Privacy Policy

Cap City Dental aims to meet the requirements of the Data Protection Act 2018, the General Data Protection Regulation (GDPR), the guidelines on the Information Commissioner’s website, and our professional guidelines and requirements.

The data controller is CAP City Dental, and Raya Rafalovitch is the information Governance Lead.

This Privacy Notice is also available at our reception at 14 Austin Friars, London, EC2N 2HE and by email if you contact dental@capcitydental.co.uk by calling 020 7621 0600.

You will be asked to provide personal information when joining the practice. The purpose of us processing this data is to provide optimum health care to you.

The categories of data we process are:

• Personal data for the purposes of staff and self-employed team member management
• Personal data for the purposes of (/email/text/other) marketing
• Special category,data including health records for the purposes of the delivery of healthcare
• Special category data including health records and details of criminal record checks for managing employees and contracted team members

We never pass your personal details to a third party unless we have a contract for them to process data on our behalf and will otherwise keep it confidential. If we intend to refer a patient to another practitioner or to secondary care such as a hospital we will gain the individual’s permission before the referral is made and the personal data is shared.

• Personal data is stored in the UK whether in digital or hard copy format
• Personal data is stored in the US in digital format when the data storage company is certified with the EU-US Data Privacy Framework
• Personal data is obtained when a patient joins the practice and when a patient is referred to the practice.

The lawful basis for processing special category data such as patients and employees’ health data is:

• Processing is necessary for the purposes of preventative or occupational medicine, for assessing the working capacity of the employee, for medical diagnosis, the provision of health or social care or for treatment or management of health or social care systems and services.

The lawful basis of processing personal data such as name, address, email or phone number is:

• Consent of the data subject
• Processing is necessary for the performance of a contract with the data subject or to take steps to enter into a contract

The retention period for special data in patient records is a minimum of 10 years and maybe longer for complex records in order to meet our legal requirements. The retention period for staff records is 6 years. The retention periods for other personal data is 2 years after it was last processed. Details of other retention periods are available in the Record Retention procedure available from the practice.

You have the following personal data rights:

• The right to be informed
• The right of access
• The right to rectification
• The right to erasure (clinical records may be retained for a certain time period)
• The right to restrict processing
• The right to data portability
• The right to object

Further details of these rights can be seen in our Information Governance Procedures or on the Information Commissioner’s website. Here are some practical examples of your rights:

• If you are a patient of the practice you have the right to withdraw consent for important notifications, newsletters, surveys or marketing. You can inform us to correct errors in your personal details or withdraw consent from communication methods such as telephone, email or text. You have the right to obtain a free copy of your patient records within one month.
• If you are not a patient of the practice you have the right to withdraw consent for recall reminders, important notifications, newsletters, surveys or marketing. You can also withdraw consent from communication methods such as telephone, email or text. We may retain clinical records relating to former patients in order to manage our legal rights and comply with our legal obligations as a healthcare service provider. Such records shall be kept at all times in accordance with our professional obligations of confidentiality.

We have carried out a Privacy Impact Assessment and you can request a copy from the details below. The details of how we ensure the security of personal data is stated in our Data Protection Policy.

Comments, suggestions and complaints

Please get in touch with Raya Rafalovitch at the practice for a comment, suggestion or complaint about your data processing at dental@capcitydental.co.uk or 020 7621 0600 or by writing to or visiting the practice at 14 Austin Friars, London, EC2N 2HE.  We take complaints very seriously.

If you are unhappy with our response or need any advice, you should contact the Information Commissioner’s Office (ICO). Their telephone number is 0303 123 1113; you can also chat online with an advisor. The ICO can investigate your claim and act against anyone who misuses personal data. You can also visit their website for information on how to make a data protection complaint.

Related practice procedures

You can also use these contact details to request copies of the following practice policies or procedures:

• Data Protection and Information Security Policy
• Privacy Impact Assessment