personal information for as long as required in order to fulfil the purpose it was collected for (or for a related compatible purpose, such as keeping a record of a treatment).

We regularly review what data we have and delete that which is no longer necessary. You also have a right to request that your data be deleted (the right to be forgotten), please see section 11 for further details.

Your information is not retained for a fixed period, and instead we keep it on file until we are satisfied that there is no longer a reasonable prospect you might make any claim or ask for any treatment information. Once you cease using our services, we will restrict the use of this information so that it is securely stored and only accessed in the event of such a claim.

Certain parties have access to Cliniko with various levels of access to data. All users have password access. Our clinical and exercise lead and financial director have access to Cliniko as Administrators. This allows full access to all aspects of our EMR. Therapists have practitioner access, meaning they have access to all patient treatment notes, the practice calendar and financial records kept on the system. Schedulers have access to the clinic’s calendar and patient contact information. They can also input new patient information for bookings.

We also use the following sub-contracted services that may import data form Cliniko in order to provide additional services. These companies have been selected due to their integration ability with our EMR and due to their compliance with GDPR legislation. To view each services privacy policy, please follow the associated web links.

Track Active – (based in Australia) Imports a patient’s name, and contact information in order to offer exercise programs. (http://www.trackactive.co/privacy-policy/).

Finger Ink – (based in Australia) Imports a patient’s contact information and transfers informed consent, acceptance of clinic privacy and pertinent medical information back to Cliniko. This program is used to gather pertinent data for our practitioners to provide services (https://finger-ink.com/privacy).

Mailchimp – Used for marketing purposes and is fully GDPR compliant. (https://mailchimp.com/legal/privacy/)

PT Distinction – Used as a bespoke online personal training service, providing programs and health data to subscribers. This is a non-intergrated service and is run independently. (https://www.ptdistinction.com/terms/privacy.php).

Best Reception – Recieves phone calls and can book appointments for a patient, as well as deals with general enquiries. Has scheduler access to Cliniko.

International Transfers

Cliniko is an Australian company however is fully committed to GDPR regulations necessary in the EEA and UK, it has a European Data Protection Officer to ensure it safeguards your data to any future data protection changes. These safeguards will usually be contractual and/or the result of a European Union decision which allows the transfer (such as a US organisation which is certified under the EU-US Privacy Shield framework).

Incorrect information

If you believe that any information we are holding on you is incorrect or incomplete, please write to Stroud Sports Clinic, The Fifth Dimension, Ebley Wharf Mill, Ebley, Stroud, Glos, GL54SR, or emailing info@stroudsportsclinic.com

10. Keeping your data safe

We employ a variety of physical and technical measures to keep your personal data safe and to prevent unauthorised access to, or use or disclosure of it. Electronic data and databases are stored on secure computer systems and we control who has access to them (using both physical and electronic means). We have checked and conatced each service provider we use to ensure they are compliant with current data protection guidelines. However, we cannot absolutely guarantee the security of the internet or external networks or your own device, accordingly any online communications (e.g. information provided by email or through our website) are at your own risk.

11. Your rights

We want to ensure you remain in control of your personal information. Part of this is making sure you understand your legal rights, which are as follows:
  • the right to confirmation as to whether or not we have your information and, if we do, to obtain a copy of the personal data;
  • (from 25 May 2018) the right to have certain information provided to you in a portable electronic format, or transmitted to another data controller, where technically feasible;
  • the right to have inaccurate data rectified;
  • where personal data is processed on the basis of your consent, the right to withdraw that consent;
  • the right to object to your data being used for marketing or for legitimate interests purposes;
  • the right to restrict how your personal information is used; and
  • the right to be forgotten, which allows you to have your data erased in certain circumstances (though this is not an absolute right and may not apply if we need to continue using the information for a lawful reason).
If you would like further information on your rights or wish to exercise them, please write to Stroud Sports Clinic,, The Fifth Dimension, Ebley Wharf Mill, Ebley, Stroud, Glos, GL54SR, or emailing info@stroudsportsclinic.com making sure that you state your request clearly.

Please keep in mind that there are exceptions to the rights above and, though we will always try to respond to your satisfaction, there may be situations where we are unable to do so (for example, because the information no longer exists or there is an exception which applies to your request).

If you are not happy with our response, or you believe that your data protection or privacy rights have been infringed, you should contact the UK Information Commissioner’s Office, which oversees data protection compliance in the UK. Details of how to do this can be found at www.ico.org.uk.

12. Updates to this Policy

SSC may update this Policy at any time. When we do, we will post a notification on the main page of our website, revise the updated date at the bottom of this page. We encourage users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect.
 
This policy was last updated on 25 May 2018.
 
Contact

All comments, queries and requests relating to our use of your information are welcomed and should be addressed to:

Stroud Sports Clinic
The Fifth Dimension
Ebley Wharf Mill
Ebley
Stroud
Glos, 
GL54SR, 

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