Policies

Check out our policies before attending your chiropractic consultation

Cotswold Chiropractic wants to make sure you're completely confident in the skills and services of our team. Please take a look at our policies below and don't hesitate to contact our Cheltenham clinic if you have any questions.

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Covid-19 transmission risk-reduction policy

GENERAL POLICY

 Coronavirus is thought to be primarily spread between people who are in close contact with one another (within about 2 metres), through respiratory droplets produced when an infected person coughs or sneezes. The virus is also thought to be passed on through surface transmission, when touching a surface or object that has some respiratory droplets on it and then touching your own face, mouth, nose, eyes, or someone else. Our risk assessment for transmission of coronavirus within Cotswold Chiropractic therefore addressed both close contact between individuals and touch of surfaces that may occur. Our policy for risk reduction is to implement measures to remove, minimise or mitigate each of the identified areas of risk.


POLICY FOR PATIENTS AND OTHER VISITORS

  • No ‘walk-ins’ – all appointments and enquiries must be made by telephone or email.
  • Assessment of need for an appointment – potential patients will be screened to evaluate the level of risk to them of attending (do they belong to the vulnerable or extremely vulnerable groups), the level of necessity for care and their understanding of these factors. Patients and staff will make shared decisions, as to whether face-to-face appointments are appropriate, or whether remote consultations, no care, or referral for other care are indicated.
  • Informed consent – patients will be required to give informed consent for the decided course of action upon attending a face-to-face, or remote consultation.
  • Screening - patients will be screened upon booking and again prior to entry to the clinic for symptoms of Covid-19 or other reason requiring self-isolation. Possible or confirmed cases must not be admitted.
  • Face masks – Patients will wear a face mask to reduce the risk of transmission to staff or to other patients or visitors within the clinic.
  • ‘Clean upon arrival’ - Immediately upon entry, patients are requested to wash their hands.
  • ‘No-touch’ policy – No patient will need to touch a surface that has not been cleaned immediately prior to them doing so. Staff will wipe objects that it is necessary to touch (e.g. and hand weights/exercise equipment etc). Patients are given a surface wipe on arrival that they should retain and use to wipe any other surface within the clinic before they touch it.
  • Social distancing – the clinic layout is organised to enable a minimum of 2 metres to be maintained from staff or other patients within the reception area. The number of people within the clinic at any time is also limited to facilitate this. Social distancing will be maintained within the clinical care areas, as far as possible, however some clinical procedures are not possible without closer physical contact (staff and clinicians will wear appropriate PPE to reduce the risk of respiratory droplet transmission to patients where close physical contact in unavoidable).
  • Contact during clinical procedures - on treatment plinths patients will be requested to keep their own clothes on, wherever possible. Patients will keep their footwear on until they are seated on treatment plinths and replace this prior to getting off the plinth. Treatment plinths, equipment used and other hard surfaces in treatment rooms will subsequently be cleaned with chlorine-based product after every patient.
  • ‘Clean upon departure’ – Patients will be requested to wash their hands prior to exiting the clinic, thereafter no surfaces will be touched.


CLINICIANS AND OTHER STAFF

  • No entry if symptomatic or self-isolating – staff must not enter the clinic with symptoms of Covid-19 or other reason requiring self-isolation.
  • ‘Clean upon arrival’ - Immediately upon entry, all staff wash their hands.
  • Face masks – all staff will wear a surgical (type II) face mask to reduce the risk of droplet transmission to other staff, patients or visitors within the clinic. This may be sessional. Donning, doffing and disposal of masks and other PPE (see below) must follow correct procedures.
  • Sessional cleans – Hard surfaces must be cleaned, according to protocol, throughout the reception and common areas and within any consulting room to be used, prior to first use in any session (morning, afternoon or evening). Consulting room cleaning is the responsibility of the clinician who will be using it. Reception and common area cleaning will be the responsibility of reception staff, when they are present, but at other times will be the responsibility of the clinician. Sessional cleaning will be recorded and monitored.
  • ‘No-touch’ policy – Clinicians and other staff will not touch any surface or object that has not been wiped since potentially having been touched by another person. Surface wipes provided should be used by each individual, as required. Clinicians and other staff will also explain and remind patients of this.
  • Cleaning between patients – all hard surfaces within consulting rooms will be cleaned by each clinician after every patient.
  • Ventilation – all windows within the clinic will be open whenever possible to enable replacement of potentially virus-contaminated air.
  • Social distancing – Staff will maintain a minimum 2 metres distance between themselves and other staff, patients or visitors in the reception and common areas. The number of people within the clinic at any time is also limited to facilitate this. Social distancing will be maintained within the consulting rooms, as far as possible, however some clinical procedures are not possible without closer physical contact (in which case clinicians will wear appropriate PPE to reduce the risk of respiratory droplet transmission to patients – see below).
  • PPE – in addition to sessional use of surgical face masks by all clinicians and staff, clinicians who may come within 2 metres of patients will also wear single-use disposable gloves and aprons, in accordance with Public Health England’s guidance for healthcare settings. PPE will be correctly donned, doffed and disposed of. Eye protection (unless performing aerosol-generating procedures) will not be required as face-to-face screening of patients for Covid-19 is not permitted or required. Single use filtering facepiece respirators are required for aerosol generating procedures.
  • Screening of patients – All staff will ensure that patients or other visitors are screened for symptoms of Covid-19 or other reason requiring self-isolation using the intercom, before permitting them entry to the clinic. Possible or confirmed cases must not be admitted.
  • Emergency decontamination – should any individual who does have possible symptoms of Covid-19 gain entry to the clinic, they must immediately be asked to leave, other staff or patients within the clinic must be notified and evacuated or contained until decontamination procedures have been completed.
  • Risk/benefit evaluation and consent – clinicians will evaluate the appropriateness of face-to-face consultations and of procedures requiring close physical contact on a case-by-case basis. Telephone or video consultations may be deemed sufficient/appropriate in some instances as an alternative. In deciding what level of consultation to provide, clinicians will evaluate the vulnerability status of the patient and their level of need for care. The options for care and their associated risks will be explained to the patient, ensuring that they have adequate understanding and are given the opportunity to ask questions, prior to obtaining signed consent for each visit (see example Covid-19 consent form).
  • Contact during face-to-face consultations – close contact of clinicians (less than 2 metres distancing) with patients will be avoided, if possible. Where procedures unavoidably necessitate close contact, this will be minimised in duration, ensuring that the patient has first confirmed their consent.
  • ‘Clean upon departure’ – staff will be washing their hands prior to exiting the clinic.

Cotswold Chiropractic Privacy Policy

Last amended 2nd May 2018


We are committed to protecting and respecting your privacy. This Privacy Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

1 Personal Information

1.1 We take your privacy seriously and this privacy policy (Privacy Policy) sets out how we will handle your personal data securely and in accordance with your rights.

1.2 Cotswold Chiropractic Limited (we, us, our) is a registered data controller under the terms of the Data Protection Act 1998. Details of our notification to the data protection regulator may be found in the Information Commissioner’s Office Public Register of Data Controllers at ico.org.uk. Our registered office address is at Stoke Road, Bishops Cleeve, Cheltenham, Gloucestershire, GL52 8RP.

1.3 Our Data Protection Officer is: Nicola Matthews.

2 General Information

2.1 This Privacy Policy explains what information we collect about you when you:


How we handle your information in respect of our agreement with you to provide information or advice that you request, to manage patient registrations and bookings that you request, to provide chiropractic clinical care that you request and related clinical management functions (together, our Services) to ensure that we protect your rights.

2.2 Please read this Privacy Policy carefully to understand how we will treat your personal data. In this Privacy Policy, references to you or you shall mean you as a user of our Services.

2.3 By using the Website and/or our Services you will be regarded as having accepted the terms of this Privacy Policy. Please do not use the Websites or our Services if you do not agree to the terms of this Privacy Policy.

3 What information do we collect?

3.1 All website users

When you use our website, information collected may include:

  • Information that you provide by filling in forms on our Site.
  • This includes information provided at the time of registering to use our Site, subscribing to our service, posting material or requesting further services. We may also ask you for information when you enter a competition or promotion sponsored by us, and when you report a problem with our Site.
  • If you contact us, we may keep a record of that correspondence.
  • Details of transactions you carry out through our Site and of the fulfilment of your orders.
  • Details of your visits to our Site including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.

IP addresses

We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.

Cookies

Our Site uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our Site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy.

3.2 Prospective patients or general enquiries about services

When you use the website and / or our Services we may ask you to provide certain information such as, your name, date of birth and contact details (including your address, email address, and contact telephone number), along with information that you give us about the nature of your enquiry. Unfortunately, the transmission of information via the internet is not completely secure. Although we employ security measures designed to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

3.3 All Patients

When you first register as a patient with us, either online or by providing information to our reception staff or clinicians, your name, date of birth, contact details and details of any appointments made will be entered into the patient database and diary provided by our secure, hosted practice management system*. Information relating to further appointments will be collected on an ongoing basis within the system.

*Some non-chiropractor clinicians who practise on-site may not utilise our patient registration and bookings service. In this instance, your registration and booking-related data will not be collected and processed by Cotswold Chiropractic and the relevant clinician will be the Data Controller for any registration or booking information that they may collect from you themselves. Our receptionists will advise you of this, should you contact us to enquire, register or make a booking

3.3.1 Chiropractic patients

When you consult one of our chiropractors, clinical information will be collected, including that relating to your symptom(s), our assessment of the condition(s) for which you are seeking care, general health and medical history, any treatment given, clinical advice or information given or discussed. Accounts, billing and payment information will also be collected

3.3.2 Patients receiving non-chiropractic treatments

Cotswold Chiropractic does not collect, process or store any clinical information or accounts, billing or payment information for consultations with practitioners who work on-site, other than its chiropractors. Any non-chiropractor clinician that you see on-site may collect further personal, clinical or accounts, billing and payment data about you. They are the ‘Data Controller’ for any such information and as such are responsible for meeting requirements for the protection of that data.

3.3.3 Sensitive personal information**

Chiropractic patients: In order to provide you with chiropractic clinical services, information collected may include data relating to your physical or mental health, which the Data Protection Act 1998 (DPA 1998) and the General Data Protection Regulation (GDPR) regards as sensitive or special categories of personal data. We do not collect information for other sensitive or special categories of personal data. By providing data relating to your physical or mental health to us for the purposes of providing our Services, you will signify your explicit consent to such Sensitive Data being processed by us.

** Such as information relating to your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or sexual orientation (Background Information) and/or information relating to any criminal convictions you have or offences you may have committed (Criminal Records Information), Background Information and Criminal Records Information, together, being Sensitive Data

4 What do we use your information for?

4.1 You have the right to be told the legal basis and purposes for the processing of your personal data. We are relying on your explicit consent to the processing of your personal data (including any Sensitive Data, as defined above). This means that if you exercise your right to withdraw your consent (please see paragraph 8 below) we will no longer be able to process your data. Please note we may retain a copy of your data in accordance with our Data Protection Policy, if necessary to fulfil legal obligations (including those for financial reporting or health records retention***)

*** HMRC requirements (see https://www.gov.uk/running-a-limited-company/company-and-accounting-records) or The Data Protection Act (see https://ico.org.uk/for-the-public/health/)

4.2 We may use your information for the following purposes:

Fulfilment of a contract (or agreement) with you:

  • Communicating with you about your patient registration or bookings, as necessary to enable these.
  • Communicating with you about your chiropractic clinical care, as necessary.
  • Providing chiropractic clinical care, at your request.
  • Monitoring your progress and/or the outcome of your chiropractic clinical care.
  • Communicating with 3rd parties about your chiropractic clinical care or account/billing information, at your request or with your explicit consent (including medical referrals, private medical insurance companies, sickness, disability or injury reports).

Legitimate interests:

  • To ensure that content from our Site is presented in the most effective manner for you and for your computer.
  • To provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes.
  • To allow you to participate in interactive features of our service, when you choose to do so.
  • To notify you about changes to our service.
  • Monitoring our overall performance with respect to chiropractic patient clinical outcomes and satisfaction (you will not be capable of being identified from such statistical and demographic information. data is pooled and anonymised for this purpose).
  • Participation in data collection for research studies relating to chiropractic (you will not be capable of being identified from such statistical and demographic information. data is pooled and anonymised for this purpose).
  • Fulfilment of our health, safety and fire procedure obligations.
  • Processing and retaining of payment and accountancy records that fulfil the obligations of financial reporting for companies.
  • Processing and retaining chiropractic clinical records enabling fulfilment of obligations for the retention of medical records and requirements of the General Chiropractic Council (the statutory regulator of chiropractors).
  • Communicating important clinic or service-related information to you that enables you to use our Services.
  • For such purposes as are reasonably necessary to comply with any other legal obligations to which we are subject in the performance of our Services.

4.3 We do not process your personal data for the purpose of marketing or promotional activities, unless you specifically request that we do so or join any social media forum that we control.

4.4 We shall periodically check that the personal data we store for you is accurate. If you would like to update the personal data we hold about you, please contact us with your request using the contact details at paragraph 12, below or by logging-in to your patient registration account online and updating your personal details.

5 Who do we share your information with?

5.1 As part of using our Services, you consent to us sharing your personal information with the following parties:

  • Our data hosting/support service providers who process and store data on our behalf.
  • Our professional advisers, or other organisations, only for the purpose of fulfilling our legal obligations.

5.2 We may also share your personal information with third parties:

  • In the event that we, our business, or substantially all of its assets are acquired by a third party (in which case personal information about registered patients will be one of the transferred assets);
  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply any contract with or to protect our rights, property, or safety of our employees, customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction; or
  • If such disclosure is necessary in connection with any law.

5.3 We do not share your personal data with third parties for the purpose of any marketing or promotional activities.

6 Transfers of personal data outside of the United Kingdom and the EEA (European Economic Area)

6.1We will only transfer your personal data outside of the United Kingdom or EEA if necessary to enable us to communicate with you in relation to our Services, or should we contract any data processing services from companies that are registered outside of these areas. By providing us with your personal information, you agree that we may transfer, store and process your information in this manner.

6.2 We shall ensure that any such transfers outside of the United Kingdom and the EEA are lawful and with an adequate level of protection and that your personal is kept secure in accordance with the DPA 1998 (up to and including 24 May 2018) and the GDPR (from and including 25 May 2018).

7 How long do we store your personal data for?

We only store your personal information for as long as necessary for the purposes listed in paragraph 4.

8 What are your rights?

8.1 You may exercise your rights below by contacting us using the contact details in paragraph 11 of this Privacy Policy.

8.2 Access to your personal data: You may request access to a copy of your personal data by contacting us using the contact details in paragraph 11.

8.3 Right to withdraw: You may withdraw your consent to us processing your personal data at any time. Please contact us using the details located at paragraph 11 if you would like to withdraw your consent and we will delete your data in line with your right to erasure at paragraph 8.5 below. Please note that in the event that you wish to exercise your rights under this paragraph 8.3, we may be unable to process your data any further or continue to provide our Services to you.

8.4 Rectification: You may ask us to rectify inaccurate information held about you. If you would like to update the data we hold about you, please contact us using the details in paragraph 11 or by logging-in to your online booking account and updating your registration information accordingly.

8.5 Erasure: You may ask us to delete your personal data. If you would like us to delete the personal data we hold about you, please contact us using the contact details in paragraph 11 and specify why you would like us to delete your personal data. Please note that in some instances we may have a legal obligation not to delete some parts of your personal data (See paragraph 4.1, above). Please note also that in the event that you wish to exercise your rights under this paragraph 8.5, we may be unable to process your data any further or continue to provide our Services to you.

8.6 Portability: You may ask us to provide you with the personal information that we hold about you in a structured, commonly used form or ask for us to send such personal data to another data controller by contacting us using the contact details in paragraph 11.

8.7 Right to object: You may object to our processing of your personal data pursuant to this Privacy Policy. Please contact us using the details in paragraph 11, providing details of your objection. Please note that in the event that you wish to exercise your rights under this paragraph 8.7, we may be unable to process your data any further or continue to provide our Services to you.

8.8 Make a complaint: You may make a complaint about our data processing activities to a supervisory authority, for the UK this is the Information Commissioner’s Office, at ico.org.uk.

9 Security and Data Storage

9.1 We will treat all of your information in strict confidence and we will endeavour to take all reasonable steps to keep your personal data secure once it has been transferred to our systems. We adopt and ensure any third party suppliers providing services on our behalf adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorised access, alteration, disclosure or destruction of your personal information, and data stored on the Websites and associated databases.

9.2 Please note that the internet is not a secure medium and we cannot guarantee the security of any data you disclose online. You accept the inherent security risks of providing information and dealing online over the internet and will not hold us liable for any breaches of your data protection rights attributable to the transmission of your personal data over the internet.

10 Changes to this Privacy Policy

10.1 We may modify this Privacy Policy from time to time, so please review it regularly.

10.2 If we change this Privacy Policy we shall notify you by means of a notice on our Website Privacy Policy page and/or by notices in our clinic reception.

10.3 This Privacy Policy was last amended on 2nd May 2018.

11 Contact

If you have any queries relating to this Privacy Policy or our use of your personal data or you wish to exercise any of your rights under this Privacy Policy please contact our privacy team at reception@cotswoldchiro.co.uk, stating ‘FAO Data Protection Officer’ in the subject field, or our Data Protection Officer by post at Cotswold Chiropractic, Stoke Road, Bishops Cleeve, Cheltenham, Glos, GL52 8RP.


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