Privacy policy

About us

In this privacy notice, ‘we’, ‘us’ and ‘our’ mean Portman. Portman have a range of trading companies based in the United Kingdom.

Our principal address is The Port, Rosehill, New Barn Lane, Cheltenham, GL52 3LZ , our contact details can be located here.

Our Data Protection Officer can be contacted by e-mail at [email protected].

Scope of privacy notice

This privacy notice applies to anyone who interacts with us about our products and services in any way (for example, by e-mail, through our website, by phone).

What information do we collect?

We may collect the following kinds of information about you:

• Personal details such as your name, date of birth, gender, national insurance number, NHS number, address, telephone number, email address, occupation
• Information about your dental and general health, including clinical records made by dentists and other dental professionals involved with your care and treatment
• X-rays, clinical photographs, digital scans of your mouth and teeth, and study models
• Medical and dental histories
• Treatment plans and consent
• Notes of conversations with you about your care, for example details of any queries, complaints and any related communications.
• Correspondence from other health professionals or institutions involved in your care
• Details of the fees we have charged, payments exemptions (NHS), the amounts you have paid and some payment details
• Feedback and complaints
• CCTV images
• Online profile and social media information and activity, based on your interaction with us
• Our websites, including for example Internet Protocol (IP) address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
• Statistical data about your browsing actions and patterns – including the full URL clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs), and methods used to browse away from the page.
• Any other personal information you provide to us

How we obtain information

You may give us information about you through the following:

• By filling in forms at our practices, through social media, or on our websites.
• Corresponding with us by phone, e-mail, chat or otherwise.
• Through the technology you use to access our services
• By entering competitions, through social media, our website or face-to-face.
• Sources that are available to the public, such as social media

Information we receive from third parties - This includes information you provide when you visit our websites, for the purpose of booking an appointment with a dentist at Portman dental clinics, participate in discussion boards or other social media functions on our site and when you report a problem with our site.

We use data processors who are third parties who provide elements of services for us. We have Data Processor Agreements in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us or further sub-processors who must comply with our Data Processor Agreement. They will hold your personal data securely and retain it for the period we instruct.

Where we store Your Personal Information and International Data Transfers

The personal data that we hold about you will be stored in the UK and the European Economic Area (EEA). In limited circumstances may also be transferred to or stored at a destination outside the UK or EEA.

If we transfer your data to third party service providers based outside the EEA, we ensure a similar degree of protection is provided to the transfer by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.

• Where we use certain service providers, we may use specific contracts (known as Standard Contractual Clauses) approved by the European Commission which give personal data the same protection it has in Europe, as well as any additional security measures as required.

We will make sure we meet any future requirements the UK or the EU provide following the UK’s exit of the EU, including (but not limited to) the legal safeguards discussed above.

Cookies

Our website, like many others, uses third party cookies, helping us improve the performance of our website and digital marketing, to provide you with a better user experience.

For example:

• Facebook analytics, pixel, advertising, & social features. We use Facebook technologies to customize content and advertising, to provide social media features (such as the Chat widget) and to analyse traffic to our website
• Mediahawk
• Google

These cookies monitor activity throughout our website using third-party providers. We track which sources are effective at helping visitors find our website and make calls to us, navigation journeys throughout, and pages visited. We may use IP addresses, geo-location data and caller telephone numbers.

What are ‘cookies’?

‘Cookies’ are small text files that are stored by the website browser (for example, Internet Explorer or Safari) on your computer or mobile device. They are widely used in order to make websites work, or work in a better, more efficient way. They can do this because websites use them to recognise you and remember important information that will make your use of a website more convenient.

For further information visit aboutcookies.org or allaboutcookies.org.

You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser.

How we use your information – the purpose

We may use this information to:

• To perform our relationship with you, including to handle any queries or complaints
• To manage our social media or online relationship with you, in some cases we may rely on your consent for example should you provide us with a video, photograph or content to use.
• To provide you with the dental care and treatment that you need, we require up-to-date and accurate information about you.
• We may contact you to conduct patient surveys or to find out if you are happy with the treatment you received for quality control purposes.
• We will seek your preference for how we contact you about your dental care. Our usual methods are SMS, telephone, email or letter.
• If we wish to use your information for dental research or dental education, we will discuss this with you and seek your consent. Depending on the purpose and if possible, we will anonymise your information. If this is not possible we will inform you and discuss your options.
• We may use your contact details to inform you of products and services available at our practices.

We have CCTV at some of our practices for the purposes of security and patient and staff safety.

By visiting our websites, and accessing or using communications such as social media chat, or our chat widget, the. User expressly consents to the collection, use, storage, processing and disclosure of its information in accordance with our Privacy Policy.

Our website, events, promotions, social media, content, blogs and materials we provide are intended for use by individuals 13 years or older, and we do not knowingly collect personal information relating to anyone under the age of 13 years.

However, we may in some cases collect limited personal information related to children if they are connected to someone is under 13 years, for example a child of a responsible adult who is sharing information. If we become aware that we have collected personal information from a child under the relevant age without parental consent, we take steps to delete that information.

Social media

We love social media and chatting with you there, whether it be on Facebook, Instagram or Twitter or through the live chat feature on our website.

Don’t forget, however, that everybody can see everything you do there (our sites are public) so if you want us to keep your information private, please don’t put anything on these sites which you or your loved ones would like to keep private, whether now or in the future.

We will always try to respond to you using another medium such as e-mail or phone, where appropriate.

If you use certain social media features from within our website or connect with us on our social media pages, the privacy policies of those companies will apply. Please read them carefully before you share your information with us and others as these companies may have different standards of protection of information than we do.

Sharing your information

Your information is normally used only by those working at the practice but there may be instances where we need to share it – for example, with:

• Your doctor
• The hospital or community dental services or other health professionals caring for you
• Dental laboratories
• NHS payment authorities
• The Department for Work and Pensions and its agencies, where you are claiming exemption or remission from NHS charges
• Private dental schemes of which you are a member
• Debt collection companies

We also share your information with third parties in order to deliver the following services to you:

• Managing new enquiries from our website, chat or social media
• Contacting you to check if you wish to remain a client of ours
• Sending reminders for your dental appointments
• Processing on-line booking appointments
• Collecting feedback from our patients
• Managing email communications to our patients
• Providing troubleshooting and support services for our various IT systems

We will only disclose your information on a need-to-know basis and will limit any information that we share to the minimum necessary. We also have third party agreements in place to protect your information.

In certain circumstances or if required by law, we may need to disclose your information to a third party not connected with your health care, including HMRC or other law enforcement or government agencies.

How we will keep your information safe

We employ administrative, electronic and physical security measures to ensure that the information that we collect about you is protected from access by unauthorised persons and protected against unlawful processing, accidental loss, destruction and damage.

This includes:

• Password protection
• Locked cabinets/rooms
• Practice security systems (including CCTV)
• Virus protection
• Secure servers
• Back-up facilities
• Secure cloud-based storage

In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality to us.

How long will we keep your information?

We keep your dental records for 10 years after the date of your last visit.

There are a number of other documents that we may collect that have a variety of retention dates, for example the NHS PR form – used to declare payment exemptions – which needs to be kept for 2 years.

We will only keep information, such as records through chat functions, for as long as necessary to fulfil the purposes we collected it.

We have a retention schedule listing all documents and the timeframes for disposal. Retention periods may be changed from time to time based on business or legal and regulatory requirements.

Your rights

Access

You have a right to access the information that we hold about you and to receive a copy. You can make a request by contacting your practice or by e-mailing [email protected].

Rectification

You have a right to correct any information that you believe is inaccurate or incomplete. Please contact your practice to request a change in information.

Erasure

You have a right to request that we delete your personal information, although you should be aware that, for legal reasons, we may be unable to erase certain information (for example, information about your dental treatment). Please contact your practice to make this request.

Restriction

You have the right to request us to restrict the processing of your personal information for example, sending you reminders for appointments or information about our service. Please contact your practice to make this request.

Portability

You have a right to data portability, this could include supplying your information to another dentist. Please contact your practice to make this request.

Your Data Matters: How can you learn more about protecting your information?

If you want detailed information on your rights, protecting your information, and what the Information Commissioner’s Office (ICO) does and how it can help you protect your information, please visit https://ico.org.uk/yourdatamatters. The ICO is the UK’s independent body which upholds information rights.

Concerns

If you have any concerns about how we use your information and you do not feel able to discuss it with your dentist or anyone at the practice, you can contact our Data Protection Officer via email at [email protected]