PRIVACY NOTICE FOR PATIENTS
We are Todays Dental, a group of companies that operate dental practices throughout England and Wales.
This privacy notice is issued on behalf Todays Dental Group Limited and its subsidiaries (Group) so when we mention “we”, “our”, “us”, or “Todays Dental”, we are referring to the relevant company in the Group responsible for your data.
Each practice website states which Todays Dental entity is the data controller for that practice.
Todays Dental is committed to protecting the privacy and security of your personal information.
This privacy notice contains information about how Todays Dental collects, uses and looks after your personal information when we provide your dental care and treatment, your privacy rights and how the law protects you.
We have appointed a data protection officer (DPO) who is responsible for overseeing matters relating to this privacy notice.
If you have any questions about this privacy notice or the way in which we handle your personal information or you want to exercise your privacy rights, please contact us in the following ways:
Postal Address:
Data Protection Officer
Todays Dental
Monmouth House
Blackbrook Business Park
Taunton TA1 2PX
Telephone: 018 2358 7960
Data Protection Officer: privacy@todaysdental.co.uk
The types of personal data we collect about you
Personal data means any information about an individual from which that person can be identified.
We may collect, use, store and share different kinds of personal data about you which we have grouped together as follows:
- Personal information:
- Title, first name, surname, preferred name, address, post code, mobile number, alternate contact number, personal and work email addresses, GP contact details
- Characteristics information (such as gender, age and date of birth)
- National insurance number, NHS number (where applicable)
- Next of kin and their contact number, relationship to you and if they are a patient at the practice
- Occupation
- Dental and health records (special categories of personal data):
- Medical and dental history
- Treatment plans and consent
- X-rays, clinical photographs, digital scans of your mouth and teeth and study models
- Clinical records made by dentists and other dental professionals involved with your care and treatment
- Notes of conversations with you about your care
- Communication records with you such as letters and emails
- Correspondence from other health professionals or institutions involved in your care
- Dates of your appointments and reminders
- Details of any complaints and/or feedback that you make and how those complaints were dealt with
- Financial information
- Fees charged by us and the amounts you have paid
- Exemption details (NHS only)
- Data about your use of a practice’s website:
- Internet Protocol (IP) address
- Login data
- Details about your browser
- Length of visit to pages on a website
- Page views and navigation paths
- Details about the number of times you use a website
- Time zone settings on the devices a patient uses to access a website, social media channels and patient portal
- Third party cookies which monitor activity throughout a website using third-party providers. Please note that you can always set your browser to only accept essential cookies
How is your personal data collected?
We use different methods to collect data from and about you including through:
- Your interactions with us. You may give us your personal data in a number of ways including by: making an enquiry for dental care and treatment at one of our practices; joining or registering with one of our practices; filling in online forms; completing medical and dental history forms; corresponding with us in person, by post, phone or email or through our website; requesting marketing be sent to you; giving us feedback.
- Third parties. We may receive personal data about you from various third parties such as:
- from another practice if it becomes part of our Group
- from another clinician (or the NHS or a hospital) if they refer you to us for treatment
- Automated technologies or interactions. As you interact with our website, we will automatically collect technical data from analytics providers (such as Google, based outside the UK) about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy www.todaysdental.co.uk/practicecookiepolicy for further details.
How we use your personal data
Legal basis
The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
- Performance of our contract with you [*]: We may use your personal data to enable us to provide you with dental care and treatment and perform any contract we may have with you.
- Legal obligation [**]: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
- Legitimate interests [***]: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
- Consent [****]: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to marketing.
Purposes for which we will use your personal data
We have set out below the various ways we plan to use the various categories of your personal data and have indicated using asterisks the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate:
- Maintain clinical records and provide dental treatment, prevention and oral health advice [*] and [**]
- Refer you to other dentists or doctors and health professionals as required [***]
- Carry out financial transactions and for debt recovery [***]
- Send information to the General Dental Council or other authority as required by law [**]
- Communicate with you [***] and [****]:
- establish your preference for how we contact you about your dental care
- appointment reminders, treatment plans and estimates, changes to dental appointments and provision of dental care at your practice
- with your next of kin in an emergency
- to inform you of products and services available at our practices
- conduct patient surveys or to find out if patients are happy with the treatment received in order to continually improve the care and service a patient receives from us for quality control purposes
- Where we request your consent to the collection, processing and transfer of your personal data for a specific purpose e.g. to receive notifications, newsletters, surveys or marketing, you have the right to withdraw consent for that specific processing at any time. To withdraw your consent, you should contact your practice (FAO: practice manager) in writing. Once we receive your notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes that you originally agreed to.
- Analyse and understand the effectiveness of our marketing activities [***]
- Ensure your safety when you visit a dental practice where there is CCTV [***]
- Undertake dental research or dental education. We will discuss this with you and seek your consent. Depending on the purpose and if possible, we will anonymise your information. If this is not possible, we will inform you and discuss your options [***] and [****]
Direct marketing
When you join or register with one of our practices, you will be asked to indicate your preferences for receiving direct marketing communications from Todays Dental via email, SMS, telephone or post.
We may also analyse your personal information to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.
Third-party marketing
We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.
Opting out of marketing
You can ask us to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by following these steps:
- Contact the Practice: To opt out, please contact the practice where you are registered. You can do so by speaking with the reception team or by contacting the practice manager. They will help you update your marketing preferences.
- By Phone or In Person: Visit or call your registered practice to request the opt-out.
- By Written Request: If you prefer, you can also write to the practice and request that your marketing preferences be updated.
Once your request is received, we will ensure that you no longer receive marketing communications. However, you may still receive essential service-related communications, such as appointment reminders or updates about your care.
Cookies
For more information about the cookies we use and how to change your cookie preferences, please see www.todaysdental.co.uk/practicecookiepolicy.
Sharing your personal data
Although typically your personal information will only be used by those working in your practice or in our Resource Hub, we may need to share it with third parties, including those set out below:
- Your doctor
- Your hospital or community dental services or other health professionals caring for you
- Specialist dental or medical services to which you may be referred
- Former healthcare associates/partners (e.g. Dentists, dental hygienists etc.) as they have an ongoing responsibility for work provided under their care
- Dental laboratories
- NHS payment authorities
- Dental payment plan administrators
- The Department for Work and Pensions and its agencies, where you are claiming exemption or remission from NHS charges
- Private dental schemes of which you are a member
- NHSBSA – NHS Business Services Authority
- Regulatory authorities such as the General Dental Council, the Care Quality Commission and Healthcare Inspectorate Wales
- NHS Heath Boards
- Debt collection companies
- Police, fraud prevention agencies, your insurance company – where it is considered to be in your best interest or if we have reason to believe an individual may be at risk of harm or abuse
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy. In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes
- To third parties who provide troubleshooting and support services for our various IT systems
In certain circumstances or if required by law, we may need to disclose your information to a third party not connected with your health care, including HMRC or other law enforcement or government agencies. We will only disclose your information on a need-to-know basis and will limit any information that we share to the minimum necessary.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
International transfers
We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law.
Whenever we transfer your personal data out of the UK to service providers, we ensure that appropriate safeguards are in place to ensure the security of your personal data.
Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Data retention
How long will you use my personal data for?
We retain patient clinical records and orthodontic study models in line with the British Dental Association’s recommended retention timeframes. These recommended retention periods are reiterated in NHS England’s Records Management Code of Practice.
For adult patients the retention timeframe is 11 years after the last attended appointment and for child patients we retain their personal data until they are aged 25 or for eleven years after their last attended appointment, whichever is the longer.
Your legal rights
You have a number of rights under data protection laws in relation to your personal data.
You have the right to:
- Request access to your personal data (commonly known as a “subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
- You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see Opting out of marketing above for details of how to object to receiving direct marketing communications).
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products and services to you. We will advise you if this is the case at the time you withdraw your consent. Essential healthcare communications will continue even if you withdraw your consent for marketing. This includes important information like reminders about your dental appointments, updates to your treatment plan, or urgent healthcare notifications.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
- If you want us to establish the data’s accuracy;
- Where our use of the data is unlawful but you do not want us to erase it;
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
If you wish to exercise any of the rights set out above, please contact our Data Protection Officer: privacy@todaysdental.co.uk
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Complaints
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, welcome the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last updated in March 2025.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
Last updated: March 2025