Data Protection
Data Protection Policy
Version 1.0 · Last updated · 7 June 2026
Precision Orthopaedic & Spine
Version: 1.0 · Effective Date: June 2026 · Review Date: June 2027
1. Purpose
1.1 The purpose of this policy is to ensure that Precision Orthopaedic & Spine and PrecisionOS Limited process personal data in accordance with the requirements of the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, common law duty of confidentiality, and all applicable healthcare information governance standards.
1.2 This policy establishes the principles, responsibilities and procedures for the lawful collection, use, storage, sharing and disposal of personal data.
1.3 The practice recognises that patient confidentiality is fundamental to the provision of safe and effective healthcare and is committed to maintaining the highest standards of information governance.
2. Scope
2.1 This policy applies to:
- a) PrecisionOS Limited
- b) Mr Mohammed Madi
- c) Employees
- d) Contractors
- e) Temporary staff
- f) Administrative personnel
- g) Overseas administrative personnel
- h) Consultants acting on behalf of the practice
- i) Any third party processing personal data on behalf of the practice
2.2 This policy applies to all forms of information including:
- a) Electronic records
- b) Paper records
- c) Medical images
- d) Audio recordings
- e) Email communications
- f) Messaging platforms
- g) Cloud-based systems
- h) Website enquiry forms
3. Definitions
3.1 Personal Data
Any information relating to an identified or identifiable individual.
3.2 Special Category Data
Information requiring additional protection, including health information, biometric information and genetic information.
3.3 Processing
Any operation performed on personal data including collection, recording, storage, retrieval, disclosure, amendment or deletion.
3.4 Data Subject
The individual to whom the personal data relates.
3.5 Data Controller
The organisation determining the purposes and means of processing personal data.
For the purposes of this policy: PrecisionOS Limited is the Data Controller.
3.6 Data Processor
A person or organisation processing personal data on behalf of the Data Controller.
4. Data Protection Principles
4.1 The practice shall comply with the following principles:
4.1.1 Lawfulness, Fairness and Transparency
Personal data shall be processed lawfully, fairly and transparently.
4.1.2 Purpose Limitation
Data shall only be collected for specified, explicit and legitimate purposes.
4.1.3 Data Minimisation
Only information necessary for the intended purpose shall be collected.
4.1.4 Accuracy
Reasonable steps shall be taken to ensure personal data remains accurate and up to date.
4.1.5 Storage Limitation
Information shall not be retained longer than necessary.
4.1.6 Integrity and Confidentiality
Appropriate security measures shall be implemented to protect personal information.
4.1.7 Accountability
The practice shall be able to demonstrate compliance with all applicable legislation.
5. Categories of Information Processed
5.1 The practice may process:
5.1.1 Patient Information
- a) Name
- b) Date of birth
- c) Address
- d) Telephone number
- e) Email address
- f) NHS number
- g) Insurance details
5.1.2 Clinical Information
- a) Referral letters
- b) Consultation records
- c) Medical history
- d) Imaging
- e) Investigation results
- f) Surgical records
- g) Clinical correspondence
5.1.3 Financial Information
- a) Invoices
- b) Payment records
- c) Insurance authorisations
- d) Billing information
5.1.4 Website Information
- a) Website enquiries
- b) IP addresses
- c) Cookie information
- d) Analytics information
6. Legal Basis for Processing
6.1 Personal data shall only be processed where a lawful basis exists.
6.2 The primary lawful bases relied upon include:
6.2.1 Contract
Processing necessary to provide requested healthcare services.
6.2.2 Legitimate Interests
Administration, governance and service improvement.
6.2.3 Legal Obligation
Compliance with legal, regulatory and professional obligations.
6.2.4 Healthcare Provision
Processing of special category health information necessary for medical diagnosis, treatment and healthcare management.
7. Confidentiality
7.1 All staff and contractors must maintain patient confidentiality at all times.
7.2 Access to patient information shall be restricted to those with a legitimate need to know.
7.3 Information shall only be disclosed where:
- a) Necessary for patient care
- b) Required by law
- c) Required by a court order
- d) Explicit patient consent has been obtained
8. Information Sharing
8.1 Information may be shared with:
- a) General Practitioners
- b) Hospitals
- c) Radiology providers
- d) Physiotherapists
- e) Other healthcare professionals involved in care
- f) Insurers
- g) Regulators
- h) Legal representatives where authorised
8.2 All sharing shall be limited to the minimum necessary information.
9. International Data Transfers
9.1 The practice may utilise authorised administrative support personnel located outside the United Kingdom.
9.2 Where international transfers occur, appropriate safeguards shall be implemented including:
- a) International Data Transfer Agreements (IDTAs)
- b) Data Processing Agreements
- c) Confidentiality Agreements
- d) Role-based access controls
- e) Encryption
- f) Audit logging
9.3 International processing arrangements shall be reviewed periodically to ensure continued compliance.
10. Information Security
10.1 The practice shall implement technical and organisational measures appropriate to the risks presented by the processing activities.
10.2 Measures may include:
- a) Multi-factor authentication
- b) Encryption
- c) Password management
- d) Secure cloud storage
- e) Audit logs
- f) Access controls
- g) Endpoint security
- h) Secure backups
11. Data Retention
11.1 Records shall be retained in accordance with applicable NHS and private healthcare retention schedules.
11.2 At the end of the retention period, records shall be securely destroyed or anonymised.
12. Data Subject Rights
12.1 Individuals have rights under UK GDPR including:
- a) Right of access
- b) Right to rectification
- c) Right to restriction of processing
- d) Right to object
- e) Right to data portability where applicable
- f) Rights relating to automated decision-making
12.2 Requests shall be handled within statutory timescales.
13. Data Breach Management
13.1 Any actual or suspected data breach must be reported immediately to the Practice Director.
13.2 All breaches shall be investigated and documented.
13.3 Where required, breaches shall be reported to the Information Commissioner's Office within statutory time limits.
13.4 Affected individuals shall be notified where there is a high risk to their rights and freedoms.
14. Training
14.1 All personnel with access to personal information shall receive appropriate information governance and confidentiality training.
14.2 Training records shall be maintained.
15. Monitoring and Audit
15.1 Compliance with this policy shall be monitored through periodic review and audit.
15.2 Findings shall be used to improve information governance arrangements.
16. Responsibilities
16.1 Practice Director
Mr Mohammed Madi shall have overall responsibility for ensuring compliance with this policy.
16.2 Staff and Contractors
All staff and contractors are responsible for:
- a) Compliance with this policy
- b) Maintaining confidentiality
- c) Reporting incidents
- d) Following security procedures
17. Related Documents
- Privacy Policy
- Information Security Policy
- Records Management Policy
- Cookie Policy
- Data Breach Procedure
- Subject Access Request Procedure
- Confidentiality Policy
- Acceptable Use Policy
- Data Processing Agreements
- International Data Transfer Agreements
18. Review
18.1 This policy shall be reviewed annually or sooner if there are significant legislative, regulatory or operational changes.
18.2 The current approved version shall be maintained by PrecisionOS Limited.
Approval
- Approved By: Mr Mohammed Madi
- Position: Director, PrecisionOS Limited
- Version: 1.0
- Effective Date: June 2026
- Next Review Date: June 2027
For any questions about this policy, please contact the practice.