Tonic Privacy Policy and Complaints Procedure

Introduction

This document refers to personal data, which is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain.

The General Data Protection Regulation (GDPR) seeks to protect and enhance the rights of data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU. It should be noted that GDPR does not apply to information already in the public domain.

TONIC WEIGHT LOSS SURGERY LTD is pleased to provide the following Privacy Notice:

Personal Data

TONIC WEIGHT LOSS SURGERY LTD uses the information collected from you to provide quotations, make telephone contact and to email you marketing information which TONIC WEIGHT LOSS SURGERY LTD believes may be of interest to you and your business. In you making initial contact you consent to TONIC WEIGHT LOSS SURGERY LTD maintaining a marketing dialogue with you until you either opt out (which you can do at any stage) or we decide to desist in promoting our services. TONIC WEIGHT LOSS SURGERY LTD also acts on behalf of its clients in the capacity of data processor. When working exclusively as a data processor, TONIC WEIGHT LOSS SURGERY LTD will be acting on the instruction of its client, and will work hard to ensure that the client is fully GDPR compliant.

Some personal data may be collected about you from the forms and surveys you complete, from records of our correspondence and phone calls and details of your visits to our website, including but not limited to personally identifying information like Internet Protocol (IP) addresses. TONIC WEIGHT LOSS SURGERY LTD may from time to time use such information to identify its visitors. TONIC WEIGHT LOSS SURGERY LTD may also collect statistics about the behaviour of visitors to its website.

TONIC WEIGHT LOSS SURGERY LTD’ website uses cookies, which is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Our website uses cookies to help TONIC WEIGHT LOSS SURGERY LTD identify and track visitors and their website access preferences. TONIC WEIGHT LOSS SURGERY LTD website visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using TONIC WEIGHT LOSS SURGERY LTD’s website.

Any information TONIC WEIGHT LOSS SURGERY LTD holds about you and your business encompasses all the details we hold about you and any sales transactions including any third-party information we have obtained about you from public sources and our own suppliers such as credit referencing agencies.

TONIC WEIGHT LOSS SURGERY LTD will only collect the information needed so that it can provide you with marketing and consulting services, this agency does not sell or broker your data, although coincidentally there may be times when your information could be contained in data that TONIC WEIGHT LOSS SURGERY LTD has purchased from a third-party list broker, on behalf of a client.

Legal basis for processing any personal data

To meet TONIC WEIGHT LOSS SURGERY LTD’ contractual obligations to clients and to also respond to marketing enquiries.

Legitimate interests pursued by TONIC WEIGHT LOSS SURGERY LTD and/or its clients

To promote the marketing and consulting services offered by TONIC WEIGHT LOSS SURGERY LTD and/or to market the services and/or products offered by TONIC WEIGHT LOSS SURGERY LTD’ existing clients.

Consent

Through agreeing to this privacy notice you are consenting to TONIC WEIGHT LOSS SURGERY LTD processing your personal data for the purposes outlined. You can withdraw consent at any time by emailing Kay@tonicsurgery.co.uk or writing to us, see last section for full contact details.

Disclosure

TONIC WEIGHT LOSS SURGERY LTD may on occasions pass your Personal Information to third parties exclusively to process work on its behalf. TONIC WEIGHT LOSS SURGERY LTD requires these parties to agree to process this information based on our instructions and requirements consistent with this Privacy Notice and GDPR.

TONIC WEIGHT LOSS SURGERY LTD do not broker or pass on information gained from your engagement with the agency without your consent. However, TONIC WEIGHT LOSS SURGERY LTD may disclose your Personal Information to meet legal obligations, regulations or valid governmental request. The agency may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of TONIC WEIGHT LOSS SURGERY LTD, its clients and/or the wider community.

Retention Policy

TONIC WEIGHT LOSS SURGERY LTD will process personal data during the duration of any contract and will continue to store only the personal data needed for between a minimum of five and up to twenty years after the contract has expired to meet any legal obligations.

Data storage

Data is held in UK using different (multiple) servers. TONIC WEIGHT LOSS SURGERY LTD does not store personal data outside the EEA.

Your rights as a data subject

At any point whilst TONIC WEIGHT LOSS SURGERY LTDis in possession of or processing your personal data, all data subjects 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 you 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 not to be subject to the legal effects of automated processing or profiling.

If TONIC WEIGHT LOSS SURGERY LTD refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge.

TONIC WEIGHT LOSS SURGERY LTDat your request can confirm what information it holds about you and how it is processed

You can request the following information:

Identity and the contact details of the person organisation (TONIC WEIGHT LOSS SURGERY LTD) that has determined how and why to process your data.
Contact details of the data protection officer, where applicable.
The purpose of the processing as well as the legal basis for processing.
If the processing is based on the legitimate interests of TONIC WEIGHT LOSS SURGERY LTD or a third party such as one of its clients, 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.
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 (Data Protection Regulator).
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.

To access what personal data is held, identification will be required

TONIC WEIGHT LOSS SURGERY LTDwill accept the following forms of ID when information on your personal data is requested: a copy of your national ID card, driving license, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If TONIC WEIGHT LOSS SURGERY LTDis dissatisfied with the quality, further information may be sought before personal data can be released.

All requests should be made to Kay@tonicsurgery.co.uk or by phoning 0115 950 4662 or writing to us at the address further below.

Complaints

Complaints by email should be sent to info@tonicsurgery.co.uk detailing the below information

Patient’s Name
Address
Date of Birth
Date of Surgery
A clear description of your complaint and any relevant times and dates
Details of any relevant healthcare providers or surgeons, medical staff

Other parties will have their own complaints procedure and it is advisable should you have a complaint about these to ask for a copy of their procedure.

For reasons of data protection and patient confidentiality, we will only acknowledge receipt of the complaint by email. Response/s will be sent in writing by email where possible, but may also be sent via post, and so the patient’s address will be required. We may also require further information for verification purposes.

Complaints from an authorised representative can only be accepted with the written consent of the patient concerned.

Stage 1

A written acknowledgement will be sent within 3 working days

We will undertake an immediate investigation into the comments provided and, once all relevant medical records and reports have been compiled, we will carry out a review. It may also be necessary to take advice from other Clinical Specialists within TONIC.

On completion of the investigation review, the complainant will receive a letter, within 20 working days of receiving the complaint. (This timescale does not include Weekends or Bank Holidays). This letter will contain a full written account of the outcome of the investigation, an apology for any deficiencies, and an explanation of remedial action taken.

On any occasions when a written response cannot be provided within this timescale, we will inform the patient of the status of the complaint at a minimum of 20 working day intervals and aim to reach a timely conclusion.

A complaint should be made as soon as possible and within 6 months of the date of the event, which is the subject of the complaint, or as soon as the matter first came to the attention of the complainant.

Patients seeking to clarify comments made, should write as soon as possible after the response at Stage 1and a further response will be provided within 20 working days.

Stage 2

If, following receipt of the final response from the Clinic Director, a patient wishes to seek a review of Stage 1 they should write to the Stage 2 Complaints Review Manager at the same address.

This request should be made within 4 months of the final written response, stating the reason why they are not satisfied with the Stage 1 handling of the complaint.

A written acknowledgement will be sent within 3 working days (unless a full reply can be sent within 5 working days).

The Complaints Review Manager will undertake an immediate review into the outcome provided at Stage 1 by the Clinic Director.

The Stage 2 Complaints Review Manager will respond, following review, within 20 working days of receiving the letter, to confirm the decisions and actions taken by the Complaints Manager or to offer an alternate resolution.

Where the investigation is still in progress and a decision has not been made, the Complaints Review Manager will send a letter explaining the reason for the delay to the complainant, at a minimum every 20 working days.