Privacy and Complaints Policy

Privacy Policy for The Harley Street Smile Clinic for Patient Data

The Harley Street Smile Clinic takes great care to protect the personal data we hold for our patients in line with the requirements of the General Data Protection Regulation (GDPR) and the Data Protection Act 2018.

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

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

Personal data held for our patients

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

  • Name, address, date of birth.
  • Unique identification number.
  • Next of kin.
  • Email address.
  • Phone numbers.
  • GP contact details.
  • Occupation.
  • Medical history.
  • Dental care 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 patients and this is available for patients on request. A list of personal information held is also included in our Privacy Notice that is given to all patients.

Privacy notice for call recording

This privacy notice explains how we use recordings of phone calls in relation to telephone calls made on https://harleystreetsmileclinic.co.uk/.

Personal data When a call is recorded, we collect:

  • the telephone number of both parties (internal and external)
  • the source of the telephone call – traffic acquisition channel, landing page etc.

Call tracking will be used:

  • to assist marketing performance
  • to enable for appointment booking and follow-up

Sharing data under Data Protection legislation

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 patients’ 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 patients’ personal information with may include:

  • Regulatory authorities such as the General Dental Council or the Care Quality Commission 
  • NHS Local Authorities
  • Dental payment plan administrators
  • Insurance companies
  • Loss assessors
  • Fraud prevention agencies
  • In the event of a possible sale of the practice at some time in the future.

We may also share personal information where we consider it to be in a patient’s 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 and the Data Protection Act 2018, 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 decision-making.
  • Right to data portability.

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

Legal basis for processing data held about patients

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

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

The legal basis on which we process personal information for our private patients is for ensuring clinical notes relate to the correct person. To be able to correspond accordingly to the correct person. To be able to provide information to the correct person.

The legal basis on which we process personal information for our payment plan patients is to ensure payment plans are linked to the correct person and any information provided to us or to the patient is to the correct person (s).

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.

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

Consent

The Harley Street Smile Clinic always obtains specific, unambiguous opt in consent (verbally and written) from all patients to whom we send direct marketing information.

We also obtain specific, unambiguous, opt in consent from our patients for using digital clinical photos for marketing or training, sending links to carry out reviews.  For a new patient,we obtain consent for these things when the patient first attends the practice.  For an existing patient, we ask the patient for consent when they attend for their recall appointment or for a treatment appointment.  We refresh this consent annually when the patient completes a new medical history proforma.

Withdrawal of consent

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

Retention period

This practice retains dental records and orthodontic study models while the patient is a patient of the practice and, after they cease to be a patient, for at least eleven years, or for children until age 25, whichever is the longer.

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 Paula Cole.  All complaints will be dealt with in line with the practice complaints policy and procedures.

Transferring personal data outside the EU

This practice sends any necessary laboratory work to Italy.

Laboratory work sent outside the EU will be labelled with the patient’s unique identifying number rather than the patient’s name. A record of the unique identifying number will be held at the practice.

This Policy was reviewed and implemented on: 17.2.20 and 14.6.2020 and 5.2.21

This policy and relevant procedures will be reviewed annually and are due for review on 5.2.22 or prior to this date in accordance with new guidance or legislative changes.

Document Change Record for Privacy Policy for Patient Data

Published
Date
Document
Version
Number
Pages
affected
Description of revisionAuthor
Privacy policy patient data England v2.0
©Apolline Ltd

Complaints Policy and Procedures and Code of Practice for patients who wish to raise concerns

Complaints Policy

At The Harley Street Smile Clinic we want to ensure that all our patients are pleased with their experience of our service. We take complaints very seriously indeed. If a patient makes a complaint, we will deal with the matter courteously and promptly so that it is resolved as quickly as possible. Our complaints policy and procedures are based on these objectives.

We display the General Dental Council’s 6 core principles for ensuring that we get the most from patient feedback and complaints for the benefit of all in reception on top of filing cabinets.

At The Harley Street Smile Clinic we have an effective complaints system in place to ensure that identifying, receiving, recording, handling and responding to any comments, observations, concerns or complaints occurs within a strict timetable that is clearly documented. Our Code of Practice for patients who wish to raise concerns is displayed in the patient handbook and all patients and visitors should feel confident that they will be listened to and responded to without fear of discrimination or recrimination. Our Complaints Policy and Procedures are displayed in reception.

We aim to ensure that any complainant is treated sensitively and in a manner that respects their human rights and diversity.

We recognise that a complaint is any expression of dissatisfaction with our service, treatment or advice and that a complaint can be made by a variety of methods, including verbally, by sign language or in writing.

In situations where a patient may lack confidence to express their views, or require help to do so, they will be supported by helpful team members. All patients’ complaints are fully documented and investigated and are dealt with fairly.

At The Harley Street Smile Clinic we view complaints as an opportunity to improve our service delivery and to learn lessons that will help us make changes with the intention of avoiding a repetition of any similar complaint.

To help us learn lessons from complaints, we track and analyse all our complaints to identify trends that will help us improve our service.

Here at The Harley Street Smile Clinic, we take patient feedback very seriously and welcome any comments our patients have about the services they receive. The General Dental Council (GDC) has outlined 6 core principles for managing patient feedback and complaints.

  1. All your feedback is important to us
  2. We want to make it easy for you to raise a concern or complaint if you need to
  3. We follow a complaints procedure and will keep you informed
  4. We will try to answer all your questions and any concerns you raise
  5. We want you to have a positive experience of making a complaint
  6. Your feedback helps us to improve our service

Our complaints procedures are monitored and reviewed regularly and the named contact who is accountable for doing this is Paula Cole.

This Policy was implemented on 01/11/2019 and 5/2/2021

This policy and relevant procedures will be reviewed annually and are due for review on 5/2/2022 or prior to this date in accordance with new guidance or legislative changes or as a result of learnings following a complaint.

Complaints Procedures

Verbal complaints

If a patient complains on the telephone, at the reception desk or anywhere else in the practice, we will listen sympathetically to their complaint and make notes about his/her issues or problems, provided that the patient consents to us doing this.

Having first listened to the patient’s complaint, we will offer to refer him/her to Paula Cole immediately. If Paula Cole is not available at the time, the patient will be advised of when they will be able to speak to her and arrangements will be made for this to happen. If the patient has consented to their concerns or issues being written down, the team member will take brief details of the complaint and pass them on. If we cannot arrange this within a reasonable time period or if the patient does not wish to wait to discuss the matter, arrangements will be made for a senior Dentex Ltd representative to deal with it.

Our aim in handling verbal complaints is always to try to resolve the issue to the patient’s satisfaction so that it does not escalate and become a written complaint.

Written complaints

  • If the patient complains in writing the letter will be passed on immediately to Paula Cole.
  • Complaints about clinical care or associated charges will be referred to the clinician concerned, unless the patient does not want this to happen.
  • If a claim has begun, or if a complaint to one of the regulatory bodies has been made or intimated, advice and assistance should be sought from the relevant registrant’s indemnity provider.
  • A written response to a complaint with an accompanying copy of our Code of Practice and a copy of our Complaints Policy and Procedures will be sent as soon as possible, normally within two working days.
  • We will investigate the complaint to enable us to give an explanation of the circumstances that led to the complaint within ten working days of receipt. If the patient does not wish to meet us, then we will attempt to talk to them on the telephone. If we are unable to investigate the complaint within ten working days, we will notify the patient, giving reasons for the delay and a likely period within which the investigation will be completed.
  • We will confirm the decision about the complaint in writing immediately after completing our investigation
  • We make and keep proper and comprehensive records of any complaint received

If patients are not satisfied with the result of our procedure, then a complaint may be made to:

The Dental Complaints Service for complaints about private treatment
Address: Stephenson House, 2 Cherry Orchard, Croydon, CR0 6BA
Phone0208 253 0800
Email[email protected]

The Care Quality Commission
Address: Citygate, Gallowgate, Newcastle upon Tyne NE14PA
Phone03000 616161
Email[email protected]

General Dental Council
We have changed our opening hours to 9am to 5pm Monday to Friday, so we can better deal with your enquiries during the period of the COVID-19 crisis. You can get in touch using the online contact form or by calling our Customer Services team on 020 7167 6000.

The Harley Street Smile Clinic Code of Practice for patients who wish to raise concerns

In The Harley Street Smile Clinic we place great emphasis on meeting and whenever possible, exceeding our patients’ expectations. We try to ensure that all patients are pleased with their experience of our service and we take any concerns a patient may have very seriously.

If you have a concern regarding any aspect of your care, please let us know. We will do all that we can to resolve your concern to your satisfaction promptly and professionally.

Our aim is to respond to your concerns in a caring and sensitive way.

The person responsible for dealing with any concerns about the service we provide in this practice is Paula Cole.

If you raise an issue you are concerned or unhappy about on the telephone or at the reception desk, after listening to a description of the problem the person with whom you raise your concern will try to resolve the issue to your satisfaction immediately.

If the person with whom you raise your concern is unable to resolve the issue for any reason, we will contact Paula Cole immediately. Should Paula Cole be unavailable at the time, we will advise you when they will be available, and arrangements will be made for you to meet or speak with her.

If for any reason Paula Cole is going to be unable to meet you or speak with you at a time that is convenient to you, we will arrange for a senior Dentex Ltd representative to take responsibility for dealing with your concern or complaint.

The team member with whom you first raised your concern will take brief details from you and pass these to Paula Cole so that they can familiarise themselves with your concern prior to meeting you or speaking with you.

If you choose to write to us to express your concern rather than raising it verbally, your letter or email will be passed on to the relevant person immediately.

We will acknowledge any concerns you raise in writing within two days and we will also include a copy of this Code of Practice with our response. We will investigate your concern and report back within ten working days of it being received. If we are unable to complete our investigations within ten working days for any reason, we will notify you, giving reasons for the delay and the likely period within which the investigation will be completed.

We will confirm the outcome of the investigation and any decisions made in writing.

We will keep proper and comprehensive records of any concerns or complaints received.

We will do all we can to resolve your issue, concern or complaint to your satisfaction. If, for any reason, you are not satisfied with the outcome or the procedure, we will advise you of other avenues open to you for raising concerns. These are:

The Dental Complaints Service for complaints about private treatment
Address: Stephenson House, 2 Cherry Orchard, Croydon, CR0 6BA
Phone0208 253 0800
Email[email protected]

The Care Quality Commission
Address: Citygate, Gallowgate, Newcastle upon Tyne NE14PA
Phone03000 616161
Email[email protected]

General Dental Council
We have changed our opening hours to 9am to 5pm Monday to Friday, so we can better deal with your enquiries during the period of the COVID-19 crisis. You can get in touch using the online contact form or by calling our Customer Services team on 020 7167 6000.

Document Change Record For Complaints Policy

The table below is used to register all changes to the policy:

Published
Date
Document
Version
Number
Pages
affected
Description of revisionAuthor
18/01/196.11To include reference to General Dental Council’s 6 core principlesPL

Complaints policy v6.1
©Apolline Ltd

General Dental Council
37 Wimpole Street
London W1G 8DQ
+44 (0) 20 7167 6000

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