Information Management Policy.
Purpose
This policy outlines how {Chapter One Dental} manages patient and staff information to ensure confidentiality, integrity, and lawful processing in accordance with legal and ethical obligations.
Scope
This policy applies to all practice staff, including employees, contractors, temporary staff, and trainees who have access to personal or sensitive information.
Legal and Regulatory Framework
This policy complies with:
UK General Data Protection Regulation (UK GDPR)
Data Protection Act 2018
Human Rights Act 1998
Common Law Duty of Confidentiality
Caldicott Principles
General Dental Council (GDC) Standards
Freedom of Information (Scotland) Act 2002 (if applicable)
Data Protection
We are committed to processing all personal data in accordance with the UK GDPR’s seven principles:
Lawfulness, fairness, and transparency
Purpose limitation
Data minimisation
Accuracy
Storage limitation
Integrity and confidentiality (security)
Accountability
Data Subject Rights are respected and include:
The right to access their personal data
The right to rectification
The right to erasure (where applicable)
The right to restrict processing
The right to data portability
The right to object
Rights in relation to automated decision-making
Privacy Notices for Patients, including Children are available in the waiting room and on the practice website.
A privacy notice for staff is available <in staff area>.
The table below outlines key responsibilities within our practice.
Caldicott Guardian
A Caldicott Guardian is appointed to oversee the protection and appropriate sharing of patient-identifiable information.
The Caldicott Guardian for {Chapter One Dental} is: < Ashley Chisholm >
The Guardian ensures adherence to the eight Caldicott Principles, which govern how personal data should be handled in health and social care settings.
Confidentiality
All staff have a duty to maintain the confidentiality of personal and sensitive information obtained through their work.
Confidentiality applies to information about patients, staff, and the business operations of the practice.
Information is only shared on a need-to-know basis and in accordance with legal or regulatory requirements.
All staff contracts and agreements have a clause regarding confidentiality of personal data, or a separate confidentiality agreement is signed.
Information Security
Electronic records are stored securely with access controls, passwords, and encrypted backups.
Paper records are held in locked cabinets in secure areas.
Access to data is limited to authorised personnel only.
Data is disposed of securely when no longer needed (e.g., shredding paper records, wiping electronic data).
The business contingency plan includes details on procedures for protecting and restoring personal data in the event of an incident.
Staff Responsibilities
All staff must complete regular training on data protection, confidentiality, and information governance.
Breaches of confidentiality or data protection policies may result in disciplinary action, and potentially criminal proceedings.
Data Breach Management
All suspected or confirmed breaches of data must be reported immediately to the Ashley Chisholm or data protection officer.
Serious breaches will be reported to the Information Commissioner’s Office (ICO) within 72 hours, as required.
Data Sharing and Third Parties
Data is only shared with third parties (e.g., NHS bodies, referral services) when legally permitted and with appropriate safeguards in place.
Contracts with processors (e.g., IT providers) include clauses ensuring GDPR compliance.
Patients are informed about any information that is to be shared and why.
Information is only shared with consent from the patient.
There may be some circumstances where information can be shared without consent such as where information is required by the police to prevent or detect crime, when requested by a coroner, or in response to a court order. The Ashley Chisholm and/or the DPO is responsible for making decisions on sharing data in these situations.
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