Digital Marketing and Privacy Policy

INTRODUCTION

1. Connective Chiropractic Limited (“Connective Chiropractic”) are committed to
safeguarding the privacy of our customers, website visitors and service users. 

DATA CONTROLLER

2. Connective Chiropractic are data controllers for the purposes of this policy and in compliance with the General Data Protection Regulation, effective from 25 May 2018 (“GDPR”)

3. Connective Chiropractic are registered with the Information Commissioners Office

DATA PROTECTION OFFICER

4. Connective Chiropractic have decided that a Data Protection Officer is not required for their activities to be compliant with GDPR

DATA PROCESSING

5. Connective Chiropractic hold and process data under varying legal basis (See Appendix One; legal basis) Our most common processes are detailed as follows:

5a:Patient Record Cards and Financial Information – Legal Basis

Legal Basis, Retention: 8 years

Specialist data: Record cards, including name, address, phone number, email, medical history, diagnosis, prognosis, treatment information and credit card details. Medical and treatment information shared across team.

Paper documents, shredded after use. Scanned and stored/backed up on
encrypted storage and cloud based storage systems with 2-factor authentication. Maintained via booking system, secured with 2-factor authentication.

PracticeHub / Google Drive / Dropbox

5b: Booking system; Reminder and Text Emails, Financial Data

Contract basis, Retention, along with record cards: 8 years

Digital, cloud based system, including name, address, phone number, date of birth and medical records. Also link to ‘Stripe’ credit card management
(Encrypted information)

PracticeHub / Stripe

5c:Newsletter management

Consent / Contract basis (B2C / B2B): Annually assessed opt in/out

Digital, cloud based information: Name, email address

Mailchimp

5d:Surveys

Consent basis: Deleted after use in line with consent terms

Digital, cloud based: name, email address

SurveyMonkey

5eDirect Debit Processing

Consent basis: Deleted after expiry of direct debit (annual check)

Name, address, account details

GoCardless

5fCard Payments

Consent basis: Stored in line with card company process, no other
processing

Card information (encrypted), email address

Dojo

5gExternal premises and Internal Communal Area Camera Footage

Legal/Legitimate interest: Deleted on rolling basis or after 30 days. Sharing with police as legally required to do so. 

Audiovisual footage of clinic. Accessed only by practice manager or owner

Verisure, Ring, Tapo

5hTelephone System

Legitimate Interest / Consent: Deleted annually

Recording of telephone calls for monitoring and training purposes

4Com / Hihi

5iPhotographs and Testimonials

Consent basis – retained until consent changed or no lawful basis

Online, public domain, clinic literature, Social media, Google, Website

5jGP and Insurance Company Letters / External Referrals

Consent / Vital interests / Legitimate Interests – Annual deletion of emails,
Audit record of decision making and copies kept with record card

Digital/Letter, name, date of birth, email address, sensitive data: medical
information

Legitimate interest grounds to provide adequate sharing of information for
wider interdisciplinary health care or needs. Consent to do so will be
confirmed at clinic onboarding/initial consultation, with ability to opt out.
Ability to share information if vital interest or sufficient legitimate interest

Digital records shall be deleted after a year however printed copies form
record card, above

5kPatient Management Records

Legitimate interest – Annual audit and deletion of information

Name, Medical information

Google Drive / PracticeHub

5lClinic Research

Consent Basis – Deleted after use in line with consent terms

Anonymised identification and medical Information 

Google Drive / As required and notified in research

6. Connective Chiropractic also process data in terms of;

a) Staff and subcontractor details;

name, profile pictures and employment/ HR details. In
this instance the legal basis for processing is the performance of a contract between you and us

b) Testimonials, see clauses 16-19

c) Photographs at events;

we reserve the right to use pictures taken at events for promotion and social media as part of a contractual basis on attendance, subject to your rights to opt out

WEBSITE

7. Connective Chiropractic’s website does not directly process any data, however it
does process some data through indirect means, such as by utilising cookies (See Definitions; cookie) and using basic website tracking software

8. Connective Chiropractic’s website has a SSL certificate to add a greater level of security. 

9. We can not vouch for the safety or security of data published on an external link or via social media accounts. We remind all users to act with caution when posting.

10. Connective Chiropractic do not store or process data directly on the website. The
website does not contain logins for staff or members of the public to use.

11. Connective Chiropractic uses cookies to;

a) identify you when you visit our website and as you navigate our website

b) determine if you are logged onto our website

c) secure our website and services generally

d) help us to analyse the use and performance of our website and services; and

e) store your website use preferences.

12. Connective Chiropractic will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website.

13. Website users are able to refuse to accept or block cookies through their browser security settings at any time. Blocking cookies may reduce usability or the number of features available on our website.

14. Connective Chiropractic do not store, save or collect personal information from the website through cookies.

TRACKING SOFTWARE

15. Connective Chiropractic’s website uses tracking software to monitor its visitors to better understand how they use it. This software is provided by Google or Facebook and its associated products such as Google Analytics and Google Search Console. The information gathered relating to our website is used to create reports about the use of our website and to understand usage for further development.

Google’s privacy policy is available at: https://www.google.com/policies/privacy/.

TESTIMONIALS

16. Connective Chiropractic may process testimonials and include the full name, company and/or employment details of the author of a testimonial

17. Connective Chiropractic reserve the right to copy, screen shot and use comments made about Connective Chiropractic in a public arena, such as on social media

18. Testimonials may be shared on Connective Chiropractics website, social media, paper and/or digital marketing. They may also be shared with subcontractors, employees and service users

19. Connective Chiropractic reserve the right to use anonymised testimonials or testimonials without use of identifiable data, where consent is not recorded following provision of a testimonial

EXTERNAL LINKS

20. Although this website includes quality, safe and relevant external links, users are still advised to adopt a policy of caution before clicking any external web links mentioned throughout this website. (External links are clickable text / banner / image links to other websites etc.)

21. Connective Chiropractic cannot guarantee or verify the contents of any externally linked website despite their best efforts. Users should therefore note that they click on external links at their own risk and this website and its owners cannot be held liable for any damages or implications caused by visiting any external links mentioned

22. Shortened URL links might be used on social media or on Connective Chiropractic’s website

SOCIAL MEDIA

23. Communication, engagement and actions taken through external social media platforms that this website and its owners participate on are subject to the terms and conditions as well as the privacy policies held with each social media platform respectively

24. Users are advised to use social media platforms wisely and communicate / engage upon them with due care and caution in regard to their own privacy and personal details. Neither this website nor its owners will ever ask for personal or sensitive information through social media platforms. Users wishing to discuss sensitive details should do so through primary communication channels such as by telephone or email

25. Connective Chiropractic’s website may use social sharing buttons which help share web content directly from web pages to the social media platform in question. Users are advised before using such social sharing buttons that they do so at their own discretion and note that the social media platform may track and save your request to share a web page through your social media platform account

26. Connective Chiropractic reserve the right to publish comments, testimonials and posts made on social media in unedited form. We use automated social media walls, social share functions on our website to reflect up to date social media engagement. Website users are reminded that engagement with these functions are at their own risk

27. Users are advised to take caution and use good judgement before clicking any shortened URLs published on social media platforms by Connective Chiropractic. Despite the best efforts to ensure only genuine URLs are published, many social media platforms are prone to spam and hacking and therefore this website and its owners cannot be held liable for any damages or implications caused by visiting any shortened links.

EMAIL NEWSLETTER

28. Connective Chiropractic operates an email newsletter program, used to inform visitors about products and services. Users can subscribe through an online automated process should they wish to do so at their own discretion. Some subscriptions may be manually processed through prior written agreement with the user.

29. Subscriptions are taken in compliance with UK Spam Laws detailed in the Privacy and Electronic Communications Regulations 2003 as well as GDPR

30.Email marketing campaigns published by Connective Chiropractic may contain tracking facilities within the actual email. This information is used to refine future email campaigns and supply the user with more relevant content based around their activity only.

31. In compliance with UK Spam Laws and the Privacy and Electronic Communications Regulations 2003, subscribers are given the opportunity to un-subscribe at any time through an automated system. This process is detailed at the footer of each email campaign. If an automated un-subscription system is unavailable, clear instructions on how to un-subscribe will be detailed instead.

PROVIDING YOUR DATA TO OTHERS

32. From time to time Connective Chiropractic may contact your GP, insurance provider and/or other healthcare professionals about the status of your care. Connective Chiropractic will gain consent from you that it is satisfactory for us to do this, however we reserve the right to do so should it be considered that there is a legal or vital interest to do so

33. Connective Chiropractic reserve the right to breach confidentiality and share personal data where there is a public safety, legal obligation or vital interest to do so

34. Connective Chiropractic may process any personal data identified in this policy for the establishment, exercise or defence of legal claims (whether administrative or out of court) and for the purposes of obtaining or maintaining insurance coverage, managing risks or obtaining professional advice.

35. Connective Chiropractic might disclose personal data to our subcontractors or employees on your approval. We may also disclose some personal data on your request to other practitioners for referrals.

36. We will share transaction data with any payment services or professional accountants on in so far of processing and refunding payments, dealing with complaints and queries and to satisfy our wider financial and/or insurance
obligations.

YOUR RIGHTS: RETAINING AND DELETING INFORMATION

37. Personal data that we process, for any purpose, shall not be kept for longer than is necessary for that purpose or those purposes

38. Connective Chiropractic respect your rights under GDPR (See definitions, Your rights). Please contact james@connectivechiropractic.co.uk  at any time to instruct us should you feel that your rights are being infringed or for requests for further information

REQUESTING DATA

39. You have the right to confirmation as to whether or not we process your personal data. purposes of the processing, the categories of personal data concerned and the recipients of the personal data

40. You have the right to request copies of data held by Connective Chiropractic, providing the rights and freedoms of others are unaffected

41. Requests for copies of data should be made to james@connectivechiropractic.co.uk. Connective Chiropractic will confirm receipt of your request.

42. The first copy will be provided free of charge. Additional copies may be subject to a reasonable fee. Pursuant to GDPR, Connective Chiropractic reserve the right to charge for requests that are vexatious or require additional administration.

YOUR RIGHTS TO CORRECT, ERASE, OBJECT TO, RESTRICT DATA AND WITHDRAW CONSENT

43. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed

44. In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfullyprocessed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims

45. In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest

46. You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims

47. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose

48. You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest

49. If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

50. You have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal

VARIATIONS

51. Connective Chiropractic reserve the right to change and/or vary our website, services and/or policies at any time. Please check our website to see any latest variation.

OUR DETAILS

52. Connective Chiropractic is owned and operated by Connective Chiropractic Limited (Registered Company Address in England and Wales: 55 Kingsclere Road, Basingstoke RG21 6XG, Company number: 10788728)

53. The Connective Chiropractic name and logos are registered trademarks (UK00003278007, UK00003574179, UK00003762225)

54. Please contact us via james@connectivechiropractic.co.uk or 07833 585501 or by post at the above address should you need to contact us about anything within this policy.

APPENDIX ONE: DEFINITIONS

DEFINITIONS

1. “ Cookie” – A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

2. Legal Basis – the legal bases of the processing under the GDPR are:

(i) Consent: the individual has given clear consent for you to process their personal data for a specific purpose.

(ii) Contract: the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract.

(iii) Legal obligation: the processing is necessary for you to comply with the law (not including contractual obligations).

(iv) Vital interests: the processing is necessary to protect someone’s life.

(v) Public task: the processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law.

(vi) Legitimate interests: the processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.

3: Your Rights

Your principal rights under data protection law are:

(a) the right to access;

(b) the right to rectification;

(c) the right to erasure;

(d) the right to restrict processing;

(e) the right to object to processing;

(f) the right to data portability;

(g) the right to complain to a supervisory authority; and

(h) the right to withdraw consent.