Your Privacy Is Important to us.
KEATS HEALTH CLINIC
GDPR 2018 PRIVACY NOTICE
Scope
This document refers to personal data, which is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain.
The General Data Protection Regulation (GDPR) which is EU wide and far more extensive than its predecessor the Data Protection Act, along with the Privacy and Electronic Communications Regulations (PECR), seek to protect and enhance the rights of EU data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU and its storage within the EEA.
1 — Keats Health Clinic situated at 18a London Road Enfield EN2 6EB is pleased to provide the following information:
2 — Who We Are
Keats Health Clinic diagnoses and treats health conditions. Treatments are carried out in accordance within each individual therapists official governing body and comply with their code of ethics and practice standards.
3 — Personal Data
a) For the purposes of providing treatment, Keats Health Clinic may require detailed medical information. We will only collect what is relevant and necessary for your treatment. When you visit our practice, we will make notes which may include details concerning your medication, treatment and other issues affecting your health. This data is always held securely, is not shared with anyone not involved in your treatment, although for data storage purposes it may be handled by pre-vetted staff who have all signed an integrity and confidentiality agreement. To be able to process your personal data it is a condition of any treatment that you give your explicit consent to allow Keats Health to document and process your personal medical data. Contact details provided by you such as telephone numbers, email addresses, postal addresses may be used to remind you of future appointments and provide reports or other information concerning your treatment. As part of our obligations as primary healthcare practitioners there may be circumstances related to your treatment, on-going care or medical diagnosis that will require the sharing of your medical records with other healthcare practitioners e.g. GPs, consultants, surgeons and/or medical insurance companies. Where this is required we will always inform you first unless we are under a legal obligation to comply.
b) For marketing purposes, Keats Health Clinic may also use the contact details provided by you to respond to your enquiries, including making telephone contact and emailing information to you which the practice believes may be of interest to you.
c) In making initial contact with the practice you consent to Keats Health Clinic maintaining a marketing dialogue with you until you either opt out (which you can do at any time) or we decide to desist in promoting our services. Keats Health Clinic do not broker your data and you can ask to be removed from our marketing database by emailing or phoning the practice using the contact details provided at the end of this Privacy Notice.
d) Some basic personal data may be collected about you from the marketing forms and surveys you complete, from records of our correspondence and phone calls and details of your visits to our website, including but not limited to, personally identifying information like Internet Protocol (IP) addresses.
e) Keats Health Clinic will only collect the information needed so that we can provide you with the services you require, the business does not sell or broker your data.
4 — Legal basis for processing any personal data
To meet our contractual obligations obtained from explicit Patient Consent and legitimate interest to respond to enquiries concerning the services provided.
5 – Legitimate interests pursued by Keats Health Clinic
To promote treatments for patients with all types of health problems.
6 — Consent
Through agreeing to this privacy notice you are consenting to Keats Health Clinic processing your personal data for the purposes outlined. You can withdraw consent at any time by using the postal, email address or telephone number provided at the end of this Privacy Notice.
7 — Disclosure
Keats Health Clinic will keep your personal information safe and secure, only staff engaged in providing your treatment will have access to your patient records although the on-site administrative staff accesses the medical notes to update contact information and add other administrative data. Our administration team will have access to your contact details so that they can make appointments and manage your account. Keats Health Clinic will not disclose your Personal Information unless compelled to, in order to meet legal obligations, regulations or valid governmental requests. The practice may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of its staff.
8 – Retention Policy
Keats Health Clinic will process personal data during the duration of any treatment and will continue to store only the personal data needed for eight years after the contract has expired to meet any legal obligations. After eight years all personal data will be deleted, unless basic information needs to be retained by us to meet our future obligations to you, such as erasure details. Records concerning minors who have received treatment will be retained until the child has reached the age of 25.
9 – Data Storage
All Data is held in the United Kingdom. Keats Health Clinic does not store personal data outside the EEA.
10 – Your rights as a data subject
At any point whilst Keats Health Clinic is in possession of, or processing your personal data, all data subjects have the following rights:
• Right of access — you have the right to request a copy of the information that we hold about you.
• Right of rectification — you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten — in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing — where certain conditions apply you have a right to restrict the processing.
• Right of portability —you have the right to have the data we hold about you transferred to another organisation.
• Right to object — you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling — you also have the right not to be subject to the legal effects of automated processing or profiling.
In the event that Keats Health Clinic refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge. At your request Keats Health Clinic can confirm what information it holds about you and how it is processed.
11 – You can request the following information:
• Identity and the contact details of the person or organisation (Keats Health Clinic) that has determined how and why to process your data.
• Contact details of the data protection officer, where applicable.
• The purpose of the processing as well as the legal basis for processing.
• If the processing is based on the legitimate interests of Keats Health Clinic and information about these interests.
• The categories of personal data collected, stored and processed.
• Recipient(s) or categories of recipients that the data is/will be disclosed to.
• How long the data will be stored.
• Details of your rights to correct, erasure, restrict or object to such processing.
• Information about your right to withdraw consent at any time.
• How to lodge a complaint with the supervisory authority (ICO).
• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
• The source of personal data if it wasn’t collected directly from you.
• Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
12 – To access what personal data is held, identification will be required
Keats Health Clinic will accept the following forms of identification (ID) when information on your personal data is requested: a copy of your driving licence, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required.
13 – Complaints
In the event that you wish to make a complaint about how your personal data is being processed by Keats Health Clinic you have the right to complain to us. If you do not get a response within 30 days, you can complain to the ICO.
The details for each of these contacts are:
Keats Health Clinic
18a London Road, Enfield, Middx EN2 6EB
info@keatshealth.co.uk
www.keatshealth.co.uk
+44 (0) 208 366 2300
ICO
Wycliffe House, Water Lane, Wilmslow, SK9 5AF Telephone
+44 (0) 303 123 1113
Compliments, Comments & Complaints Policy.
1. Keats Health Clinic Values
Keats is dedicated to enabling people to achieve best possible wellness in a supportive
and confidential space, free from prejudice, whether that be virtual or in person.
We strive for excellence in everything that we do, but we realise that sometimes we
may get things wrong. We welcome and value feedback as this enables us to listen,
learn, and to improve what we do and how.
Your compliments, comments and complaints help us continue to strive for excellence
and help to give all our clients and patients the best possible treatment.
2. Who this policy is for
This policy applies to individuals (members of the public) and organisations wishing to
comment on, compliment or complain about the performance of the work from any
of Keats Health Clinic Directors or Keats premises condition
• co-ordination of therapists
• communication
• premises condition
• public relations
3. What this policy does not cover
This policy does not cover complaints about the quality of individual therapy received
by an therapist in the Keats Team. If you have any complaints about an individual
therapist, you should follow the individual therapist’s complaints procedure. This
usually involves speaking to the therapist about the complaint you have in the first
instance. If you are not satisfied about their response, please let us know. We can
also give you information about how you can complain to the therapist’s regulatory.
3. Complimenting us
Compliments are valuable and important to us and when they are received, they will
be recorded and reported on. Compliments enable us to:
· Understand from our supporters what we do well and the positive
difference this makes;
· Provide positive feedback to our people in the local community
· Influence the continued development of what we do, why and how.
We will endeavour to acknowledge compliments wherever possible but whilst this may
not always be practicable, please be assured that they are always appreciated.
With your permission, we would like to use your compliments on our website.
4. Feedback
It is always helpful to hear what people think about us; what we do and how.
Any comments are welcome because they:
· Help to influence the organisational decisions we may make;
· Help maintain the standards of our activities;
· Raise issues of real importance and can lead to change for the better.
Wherever we can, we will record and report, internally and externally if required, on
comments we receive.
We will also endeavour to acknowledge comments wherever possible but whilst this
may not always be practical, please be assured that they are always appreciated.
5. Complaining
We recognise that there will be times when we may make mistakes or
get things wrong. Where this happens and where we receive a complaint, we will
always take this seriously, record and report on it internally and externally if required,
and deal with it in a timely manner.
We will always take steps to maintain the confidentiality of your personal information.
We will only disclose it to people who need to look into a complaint, and, rarely, to
others where we are legally permitted to do so.
6. Defining a ‘complaint’
We define a complaint as “an expression of dissatisfaction, however made,
about actions taken or a lack of action by Keats Directors”
Where it is unclear whether a communication is indeed a complaint, we will
endeavour to confirm this with you, in so far as we can. If the communication or
comment is done anonymously, we may not be able to treat it as a complaint under
this policy.
The following issues (this is not an exhaustive list) will be treated as complaints as
they touch upon Keats purpose and values:
• Poor standards of service including accusations of professional
incompetence/misconduct;
• Financial losses/waste;
• Current or non-current (historic) harm to children or vulnerable individuals.
• Criminality within or involving Keats;
• Keats well– being deliberately used for significant private advantage
• Non-compliance with Keats own policies/procedures;
• Non-compliance with relevant laws and regulations.
Please note: under certain circumstances we may not be able to deal with/respond to
a complaint including where:
· You have not identified yourself or provided your contact details;
· Your complaint is not about Keats;
· Your expression of the complaint is insufficiently clear;
· Your complaint has been sent to us and other organisations as part of a bulk
mailing or email.
–
Keats will still take complaints seriously and deal with them appropriately,
including contacting you where we are able to, to discuss the matter further.
7. Sharing your compliments, comments & complaints with us
– Email: info@keatshealth.co.uk
Keats Health Clinic
18a London Road
Enfield
EN2 6EB
8.Our process for dealing with complaints
Where a complaint has been submitted in accordance with section 7 of this policy,
Keats will endeavour to acknowledge your complaint within 20 working days,
explain the process that will be followed and when a decision will be made.
During our Christmas and Summer break you will hear from us when we
are back in January/September.
Following a thorough and fair investigation by us to establish the facts surrounding
the complaint, we will always attempt to provide a full, written response within 20
working days. There may be occasions where this is not possible, and we will
always notify you of this and advise you of the date by which you are likely to receive
a response to your complaint against Keats.
When notifying you of the outcome of our investigation and any follow up action
taken, we will confirm to whom you should submit an appeal in the event that you
wish to contest the outcome. An appeal must be submitted in writing within 20
working days from the date of the letter notifying you of the outcome and must satisfy
one or more of the criteria in section 9 below.
9.Appealing our response
Any appeal must be made in writing and satisfy one or more of the following criteria:
· You have new, relevant information to present (which you have not
previously submitted);
· We have failed to consider adequately or at all information you provided in
connection with the complaint;
We will always attempt to provide a full response to your appeal within 20
working days. There may be occasions where this is not possible, and where this is
the case, we will always advise you and notify you of a date by when you may
receive a response.
Our outcome response, which will always be in writing, is final and there will be no
further redress within the Keats. Listed in Section 10 below, however, are
external organisations to whom you may refer.
10.Taking your complaint outside of Keats Health Clinic
In the event that you remain dissatisfied with the response you have received, you
are entitled to take your concerns to any relevant statutory body which the relevant
practitioner is a member of.
11. Legal Framework & Guidance
This Complaints Policy takes into account relevant legal requirements, regulations
and guidance, including:
· The Children Acts 1989 and 2004;
· Working Together to Safeguard Children 2024;
· Data Protection Act 2018
·
12, Review process
This policy will be renewed annually.
Approved 09/04/2025