Kallistos House takes great care to protect the personal data we hold for our clients in line with the requirements of the General Data Protection Regulation (GDPR).

The purpose of collecting and storing personal data about our clients is to ensure we can:

Provide appropriate, safe and effective care, treatment and advice for all our clients
Fulfil any contracts or consent we hold in relation to their care. For business administration of their care.

Personal Data held for our Clients

The personal data we process (processing includes obtaining the information, using it, storing it, securing it, disclosing it, and destroying it) for our clients includes:

Name, Address, Date of Birth
Next of Kin
Email Address
Phone Numbers
GP Contact Details
Occupation
Medical History
Aesthetics, Laser or Earwax Removal Records
Photographs
Family Group
Payment Plan Details
Financial Information
Credit Cards Receipts
Correspondence
Details of any Complaints Received

We keep an inventory of personal data we hold on our clients and this is available for clients on request. A list of personal information held is also included in our Privacy Notice that is given to all clients.

Disclosure to Third Parties

The information we collect, and store will not be disclosed to anyone who does not need to see it.

We will share our clients personal information with third parties when required by law or to enable us to deliver a service to them or where we have another legitimate reason for doing so. Third parties we may share clients personal information with may include:

Regulatory Authorities such as the Nursing and Midwifery Council or the Care Quality Commission
NHS Local Authorities
Insurance Companies
Thympa Ear Health
Loss Assessors
Fraud Prevention Agencies
Safeguarding Agencies
In the event of a possible sale of the business at some time in the future.

We may also share personal information where we consider it to be in a clients best interest or if we have reason to believe an individual may be at risk of harm or abuse.

Personal Privacy Rights

Under the GDPR all individuals who have personal information held about them have the following personal privacy rights:

Right to Subject Access.
Right to have Inaccuracies Deleted.
Right to have Information Erased.
Right to Object to Direct Marketing.
Right to Restrict the Processing of their Information, Including Automated Decisionmaking.
Right to Data Portability.

Clients who wish to have inaccuracies deleted or to have information erased must speak to the practitioner who provided or provides their care.

Legal Basis for Processing Data Held about Clients

The GDPR requires us to state the legal basis upon which we process all personal data for our clients and it requires us to inform our Clients of the legal basis on which we process their personal data. This is clearly stated in our privacy notice that is given to all clients.

The legal bases for recording individual types of data are recorded in our client personal data inventory. This is available for all clients to see on request.

The legal basis on which we process personal information for our clients is as a legitimate interest to ensure your continuing care and to make you aware of our services.

Automated Decision Making

All individuals who have personal data held about them have a right to object to their personal data being subjected to automated decision making.

Clients will always be asked to give specific, informed, and verifiable, opt in consent for any processes involving automated decision making.

Consent

Kallistos House always obtains specific, unambiguous opt in consent from all clients to whom we send direct marketing information. We collect Contact Consent via our practice management software and this is stored electronically within the clients’ records.

We also obtain specific, unambiguous, opt in consent from our clients for appointment reminders and appointment recalls. For new clients, we obtain consent for these things when the client first attends the clinic. For an existing client, we ask the client for consent when they attend for their recall appointment or for a treatment appointment. We refresh this consent annually when the client updated their medical history information.

Withdrawal of Consent

Clients who have given their opt in consent have a right to withdraw their consent at any time. Clients are advised of their right to withdraw their consent for anything they wish to withdraw from in our privacy notice.

Retention Period

Kallistos House retains records and study models while the individual is client of the clinic and after they cease to be a client, for at least 11 years.

Complaints

All individuals who have personal data held about them have a right to complain. All complaints concerning personal data should be made in person or in writing to the business manager, details can be found in the clinic Complaints Policy. All complaints will be dealt with in line with the Complaints Policy and procedures.

Transferring Personal Data Outside the EU

Kallistos House presently has no reason to transfer personal data to any third party outside the UK however we do have several clients from outside the Uk and they may request their information in accordance with GDPR rules for travel.

Policy Date: September 2022

Review Date: September 2025

Initials: AHT