Privacy

What this Privacy Policy covers

The Osteopathic Centre for Children (OCC), as the clinical arm of the Foundation for Paediatric Osteopathy (FPO), is committed to protecting your personal information and being transparent about what information we hold, whether you are a patient, parent/carer of a patient, donor, volunteer, student on one of our courses, or other visitor to the clinic.

Developing a better understanding of our supporters through their personal data allows us to communicate and fundraise more efficiently, which ultimately helps us provide more children and perinatal women with specialist osteopathic treatment. We have made improvements to this policy so that transparency is at the core of what we do.

The purpose of this policy is to give you a clear explanation about how the Foundation for Paediatric Osteopathy, and therefore the Osteopathic Centre for Children as its clinical arm, uses the personal information you provide to us and that we collect, whether online, via phone, email, in letters or in any other correspondence or from third parties.

We ensure that we use your information in accordance with all applicable laws concerning the protection of personal information. This policy explains:

  • What information the Foundation for Paediatric Osteopathy may collect about you;
  • How we will use that information;
  • Whether we disclose your details to anyone else;
  • Your choices regarding the information you provide to us; and
  • How we use cookies to provide services to you or to improve your use of our website

If you have any queries about this privacy policy please contact the Data Protection Officer at the Foundation for Paediatric Osteopathy, 22A Point Pleasant, Wandsworth, London SW18 1GG or email: yourdata@fpo.org.uk

 

Who we are

The Osteopathic Centre for Children (OCC) is the clinical arm of the Foundation for Paediatric Osteopathy (FPO). Our Registered Charity Number in England and Wales is 1003934. We are also registered as a company in England and Wales under registration number 2544759.

 

Information collection

We collect information in the following ways:

  • Information you give us. For example, when you visit our clinic, you’ll be asked to complete a New Patient Form, for either yourself or your child as the patient. On this form, we’ll ask for personal information, like your name, your child’s name (where they are the patient), date-of-birth of the patient, email address, postal address and telephone number. We will also ask you if you would like to receive information about the clinic and how you would like to receive that information. Other visitors will also be asked to complete a form asking for similar personal information. We will also collect personal information if you engage with our social media, make a donation to us, subscribe to our e-newsletter, register for an event, apply for one of our courses or otherwise provide us with personal information.
  • Information we get from your use of our website and services. We collect information about the services you use and how you use them, like when you watch a video on YouTube, visit our websites or view and interact with our social media posts. We only use anonymous information and statistics which do not identify individual visitors to our websites. This information helps us improve the services and information we offer on our websites. We may use service providers to help us collect and analyse this information.
  • Information from third parties. We may also receive information about you from third parties, such as JustGiving.com. This can include information such as your name, postal address, email address, phone number, credit/debit card details and whether you are a tax payer so that we can claim Gift Aid.  We, like all companies, are able to confirm what browser you are using, IP address and computer operating systems that are being used and this information may be used to improve the services we offer
  • ‘Sensitive’ personal information. This refers to any medical information we record in relation to either your or your child’s treatment at the Osteopathic Centre for Children. This information is stored securely and used only for purposes of continuity of treatment. We also record information on your ethnic background. This is purely to give us a better understanding of who is using our services and whether we are reaching specific populations in the community.

We will always make it clear to you when we collect ‘sensitive’ personal information from you, and why we are collecting it.  

 

Website users

Our website uses cookies to help our website work well and to track information about how people are using it.

‘Cookies’ are small pieces of information sent by a web server to a web browser, which enable the server to collect information from the browser. Essentially it takes the form of a small text file deposited on your computer’s hard drive.

The FPO / OCC use cookies to ensure that you can interact with our website successfully, to identify you when you visit our website and to keep track of your browsing patterns. The use of cookies does not give us access to the rest of your computer or to personal information about you.

We also work with Google Analytics to monitor use of our website. Google Analytics uses cookies to gather statistics about our visitors, such as where you come from before entering our website, which pages you look at on our site and where you go afterwards. Information collected in this way is anonymous and does not identify individual visitors. This information allows us to improve our website and the services we provide. For more information about Google Analytics, please see their privacy policy at www.google.com/privacy

If you want to prevent our cookies being stored on your computer in future, you may do so by referring to your internet browser’s instructions. You can do this by clicking on the “Help” menu. Please note however that if you disable our cookies you may not be able to access certain services or facilities on our site and your use of our site may be restricted. Further information on deleting or controlling cookies is available at www.AboutCookies.org

 

Tracking

We use very occasional first and third party technologies such as pixel tags and web beacons to track and improve the user experience on our site, quality of service and to monitor the effectiveness of campaigns and digital marketing activity.

We may use them to:

  • see what website content is popular and how people are using the site as they allow us to track users movement through our website.  This type of information is amalgamated so that we can build up a picture of how the site is performing.
  • make sure we offer you a consistent service. For example, if we are testing new website content or we want to run a survey, we use tracking to remember what content you have seen or if you have already been asked to join the survey.
  • When we email you, we may place a tag (also known as ‘tracking pixel’) on the email we send out. These let us monitor performance of our email marketing activity. 

 

Your debit and credit card information

If you use your credit or debit card to donate to us either online, over the phone or in one of our clinics, we will ensure that this is done securely and in accordance with the Payment Card Industry Data Security Standard. You can find our more information about PCI DSS here – https://www.pcisecuritystandards.org/security_standards/index.php

We do not store your credit or debit card details at all, following the completion of your transaction. We will store a copy of your transaction receipt for 12 months in the event of a dispute. This has limited information and cannot be reused. Only authorised staff will have access to your card receipt.

If we receive an email containing any credit or debit card details, it will be immediately deleted, no payment will be taken and you will be notified about this. All donations should be completed either through the donation page accessed via our website, at the clinic reception, or over the phone.

Our online donation page is hosted by JustGiving.com. You can read their Privacy Policy at: https://www.justgiving.com/info/privacy

 

Legal basis

In certain instances, we collect and use your personal information by relying on the legitimate interest legal basis. This is because when you, for example, request to receive services from the FPO / OCC, we have a legitimate organisational interest to use your personal information to respond to you and there is no overriding prejudice to you by using your personal information for this purpose. An example of this could be sending you an SMS reminder of your appointment.

This is also the case where we process your donations in support of FPO / OCC’s objectives, for our internal administrative purposes, and where we need to take steps to protect our network security or risk of fraud.

Finally, we may need to disclose your information if required to do so by law or in response to a court order or request from a law enforcement agency. In exceptional circumstances, where we think someone is at serious risk of being harmed, we may contact the police or a local authority safeguarding team.

In most instances, however, we will rely on obtaining your consent to our use of your personal information. This is the case, for example, where we seek to obtain your consent to receive email marketing about the FPO / OCC. 

 

Marketing materials:                    

As a small charity, our resources are limited, so we want to ensure we only send you information that is of interest to you. As such, wherever you register your personal information, you will be asked to opt-in to receiving information from us and you will be able to choose the channel that suits you best, ie by email or post. We will never use SMS or telephone marketing and fundraising techniques.

By subscribing to our e-newsletter, you grant us the right to use the email address for email marketing purposes.

 

Your choice:

It is always your choice as to whether you want to receive information about our work, how we raise funds and the ways you can get involved. If you do not want us to use your personal information in these ways please indicate your preferences on the form on which we collect your data.

You may change your contact preferences at any time by emailing yourdata@fpo.org.uk  We will not use your personal information for marketing purposes if you have indicated that you do not wish to be contacted by us for such purposes. However, we will retain your details on a suppression list to help ensure that we do not continue to contact you.

 

Fundraising

Occasionally we will carry out targeted fundraising activity to ensure that we are contacting you with the most appropriate communication, which is relevant and timely and will ultimately provide an improved experience for you.

Rest assured, we do not use profiling techniques or use third party wealth screening companies and insight companies to provide us with general information about you. We will also never share, sell or swap your personal information with any third parties for the purposes of their own marketing activity.

 

Recipients – Information and Disclosure

The FPO / OCC may only disclose your personal information under the following circumstances:

  • To third parties who provide a service to us and are data processors. This could include our trusted partners that work with us in connection with our charitable purposes, and other entities that may provide FPO / OCC information and marketing (subject to your communication preferences and our internal policies and procedures). We require these third parties to comply strictly with our instructions and data protection laws and we will make sure that appropriate controls are in place. We enter into contracts with all of our data processors and regularly monitor their activities to ensure they are complying with FPO / OCC policies and procedures.
  • Where we need to disclose your information if required to do so by law or in response to a court order or request from a law enforcement agency. In exceptional circumstances, where we think someone is at serious risk of being harmed, we may contact the police or a local authority safeguarding team.

 

Medical information  

All medical information is considered ‘sensitive’ personal information. It is necessary to record relevant medical details, together with diagnoses, treatment and responses to treatment. This information is kept for purposes of ongoing treatment.

Occasionally, retrospective research studies may be made using this data, however it will always be used anonymously with no personal information attached.

Medical information is kept securely in locked filing cabinets at the OCC, and is archived two years after your last visit. Archived records are held securely by a third party who complies strictly with our instructions and data protection laws. The Osteopathic Practice Standard D6 (3) requires us to keep this information for a minimum of eight years after the date of the last treatment for any adult, and until a child turns 25 years.

 

Under 18s

We are committed to protecting the privacy of all young people under the age of 18 years. Any communication relating to our young patients will be directed to their parents or guardians.

Where families are happy to share their stories and/or photos with the wider public, we gain written consent from the parent or guardian. The parent or guardian can withdraw this consent at any time by emailing yourdata@fpo.org.uk. At age 16, the child can directly request the withdrawal of consent via the same email address.

 

Vulnerable Supporters

We are compassionate towards our supporters and will never exploit vulnerability. We will do everything we can in order to assist our supporters to make an informed decision about the support they choose. Indicators of vulnerability could include bereavement, illiteracy, illness, disability or other impairment. We will always use our best judgment when we have grounds to believe that a donor is vulnerable before making a final decision.

We do not use third party fundraising organisations and our fundraising team is small, so each individual case of suspected vulnerability would be discussed at the highest level.

 

Inappropriate website content

If you post or send any content that we believe to be inappropriate, offensive or in breach of any laws, such as defamatory content on our social media pages, we may use your personal information to inform relevant third parties such as your internet provider or law enforcement agencies.

 

International transfers of personal information

For financial and technical reasons, there may be a rare occasion where we decide to use the services of a supplier outside the European Economic Area (EEA), which means that your personal information is transferred, processed and stored outside the EEA. This includes countries that the European Union authorities do not consider provides an adequate level of protection for personal data. However, in this rare circumstance, we would take steps to put in place suitable safeguards to protect your personal information when processed by the supplier such as entering into the European Commission approved standard contractual clauses.

 

Keeping your personal information

We keep your personal information only for as long as required to operate the service in accordance with legal requirements and tax and accounting rules. Where your information is no longer required, we will ensure it is disposed of in a secure manner. 

As required by the Osteopathic Practice Standard D6 (3), all medical records are kept for a minimum of eight years after the last treatment for adults, and for children, until they have turned 25 years.

 

Editing or deleting your personal information

The accuracy of your personal information is important to us. You can edit your personal information or contact preferences with us at any time by emailing yourdata@fpo.org.uk

or writing to the Data Protection Officer, Foundation for Paediatric Osteopathy, 22A Point Pleasant, Wandsworth, London SW18 1GG. You can also have your personal information deleted by contacting us through the same channels.

 

Your rights to access your personal information and how it’s been used 

In accordance with the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679), you have the right to request a copy of the personal information we hold about you, how this information has been used, and to have any inaccuracies corrected. You also have the right to request us to erase your personal information, request us to restrict our processing of your personal information or to object to our processing of your personal information.

Should you wish to exercise these rights we require you to prove your identity with two pieces of approved identification. Please address requests to the Data Protection Officer, Foundation for Paediatric Osteopathy, 22A Point Pleasant, Wandsworth, London, SW18 1GG. We will respond within 28 days of receipt of your written request and confirmed ID. Please provide as much information as possible about the nature of your contact with us to help us locate your records. There will be no fee for this process.

Where you have provided your consent for our use of your personal information, you always have a right to withdraw your consent at any time, by emailing yourdata@fpo.org.uk

 

Complaints and other feedback

If you are unhappy with our work or something that we have done or failed to do, we want to know about it. We also welcome your views on what we do well. Your comments enable us as an organisation to learn and continuously improve our services. Please send any feedback to yourdata@fpo.org.uk or write to the Data Protection Officer, Foundation for Paediatric Osteopathy, 22A Point Pleasant, Wandsworth, London, SW18 1GG.

 

Changes to this Privacy Policy

We may update the terms of this policy at any time, so please do check it from time to time. We will notify you about significant changes in the way we treat personal information by sending a notice to the primary email address you have provided to us or by placing a prominent notice on our websites. By continuing to use our website you will be deemed to have accepted such changes.