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Privacy Statement 

Issue Date: 25th May 2018



Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:


“any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.


How we use your information?

This privacy notice tells you how we, Harley Street Spine, will collect and use your personal data for the purpose of patient treatment.


Why does Harley Street Spine need to collect and store personal data?

In order for us to provide you with consultant and treatment, we need to collect personal data for identification and correspondence purposes. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.


In terms of being contacted for marketing purposes Harley Street Spine would contact you for additional consent.[A1] 


Will Harley Street Spine share my personal data with anyone else?

We may pass your personal data on to third-party service providers to Harley Street Spine in the course of treatment plan. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fullfill the service they provide.  When they no longer need your data to fulfil this service, they will dispose of the details in line with Harley Street Spine’s Data Protection Policy. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.


How will Harley Street Spine use the personal data it collects about me?

Harley Street Spine will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. Harley Street Spine is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.

Under what circumstances will Harley Street Spine contact me?

Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.


Can I find out the personal data that the organisation holds about me?

Harley Street Spine at your request, can confirm what information we hold about you and how it is processed. If Harley Street Spine does hold personal data about you, you can request the following information:

  • Identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU

  • Contact details of the data protection officer.

  • The purpose of the processing as well as the legal basis for processing

  • If the processing is based on the legitimate interests of Harley Street Spine or a third party, information about those interests

  • The categories of personal data collected, stored and processed

  • Recipient(s) or categories of recipients that the data is/will be disclosed to

  • If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information

  • How long the data will be stored

  • Details of your rights to correct, erase, restrict or object to such processing

  • Information about your right to withdraw consent at any time

  • How to lodge a complaint with the supervisory authority

  • Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.

  • The source of personal data if it wasn’t collected directly from you

  • Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing


What forms of ID will I need to provide in order to access this?

Harley Street Spine accepts the following forms of ID when information on your personal data is requested: Passport, driing licence, birth certificate, utility bill (from the last three months). 


All data subjects whose personal data is collected, in line with the requirements of the GDPR.



The Data Protection Officer is responsible for ensuring that this notice is made available to data subjects prior to Harley Street Spine collecting/processing their personal data.  All Staff of Harley Street Spine who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and their consent to the processing of their data is secured.


The Controllers

Harley Street Spine is an orthopaedic service specialising in spine health.

Our Data Protection Officer and Data Protection Consultant Representatives can be contacted directly via email at &


The personal data we would like to collect and process on you is:[A2] 

Personal data type:


Full Name

Data Subject, GP, Health Advisor or Consultant Referral, Insurance Company,


Data Subject, GP, Health Advisor or Consultant Referral, Insurance Company,

Date of Birth

Data Subject, GP, Health Advisor or Consultant Referral, Insurance Company,

Telephone Contact Numbers

Data Subject, GP, Health Advisor or Consultant Referral, Insurance Company,

Insurance Policy Name and  Reference number

Data Subject, GP, Health Advisor or Consultant Referral, Insurance Company,

Hospital Reference Numbers

Data Subject, GP, Health Advisor or Consultant Referral, Insurance Company,

Health Records (Special Category of Data)

Data Subject, GP, Health Advisor or Consultant Referral, Insurance Company,


The personal data we collect will be used for the purposes of providing medical advice and treatment. 


Our legal basis for processing for the personal data is consent. 


The special categories of personal data that we collect relate to health data.


  1. Consent

By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified.  Consent is required for Harley Street Spine to process both types of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.


You may withdraw consent at any time by contacting your consultant directly or emailing the Data Protection Officer. 



Harley Street Spine may pass on your personal data to third parties during and pertaining to your treatment plan.  Consultants will discuss this at the time of consultations.  Examples of third parties are typists, PAs, hospitals, physiotherapists, GPs and tertiary referrals to other consultant.   This will be done through as securely as possible, eg encrypted emails.   


Retention period

Harley Street Spine will process personal data for the duration of the treatment and will store the personal data for eight years before archiving the data securely. 


Your rights as a data subject

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

  • Right of access – you have the right to request a copy of the information that we hold about you.

  • Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.

  • Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.

  • Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.

  • Right of portability – you have the right to have the data we hold about you transferred to another organisation.

  • Right to object – you have the right to object to certain types of processing such as direct marketing.

  • Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.

  • Right to judicial review: in the event that Harley Street Spine refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below.

All of the above [A3] requests will be forwarded on should there be a third party involved in the processing of your personal data.



In the event that you wish to make a complaint about how your personal data is being processed by Harley Street Spine, or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Harley Street Spine’s data protection representatives Data Protection Officer / GDPR Owner.


The details for each of these contacts are:


Supervisory Authority:                                             Harley Street Spine

Information Committioner’s Office                        1.  Data Protection Officer (DPO)


Tel:  0303 123 1113                                                   2.  Data Protection Consultant Representative







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