We care about your privacy. For this reason, we collect and use personal data only as it is needed for us to deliver to you the highest standard of services, products and applications [collectively known as our services].
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
means an account required to access and/or use certain areas and features of [Our] Site;
means a small text file placed on your computer or device by [Our] Site when you visit certain parts of [Our] Site and/or when you use certain features of [Our] Site. Details of the Cookies used by [Our] Site are set out in Part 14, below; and
means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;]
2. Information About [Us]
[Our] Site is [owned and] operated by Midleton Physiotherapy, a sole trader [registered in Ireland under company number 174335].
[Registered address: 3 Ballyannon Court, Coolbawn, Midleton.]
[Main trading address:23, St. Mary’s Road, Midleton, Cork.]
[Email address: midletonphysio[at]gmail.com.]
[Telephone number: +353214631119]
[Postal Address: 23, St. Mary’s Road, Midleton, Cork..]
[[We are registered and regulated by the state regulatory body ‘ CORU’]
[We are a member of Irish Society of Chartered Physiotherapist]
3. What Does This Policy Cover?
4. What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’. Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
5. What Are Your Rights?
Under the GDPR, you have the following rights, which [we] will always work to uphold:
b) The right to access the personal data [we] hold about you. Part 13 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by [us] is inaccurate or incomplete. Please contact [us] using the details in Part 15 to find out more.
d) The right to be forgotten, i.e. the right to ask [us] to delete or otherwise dispose of any of your personal data that [we] have. Please contact [us] using the details in Part 15 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to [us] using your personal data for a particular purpose or purposes.
g) The right to data portability. This means that, if you have provided personal data to [us] directly, [we] am using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask [us] for a copy of that personal data to re-use with another service or business in many cases.
h) Rights relating to automated decision-making and profiling. [[We] do not use your personal data in this way.]
For more information about [our] use of your personal data or exercising your rights as outlined above, please contact [us] using the details provided in Part 15.
If you have any cause for complaint about [our] use of your personal data, you have the right to lodge a complaint with the Data Protection Commissioner’s Office.
6. What Data Do We Collect?
▪ [Email address]
▪ [Telephone number]
▪ [Information about your preferences and interests]
▪ [Usage data]
▪ [IP address]
▪ [Web browser type and version]
▪ [Operating system]
▪ [A list of URLs starting with a referring site, your activity on [Our] OR [My] Site, and the site you exit to;]
7. How Do We Use Your Personal Data?
Under the GDPR, [we] must always have a lawful basis for using personal data. This may be because the data is necessary for [our] performance of a contract with you, because you have consented to [our] use of your personal data, or because it is in [our] legitimate business interests to use it. Your personal data [may] be used for [one of] the following purposes:
⁃ [Providing and managing your access to [Our] Site;]
⁃ [Personalising and tailoring your experience on [Our] Site;]
⁃ [Supplying [our] [products] AND/OR [services] to you. Your personal details are required in order for [us] to enter into a contract with you.]
⁃ [Personalising and tailoring [our] [products] AND/OR [services] for you.]
⁃ [Communicating with you. This may include responding to emails or calls from you.]
⁃ [Supplying you with information by [email] and/or [post] that you have opted-in to (you may unsubscribe or opt-out at any time by <emailing us with the subject line ‘OPT-OUT’ to midletonphysio[at]gmail.com]
⁃ [Analysing your use of [Our] Site [and gathering feedback] to enable [us] to continually improve [Our] Site and your user experience.]
You will not be sent any unlawful marketing or spam. [We] will always work to fully protect your rights and comply with [our] obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.]
8. How Long Will You Keep My Personal Data?
[We] will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods:
– We are legally obliged to keep information about our patients for 7 years [ after they cease being patients.]
– in the case of children – we are legally obliged to keep information for 7 years after they turn 18 years of age
9. How and Where Do You Store or Transfer My Personal Data?
We follow accepted standards to store and protect the data we collect, including utilization of encryption where appropriate. While we all know the internet is not 100% free from security risks, we take this subject very seriously and take the necessary security steps to prevent any unauthorized individuals accessing any collected data.
10. Do You Share My Personal Data?
We will not share any of your personal data with any third parties for any purposes, subject to these important exceptions.
1. In some limited circumstances, [we] may be legally required to share certain personal data, which might include yours, if [we are] involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.]
2. In circumstances where external referrals are required for optimum patient care – [ie] the process of referring patients to other relevant external healthcare professionals [with patient consent] – for example, Consultants or GP.
11. How Can I Control My Personal Data?
In addition to your rights under the GDPR, set out in Part 5, when you submit personal data via [Our] Site, you may be given options to restrict [our] use of your personal data. In particular, [we] aim to give you strong controls on [our] use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from [us] which you may do by using the subject matter ‘OPT-OUT’ in an email to us. [midletonphysi[at]gmail.com]
12. Can I Withhold Information?
13. How Can I Access My Personal Data?
If you want to know what personal data [we] have about you, you can ask [us] for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover [our] OR [my] administrative costs in responding. [We]will respond to your subject access request within 30 days of receiving it. Normally, [we] aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date [we] receive your request. You will be kept fully informed of [our] progress.
15. How Do I Contact You?
To contact [us] about anything to do with your personal data and data protection, including to make a subject access request, please use the following details [(for the attention of <Data Protection Admin>]:
Postal Address: Midleton Physiotherapy, 23, St. Mary’s Road, Midleton, Cork.