Noeleen Malone Integrative Health respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit my clinic and website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below.
- Important information and who I am
- The data I collect about you
- How I use your personal data
- Sharing of your personal data
- How long do I keep your data?
- Your legal rights
1. Important information and who I am
Purpose of this privacy notice
The processing of personal data is governed by the General Data Protection Regulation 2016/679 (the GDPR). This legislation will replace current data privacy law, giving more rights to you as an individual and more obligations to organisations holding your personal data.
One of the rights is a right to be informed, which means we have to give you even more information than we do now about the way in which we use, share and store your personal information.
This means that we will be publishing a new privacy notice so you can access this information, along with information about the increased rights you have in relation to the information we hold on you and the legal basis on which we are using it.
This new privacy notice comes into effect and will be published on our website on 22 June 2022
Who am I?
Noeleen Malone Integrative Health is the data controller. This means I decide how your personal data is processed and for what purposes.
Whose information does this privacy notice apply to?
This privacy notice applies to information we collect from:
- prospective patients;
- former patients;
- people who subscribe to my newsletters;
- visitors to my website;
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact me at firstname.lastname@example.org
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 22/06/2022.
It is important that the personal data I hold about you is accurate and current. Please keep me informed if your personal data changes during your relationship with me by emailing me at email@example.com and/or informing me at your next appointment.
2. The data I collect about you
What is personal data?
Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. Examples of personal data we may hold about you include your contact and appointment details.
Sensitive personal data I may hold about you is relating to your health, and is collected for the purposes of clinical assessment, treatment or advice, and is necessary to be obtained, in order to provide the most accurate service for you.
3. How do I process your personal data?
I comply with our obligations under the GDPR by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data. I use your personal data for the purposes set out below.
For my patients, prospective patients, former patients and visitors to my clinic
1. I use your name, address, telephone number and email address to make, confirm and rearrange appointments
2. I use your name, address, telephone number and email address, only if I have your explicit consent, to send you marketing materials.
3. Some patients and prospective patients return pre- 1st appointment questionnaires or tell me about their medical conditions and medication by email or online enquiry forms.
4. I keep a permanent attendance register which records all appointments for patients attending my clinic, to keep a record of when you were treated for tax purposes and to secure potential evidence in the event of a criminal prosecution, civil litigation, insurance claim or complaint to my regulatory body, the Acupuncture Foundation Professional Association, Irish Register of Chinese Medical Herbalists and Yoga Alliance.
5. I may use your date of birth to help identify patients with the same name to avoid mistakes being made as to safe and appropriate treatment, for identification purposes if referring a patient to another health practitioner, and for identification purposes if writing to a registered medical practitioner so that they correctly identify the patient.
6. I use your presenting complaint and symptoms reported by you for the purposes of making a full traditional diagnosis, formulating treatment strategy and treatment planning.
7. I use any relevant medical and family history you have told us for making a full traditional diagnosis, formulating treatment strategy and treatment planning.
8. I use my clinical findings about your health and wellbeing for making a full traditional diagnosis and formulating treatment strategy and treatment planning.
9. I keep a record of and refer to that record of any treatment given and details of progress of your case, including reviews of treatment planning to enable me to: review the full traditional diagnosis, treatment strategy and planning. I record and use any information and advice that I have given, especially when referring patients to any other health professional, to help you to receive the most appropriate treatment.
10. I record any decisions made in conjunction with you to help you to receive the most appropriate treatment
11. I keep accident records for any patients, visitors or staff who are involved in accidents at my clinic in accordance with Irish Health and Safety Authority including the Safety, Health and Welfare at Work (Reporting of Accidents and Dangerous Occurrences) Regulations 2016 (S.I. No. 370 of 2016) to comply with the law.
12. Where relevant I maintain records of the patient’s consent to treatment, or the consent of their next-of-kin to be able to prove that the patient (and/or parent/guardian/next of kin) has given informed consent to treatment.
All your records are stored:
- All of your personal and health data is stored securely in locked files and in electronic format on my patient management system with Power Diary. All electronic communications are hosted within platforms which are SSL-secure, password protected and encrypted.
- On my office computer in case of correspondence, referral letters, invoices, etc. These are password-protected, backed up regularly and the office is locked out of working hours.
- Any attendance sheets and consent form from classes and retreat returned by paper are stored in a locked filing cabinet.
Subscribers to my newsletters
13. I maintain and use records of subscribers to our newsletters, only with their consent, for marketing purposes.
14. I use a third-party provider, Mailchimp, to store your name and email address and to deliver my e-newsletters. I gather statistics around email opening and clicks using industry standard technologies including clear gifs to help me monitor and improve my e-newsletter. For information, please see Mailchimp’s privacy notice.
15. When someone visits my website we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.
16. We use website cookies to improve user experience of our website by enabling our website to ‘remember’ users, either for the duration of their visit – using a ‘session cookie’ – or for repeat visits – using a ‘persistent cookie’.
18. My website may contain links to other websites of interest. However, once you have used these links to leave my site, you should note that I do not have any control over that other website. Therefore, I cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
4. Sharing your personal data
Your personal data will be treated as strictly confidential, and I will never share your personal information with any other third party without your explicit consent unless required to do so by law.
Only the following people/agencies will have routine access to your data:
- Me, so that I can provide you with treatment
- Power Diary, process all data on my electronic patient management system
- Other administrative staff, such as my bookkeeper. Again, administrative staff will not have access to your medical notes, just your essential contact details.
- I also use Mailchimp to coordinate my messages, so your name and email address may be saved by their server.
From time to time, I may have to employ consultants to perform tasks which might give them access to your personal data
For further details about the situations when information about you might be shared please see the Data Protection Commissioners website at www.gdprandyou.ie
5. How long do I keep your personal data?
I keep your personal data for no longer than reasonably necessary.
I keep patient records for a minimum of 8 years in accordance with legal requirements for healthcare professionals.
At any time you may request that changes are made to your contact details.
6. Your rights and your personal data
Unless subject to an exemption under the GDPR, you have certain rights with respect to your personal data as set out below.
- The right to request a copy of your personal data which I hold about you.
- The right to request that I correct any personal data if it is found to be inaccurate or out of date.
- The right to request your personal data is erased where it is no longer necessary for me to retain such data.
- The right to withdraw your consent to the processing at any time. This right does not apply where I am processing information using a lawful purpose other than consent.
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing.
- The right to object to the processing of personal data, (where applicable) [This right only applies where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics].
- The right to be informed if your data is lost. We shall also inform the Data Protection Commissioner in accordance with the time limits in the GDPR.
- The right to lodge a complaint with the Information Commissioner’s Office.
For further details about these rights please see the Data Protection website at http://dataprotection.ie
If I wish to use your personal data for a new purpose, not covered by this Privacy Notice, then I will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, I will seek your prior consent to the new processing.
Questions and Contact information
If you would like to: access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information contact me at firstname.lastname@example.org
You have the right to make a complaint at any time to the Data Protection Commissioner, the Irish supervisory authority for data protection issues (www.dataprotection.ie). I would, however, appreciate the chance to deal with your concerns before you approach the DPC so please contact me in the first instance.