The practice aims to meet the requirements of the Data Protec on Act 2018, the General Data Protection Regulation (GDPR], the guidelines on the Informa on Commissioner’s website as well as our professional guidelines and requirements.

The data controller is Brazilian Smile Ltd, Geize Santos is the information Governance Lead.
This Privacy Notice is available [on the practice website at / at reception/ by email if you contact / by calling 07752979208/ other.

You will be asked to provide personal informa on 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 [direct mail/email/text/other] marketing
  • ▪  Special category data including health records for the purposes of the delivery of health care
  • ▪  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 [EU] 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 Privacy Shield]

▪  Personal data is obtained when a patient joins the practice, when a patient is referred to the practice and [when a patient subscribes to an email list]

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, medical diagnosis, the provision of health or social care or treatment or management of health or social care systems and services on the basis of Union or Member State law or a contract with a health professional

▪  [Other]

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

▪  [Other]

The retention period for special data in patient records is a minimum of 10 years and may be 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 (M 215) procedure available from the practice.

You have the following personal data rights:

Last modi ed: 16 Mar 2018 Brazilian Smile Ltd, 2nd Floor, W1G9PR M 217T – Privacy No ce, Ver 1, Folder 1, Page 1 of 2

  • ▪  The right to be informed
  • ▪  The right of access
  • ▪  The right to rec ca on
  • ▪  The right to erasure (clinical records must be retained for a certain me 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 Informa on Governance Procedures (M 217C) or at the

    Informa on Commissioner’s website. Here are some prac cal examples of your rights:

  • ▪  If you are a pa ent of the prac ce you have the right to withdraw consent for important no ca ons, newsle ers, surveys or marke ng. You can inform us to correct errors in your personal details or withdraw consent from communica on methods such as telephone, email or text. You have the right to obtain a free copy of your pa ent records within one month.
  • ▪  If you are not a pa ent of the prac ce you have the right to withdraw consent for processing personal data, to have a free copy of it within one month, to correct errors in it or to ask us to delete it. You can also withdraw consent from communica on methods such as telephone, email or text.

    We have carried out a Privacy Impact Assessment (M 217S) and you can request a copy from the details below. The details of how we ensure security of personal data is in our Security Risk Assessment (M 217M) and Informa on Governance Procedures (M 217C).

    Comments, sugges ons and complaints

    Please contact Geize Santos at the prac ce for a comment, sugges on or a complaint about your data processing at, or 07752979208 or by wri ng to or visi ng the prac ce at 2nd Floor, 42 Harley Street, London, W1G9PR. We take complaints very seriously.

    If you are unhappy with our response or if you need any advice you should contact the Informa on Commissioner’s O ce (ICO). Their telephone number is 0303 123 1113, you can also chat online with an advisor. The ICO can inves gate your claim and take ac on against anyone who’s misused personal data. You can also visit their website for informa on on how to make a data protec on complaint.

    Related prac ce procedures

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

  • ▪  Data Protec on and Informa on Security Policy (M 233-DPT), Consent Policy (M 233-CNS)
  • ▪  Privacy Impact Assessment (M 217S), Informa on Governance Procedures (M 217C)