Privacy Notice
This Privacy Notice sets out details of the information that Lumiere Clinic & Dr Kian Plastic Surgery may collect from you and how that information may be used. Please take your time to read this Privacy Notice carefully before you attend your appointment at the clinic.
About us: In this Privacy Notice, ‘us’, ‘our’ or ‘we’ refer to Lumiere Clinic & Dr Kian Tan (and including his medical secretaries, and his staff at Lumiere Clinic) who are using your personal information. In the event that you have any queries, comments or concerns in respect of the manner in which we have used, or potentially will use, your personal information then you should contact us and we would be happy to discuss further. Our contact details are:
Telephone: 0161 236 6500
Email: info@lumiereclinic.co.uk
Confidentiality: The confidentiality of your personal and medical information is of a paramount concern to us. We are committed to compliance with data protection legislation and medical confidentiality guidelines. In the course of our business, we may use third parties to process your personal and medical information on our behalf. Such processing is subject to contractual provisions regarding confidentiality and security, in addition to the obligations imposed by the data protection legislation.
Medical Information: Your Medical information will be kept confidential by password protected computers and secure practice management software. Your medical information will only be disclosed to those involved with your care. This include Dr Kian’s medical secretaries, staff at Lumiere Clinic, your GP and other independent practitioners / healthcare organisations. We will only keep your personal information for as long as reasonably necessary to fulfil the relevant purposes 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 periods for which your personal information will be stored, please contact us.
Personal information
As one of our patients, the personal information we hold about you may include the following:
a) Name
b) Contact details, such as postal address, email address and telephone number (including mobile number)
c) Financial information, such as credit card details used to pay us and insurance policy details
d) Occupation
e) Emergency contact details, including next of kin
f) Background referral details
Special Categories Personal Information
As one of our patients, we will hold information relating to your medical treatment which is known as a special category of personal data under the law, meaning that it must be handled even more sensitively. This may include the following:
- a) Details of your current or former physical or mental health, including information about any healthcare you have received from other healthcare providers such as GPs, dentists or hospitals (private and/or NHS), which may include details of clinic and hospital visits, as well as medicines administered. We will provide further details below on the manner in which we handle such information.
b) Details of services you have received from us
c) Details of your nationality, race and/or ethnicity
d) Details of your religion
e) Details of any genetic data or biometric data relating to you
f) Data concerning your sex life and/or sexual orientation
g) Photographs or images that are related to your medical condition and/or those taken by us
How do we collect your information?
We may collect personal information from a number of different sources including, but not limited to:
a) GPs
b) Dentists
c) Other hospitals, both NHS and private
d) Mental health providers
e) Commissioners of healthcare services
f) Other clinicians (including their medical secretaries)
Directly from you
Information may be collected directly from you when:
a. You use our services
b. You complete enquiry forms on the Lumiere Clinic or Dr Kian Plastic Surgery website
c. You submit a query to us including by email or by social media
d. You correspond with us by letter, email, telephone or social media.
From other healthcare organisations
Our patients may receive healthcare from other organisations, and so in order to provide you with the best treatment possible we may have to collect personal information about you from them. These may include:
- a) Medical records from your GP
b) Medical records from other clinicians (including their medical secretaries)
c) Medical records from your dentist
d) Medical records from the NHS or any private healthcare organisation
e) Medical records include information about your diagnosis, clinic and hospital visits and medicines administered.
From third parties
As detailed in the previous section, it is often necessary to seek information from other healthcare organisations. We may also collect information about you from third parties when:
You are referred to us for the provision of services including healthcare services
a. You are referred to us for the provision of services including healthcare services
b. We liaise with your current or former employer, health professional or other treatment or benefit provider
c. We liaise with your family
d. We liaise with your insurance policy provider
e. We deal with experts (including medical experts) and other services
f. We liaise with debt collection agencies
g. We liaise with Government agencies, including the Ministry of Defence, Home Office and HMRC
Communication: We may communicate with you in a range of ways, including telephone, SMS, email and/or post. If we contact you using the telephone numbers which you have provided and you are not available which results in the call being directed to a voicemail and/or answering service, we may leave a voice message including only sufficient basic details to enable you to identify the reason for the call and how to call us back. To ensure that we provide you with timely updates and reminders in relation to your healthcare (including basic administration information and appointment information (including reminders)), we may communicate with you by SMS and/or unencrypted email (where you have provided me with your SMS or email address) to provide you with your medical information (including test results and other clinical updates) and/or invoicing information, we may communicate with you by email where you have provided me with your email address. The first time we send you any important encrypted emails that we are not also sending by post or which requires action to be taken, we will endeavour to contact you separately to ensure that you are able to access the encrypted email you are sent. Please note that although providing your mobile number and email address and stating a preference to be communicated by a particular method will be taken as an affirmative confirmation that you are happy for us to contact you in that manner, we are not relying on your consent to process your personal data in order to correspond with you about your treatment. As set out further below, processing your personal data for those purposes is justified on the basis that it is necessary to provide you with a healthcare service.
Communicating with you and resolving any queries or complaints that you might have:
From time to time, patients may raise queries, or even complaints, with us and we take those communications very seriously. It is important that we are able to resolve such matters fully and properly and so we will need to use your personal information in order to do so.
Communicating with any other individual that you ask us to update about your care and updating other healthcare professionals about your care:
Other healthcare professionals or organisations may need to know about your treatment in order for them to provide you with safe and effective care, and so we may need to share your personal information with them.
Complying with our legal or regulatory obligations, and defending or exercising our legal rights:
As a provider of healthcare, we are subject to a wide range of legal and regulatory responsibilities which is not possible to list fully here. We may be required by law or by regulators to provide personal information, and in which case we will have a legal responsibility to do so. From time to time, clinicians are unfortunately also the subject of legal actions or complaints. In order to fully investigate and respond to those actions, it is necessary to access your personal information (although only to the extent that is necessary and relevant to the subject-matter).
Managing our business operations such as maintaining accounting records, analysis of financial results, internal audit requirements, receiving professional advice (e.g. tax or legal advice):
In order to do this, we will not need to use your special categories of personal information and so we have not identified the additional ground to use your information for this purpose.
Provide marketing information to you:
As a provider of private healthcare services, we need to carry out marketing but are mindful of your rights and expectations in that regard. As a result, we will only provide you with marketing which is relevant to our business and only where you have specifically confirmed your consent to do so.
Disclosures to 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) A doctor, nurse, carer or any other healthcare professional involved in your treatment
b) Other members of support staff involved in the delivery of your care, like receptionists and porters
c) Anyone that you ask me to communicate with or provide as an emergency contact, for example your next of kin or carer
d) NHS organisations, including NHS Resolution, NHS England, Department of Health
e) Other private sector healthcare providers
f) Your GP
g) Your dentist
h) Other clinicians (including their medical secretaries)
i) Third parties who assist in the administration of your healthcare, such as insurance companies
j) Private Healthcare Information Network
k) National and other professional research/audit programmes and registries, as detailed under purpose 4 above
l) Government bodies, including the Ministry of Defence, Home Office and HMRC
m) Our regulators, like the Care Quality Commission, Health Inspectorate Wales and Healthcare Improvement Scotland
n) The police and other third parties where reasonably necessary for the prevention or detection of crime
o) Our insurers
p) Debt collection agencies
q) Credit referencing agencies
r) Our third party services providers such as IT suppliers, actuaries, auditors, lawyers, marketing agencies, document management providers and tax advisers
s) Selected third parties in connection with any sale, transfer or disposal of our business
t) We may also use your personal information to provide you with information about products or services which may be of interest to you where you have provided your consent for me to do so.
We may communicate with these third parties in a variety of ways including, but not limited to, email, post, fax and telephone.
Clinic Audit: Lumiere Clinic is required to conduct audits of records, including medical information, for quality assurance purposes. Your personal and medical information will be treated in accordance with guidance issued by the Care Quality Commission and the relevant data protection legislation.
Account Settlement: We may share your personal information and limited medical information with any individual or organisation (or their agent) who/which may be responsible for meeting costs of your care (eg. medical insurance provider) to the extent that it is necessary to collect payment. We may share your personal information with third parties, to the extent necessary, for the purposes of billing, processing or collecting payments or obtaining credit referencing information. In the event that an invoice is not paid in full, we may share personal information with third parties, as is necessary to collect any unpaid amount. Please note that you will be liable for the costs of debt collection in addition to the costs of care, if the invoice is not settled in full.
Contact Details: We do not make the names, postal or email addresses and telephone numbers of Lumiere Clinic & Dr Kian Plastic Surgery patients/clients available to other organisations unless they are acting on our behalf. As the patient/client you are confirming that the email address you provide is your personal email address, that it is not shared by anyone else and that you agree to it being stored and used for communication purposes.
Your rights: Under data protection law you have certain rights in relation to the personal information that we hold about you. These include rights to know what information we hold about you and how it is used. You may exercise these rights at any time by contacting us using the details provided above. There will not usually be a charge for handling a request to exercise your rights. If we cannot comply with your request to exercise your rights we will usually tell you why. There are some special rules about how these rights apply to health information as set out in legislation including the Data Protection Act (current and future), the General Data Protection Regulation as well as any secondary legislation which regulates the use of personal information.
If you make a large number of requests or it is clear that it is not reasonable for us to comply with a request then we may not be able to respond or we may have to charge an administration fee.
Your rights include:
The right to access your personal information:
You are entitled to request for a copy of the personal information we hold about you and details about how we use it. Your information will usually be provided to you in writing, unless otherwise requested. If you have made the request electronically (e.g. by email) the information will be provided to you by electronic means where possible. Please note that in some cases we may not be able to fully comply with your request, for example if your request involves the personal data of another person.
You are entitled to the following under data protection law:
1. Under Article 15(1) of the GDPR we must usually confirm whether we have personal information about you. If we do hold personal information about you we usually need to explain to you:
i. The purposes for which we use your personal information
ii. The types of personal information we hold about you
iii. Who your personal information has been or will be shared with, including in particular organisations based outside the EEA.
iv. If your personal information leaves the EU, how we will make sure that it is protected
v. Where possible, the length of time we expect to hold your personal information. If that is not possible, the criteria we use to determine how long we hold your information for
vi. If the personal data we hold about you was not provided by you, details of the source of the information
vii. Whether we make any decisions about you solely by computer and if so details of how those decision are made and the impact they may have on you
viii. Your right to ask us to amend or delete your personal information
ix. Your right to ask us to restrict how your personal information is used or to object to my use of your personal information
x. Your right to complain to the Information Commissioner’s Office
- We also need to provide you with a copy of your personal data, provided specific exceptions and exemptions do not apply.
The right to rectification:
We take reasonable steps to ensure that the information we hold about you is accurate and complete. However, if you do not believe this is the case, you can ask us to update or amend it.
The right to erasure (also known as the right to be forgotten):
We may update this Privacy Notice from time to time to ensure that it remains accurate, and the most up-to-date version can always be found on our websites (www.lumiereclinic.co.uk; www.drkianplasticsurgery.co.uk) In the event that there are any material changes to the manner in which your personal information is to be used then we will provide you with an updated copy of this Privacy Notice. In some circumstances, you have the right to request that we delete the personal information we hold about you. However, there are exceptions to this right and in certain circumstances we can refuse to delete the information in question. In particular, for example, we do not have to comply with your request if it is necessary to keep your information in order to perform tasks which are in the public interest, including public health, or for the purposes of establishing, exercising or defending legal claims.
The right to restriction of processing:
In some circumstances, we must “pause” our use of your personal data if you ask us to do so, although we do not have to comply with all requests to restrict our use of your personal information. In particular, for example, we do not have to comply with your request if it is necessary to keep your information in order to perform tasks which are in the public interest, including public health, or for the purposes of establishing, exercise or defending legal claims.
The right to data portability:
In some circumstances, we must transfer personal information that you have provided to you or (if this is technically feasible) another individual/ organisation of your choice. The information must be transferred in an electronic format.
The right to object to marketing:
You can ask us to stop sending you marketing messages at any time and we must comply with your request. You can do this by contacting us.
The right to withdraw consent:
In some cases we may need your consent in order for our use of your personal information to comply with data protection legislation. Where we do this, you have the right to withdraw your consent to further use of your personal information. You can do this by contacting us.
The right to complain to the Information Commissioner’s Office:
You can complain to the Information Commissioner’s Office if you are unhappy with the way that we have dealt with a request from you to exercise any of these rights, or if you think we have not complied with our legal obligations. More information can be found on the Information Commissioner’s Office website: https://ico.org.uk. Making a complaint will not affect any other legal rights or remedies that you have.
Updates to this Privacy Notice: We may update this Privacy Notice from time to time to ensure that it remains accurate. This Privacy Notice was last updated on 1st June 2018.
