At Pickwick Physiotherapy we are committed to protecting and respecting your privacy. This Policy explains when and why we collect personal information, how we use it, the conditions under which we may disclose it to others and what choices you have. It relates to all our business activities, not just this website.   We may change this Policy from time to time so please check this page occasionally to ensure that you’re happy with any changes. By using our services, you’re agreeing to be bound by this Policy. Any questions regarding this Policy and our privacy practices should be sent by email to enquiries@pickwickphysio.co.uk, or call 01249 588008. Date: 10/05/2018 Review Date: 10/05/2019 Author: Jane Clarke, Practice Principal 1. Who are we? We are Pickwick Physiotherapy, a Physiotherapy practice treating patients with musculoskeletal problems such as sports injuries, postural problems, neck and back complaints and post-operative rehabilitation. In keeping with our total body approach, we also treat a range of other conditions perhaps not traditionally associated with physiotherapy, such as shortness of breath and difficulties clearing phlegm. We also provide Pilates 1:1 and acupuncture. Pickwick Physiotherapy is managed by Jane Clarke. Full contact details can be found on the ‘Contact’ page of our website. 2. How do we collect information from you? We obtain information about you when:

• you visit our website
• you contact us via our website to enquire about any of our services
• you book and attend appointments for any our services
• you leave a comment or review on our facebook or twitter feed.
• we receive communication from multidisciplinary professionals involved in your care
•  we receive communication from other healthcare intermediaries involved in your care
• we receive communication from your health insurance company if applicable

3. What information do we collect & how is it used? The table in section 3.3 below outlines exactly what information we collect, and for what purpose. 3.0. Sensitive Data We do gather sensitive personal data relating to health matters pertinent to the provision of our services. Such data is provided with explicit consent of the client, by themselves or their representatives. We do not gather other sensitive data (e.g. genetic, biometric data; racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, sexual orientation, and criminal convictions). 3.1. Children’s information Our services may be directed to children under 13. Any relevant information is only collected with the explicit consent of the individual holding parental responsibility for that child. If you learn that a child under 13 has provided us with personal information without consent, please contact us. 3.2 Data sharing At times it may be appropriate for the Pickwick Physiotherapy team to share your information with your consent with other medical professionals such as make a referral to an orthopaedic surgeon, provide an outcome report to your GP or request an NHS Occupational Therapy or Physio review. In this case any written information will be created as a PDF document stored with the rest of your data and the letter posted first class. If urgent the file will be sent to the recipient in a password protected file. The recipient will then be telephoned with the password to unlock the file. 3.2. Third Parties We will not sell or rent your information to third parties. We will not share your information with third parties for marketing purposes. We may pass your information to third party service providers who we have engaged for the purpose of completing tasks and providing services to you on our behalf. We disclose only the personal information that is necessary to deliver the service. We also use a number of 3rd party services to help us fulfil our contractual obligations. These 3rd party services are listed in full below; we have verified that these 3rd party services are GDPR compliant. 3.3. Details The following table outlines the personal data we collect and for what purpose. The table also outlines the third parties the data is processed by or shared with, and how long the data is stored for:

Name	What	Legal ground	Purpose	Third parties	Data retention
Clinical & Invoicing	​Patient details, treatment and invoicing records	Legal obligation	To provide a record of clinical care	​Write Upp practice management software Unique password for each team member. stored on the WriteUpp’s secure servers within the European Union (EU). Hosted on secure data centre managed by WriteUpp’s hosting partner with 24/7 manned security, CCTV, biometric access to the facility and restrictive access to the internals of the building based on authorisation levels.	​Clinical treatment and accounts records held for 8 years in accordance with existing policies and current legislation. Records relating to children and young people must be kept until the patients 25th birthday, or 8 years after the last entry if longer
Telephone answering service	Patient name and telephone number, reason for call and insurance details if applicable	Legal obligation	To provide a record of patient contact including making, changing, cancelling appointment.	Clinic Answer Data is protected by Endpoint Security by Symatec. All messages to Pickwick team are via Microsoft 365 (GDPR compliant). Acronis software to back up data and hold securely in a European Data Centre.	Archived annually.
Enquiry emails	Patient name , telephone number, email and brief summary of request		​To provide patients with easy access point for enquiries.	Website contact form and via enquiries@pickwickphysio.co.ukdirectly.	Deleted annually.
Card payment	Patient email for receipt if requested		To provide a record of payment to the patient	​SUM UP Unique password for each team member. Data sheet shows time of transaction and time no patient details or bank details	Archived annually
Analytics	Website visitor behaviour (anonymised – full IP address is NOT stored)	Legitimate interests	To analyse website visits so we can improve our users experience.	Google Analytics	Data retention period set to 14 months NB: not personal data ​

4. Controlling your informationYou have certain rights concerning the information we hold about you, as defined under the General Data Protection Regulation. If you wish to exercise these rights, please contact us, including your email address and telephone number in the first instance.   4.0. Requesting a copy of your informationYou may request a copy of any data we hold about you. Upon request, we will provide a PDF or CSV file containing the personal data we hold on record about you.   4.1. Updating or correcting your informationThe accuracy of your information is important to us. If you change email address, or any of the other information we hold is inaccurate or out of date, please contact us so we may correct our records.   4.2    Deleting your informationYou have the right to request erasure of your personal information. Unless there is a compelling reason for the data not to be erased (for example, if we need to use that data to fulfil our contractual or legal obligations), your personal data will be deleted on request. 4.3    Automated decision makingWe do not use any personal information for automated decision making or profiling; your data is not subject to automated decision making or profiling.   5. Use of ‘cookies’Like many other websites, our website uses cookies. Cookies are small pieces of information that are stored on your computer or mobile device when you visit a website. The following list outlines what we use cookies for: Google Analytics: Google Analytics sets cookies to help us accurately estimate the number of visitors to the website and what content is most popular. This helps to ensure that our website is responding to your needs in the best way possible. ​WordPress: This website is built using WordPress.  WordPressuses cookies to give visitors a more personalized user experience.  Cookies can identify users, remember preferences, and help users complete tasks without having to re-enter information when visiting multiple pages or returning to your site 6. Security Pickwick Physiotherapy takes security seriously. In order to protect your information from loss, misuse or unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect. These steps include the following:

• Data minimisation
• Password best practice
• Security best practice concerning devices (PCs, laptops, mobile devices), online accounts, website hosting, physical access and storage
• Staff training and accountability on data protection

A copy of our internal Data Security Policy is available on request.   7. Data Breaches Our Data Security Policy includes a clear process for handling a personal data breach, should one occur. Where appropriate, Pickwick Physiotherapy will promptly notify you of any unauthorised access to your personal information.   8. Complaints ​If you wish to raise a complaint on how we have handled your personal information, you can contact us directly and we will investigate the matter. If you are not satisfied with our response or believe we are not processing your personal information in accordance with the law you can complain to the Information Commissioner’s Office (ICO).