Privacy Policy

In providing your dental care and treatment, we will ask for information about you and your health. Occasionally, we may receive information from other providers who have been involved in providing your care. This privacy notice describes the type of personal information we hold, why we hold it and what we do with it.

We are Pennypot Dental Practice Ltd operating at:

• Pennypot Dental Hythe, 1 Martello Drive, Hythe, Kent. CT21 6PH hythe@pennypotdental.co.uk
• Pennypot Dental New Romney, 17 Littlestone Road, New Romney, Kent. TN28 8LN
  newromney@pennypotdental.co.uk
• Pennypot Dental Hawkinge, 90 Canterbury Road, Hawkinge, Folkestone, Kent. CT18 7BN
  hawkinge@pennypotdental.co.uk
• Pennypot Dental Deal, 234 Dover Road, Walmer, Deal, Kent. CT14 7NE
  deal@pennypotdental.co.uk
• Pennypot Dental Ashford, 1 Commercial Quarter, 1 Dover Place, Ashford, Kent. TN23 1FB
  ashford@pennypotdental.co.uk

Naishad Patel is responsible for keeping secure the information that we hold about you. Those at the practice who have access to your information include dentists and other dental professionals involved with your care and treatment, and the reception staff responsible for the management and administration of the practice.

Our data protection officer, Naishad Patel, ensures that the practice complies with data protection requirements to ensure that we collect, use, store and dispose of your information responsibly. You can contact our data protection officer by emailing the practice.

We store your personal information securely on our practice computer system and in a manual filing system. Your information cannot be accessed by those who do not work at the practice; only those working at the practice have access to your information.

They understand their legal responsibility to maintain confidentiality and follow practice procedures to ensure this.

We take precautions to ensure security of the practice premises, the practice filing systems and computers.

We use high-quality specialist dental software to record and use your personal information safely and effectively. Our computer system has a secure audit trail and we back-up information routinely.

We use cloud computing facilities for storing some of your information. The practice has a rigorous agreement with our provider to ensure that we meet the obligations described in this policy and that we keep your information securely.
We keep your records for 10 years after the date of your last visit to the Practice or until you reach the age of 25 years, whichever is the longer.

At your request, we will delete non-essential information (for example some contact details) before the end of this period.

You have a right to access the information that we hold about you and to receive a copy. Access may be obtained by making a request in writing to Naishad Patel.

You can also request us to:

• Correct any information that you believe is inaccurate or incomplete. If we have disclosed that information to a third party, we will let them know about the change.
• Erase some of the information we hold. For legal reasons, we may be unable to erase certain information (for example, information about your dental treatment). However, we can, if you ask us to, delete some contact details and other non-clinical information.
• Stop using your information – for example, sending you reminders for appointments or information about our service. Even if you have given us consent to send you marketing information, you may withdraw that consent at any time.
• Stop using information if you believe the information is inaccurate or you believe we are using your information illegally.
• Supply your information electronically to another dentist.

If we are relying on your consent to use your personal information for a particular purpose, you may withdraw your consent at any time and we will stop using your information for that purpose.

All requests should be made to Naishad Patel at the practice email address.

If you do not wish us to use your personal information as described, you should discuss the matter with your dentist. If you object to the way that we collect and use your information, we may not be able to continue to provide your dental care.

If you have any concerns about how we use your information and you do not feel able to discuss it with your dentist or anyone at the practice, you should contact

The Information Commissioner’s Office (ICO), Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF (0303 123 1113 or 01625 545745).

Vulnerable Patient Policy

Pennypot Dental ensures that patients in vulnerable circumstances are treated not only fairly, but with empathy and sensitivity to their circumstances. This is a growing priority for the Financial Conduct Authority (FCA) and other regulators. We are aware that a vulnerable person is likely to need additional assistance at some stage in order to avoid detriment (financial or psychological) when attempting to arrange appointments, discussing treatment plans, undergoing treatment, making payments or arranging payment plans. The purpose of this policy is to ensure that the way in which we conduct our business does not have a negative impact on vulnerable patients.

A vulnerable consumer is defined as someone who has personal circumstances that place them at a higher risk of detriment, particularly if a company does not act with the appropriate level of care.

Pennypot Dental is committed to ensuring that all its team members can identify vulnerable patients, and that they are able to handle a situation involving a vulnerable patient with the required levels of care, attention and respect. A patient may find it difficult to make an informed decision about their available options for a variety of reasons.

The risk factors that contribute to patient vulnerability in financial services include:

– low literacy, numeracy and financial capability skills
– physical disability
– severe or long-term illness
– mental health problems including common mental disorders (CMD)
– low income and/or debt
– caring responsibilities (including operating a power of attorney)
– being ‘older old’ for example over 80, although this is not absolute (may be associated with cognitive or dexterity impairment, sensory impairments such as hearing or sight, onset of ill- health, not being comfortable with new technology)
– being young (associated with less experience)
– change in circumstances (e.g. job loss, bereavement, divorce)
– lack of English language skills
– non-standard requirements or credit history (e.g., armed forces personnel returning from abroad, ex-offenders; care-home leavers, recent immigrants).

Living with a disability, illness or diagnosis does not in itself make someone vulnerable. In the context of financial services, it is the person’s situation and barriers to accessing such services that may make them vulnerable. Equally a person may be vulnerable without any disability, illness or diagnosis, for example if they are recently bereaved or frail.

Identifying Vulnerable Patients
For team members to correctly address the needs of a vulnerable patient, it is important to be able to identify them.

Risk factors that can help to identify a vulnerable patient include illness, disability, illiteracy, bereavement, and other impairments as indicated above. The patient may have indicated a vulnerability in correspondence or one or more of the following indicators may become apparent during a telephone conversation or meeting.

Key indicators that often highlight a risk factor include:
a) Can the patient hear everything you are saying, and do they understand what you are saying? Do they ask you to slow down or to speak louder?
Are you sure they have heard and understood all the relevant details?
Do they ask you to clarify any details or advise they do not understand terminology being used?

b) Does the patient stay on topic and hold a conversation that is coherent, or do they appear distracted or confused?
Do the patient responses remain relevant and are their questions typical for the discussion being had?

c) Does the patient take an unusually long amount of time to answer a question that suggests they are struggling to process the information provided to them?

d) Does the patient indicate they may have a disability or impairment based on their voice, pronunciation, breathing, hearing or ability to understand the conversation?
Are they coherent and fluent in the language being used?

Dealing with Vulnerable Patients
Just because somebody is vulnerable does not automatically mean that they are unsuitable for the products and services. As soon as we think we may be engaging with a vulnerable person we should take care to adhere to the requirements set out in this policy.

When dealing with vulnerable patients’ team members must remain aware of the following guidelines:
a) Remain patient and empathetic; do not rush them, interrupt, or appear impatient. Allow them to arrive at their own decisions and process the information sufficiently.

b) Ensure the patient is able to hear and understand what you are saying, ask the patient to explain their understanding of what you are telling them, or include questions as frequently as possible to ensure they are aware of and understand what is being discussed.

c) Allow the patient to explain thoroughly; do not assume you already know what their requirements or needs are, and do not finish off their sentences which often implies you are rushing them to progress the conversation. Listen carefully to the patient and remain conscious of any absence of understanding, hints at unawareness, or forgetfulness of topics already discussed.

d) Clarify that the patient is comfortable with the standard and method of communication and offer to provide details in an alternate format such as via post or email for clarity. Before acting on a vulnerable patient’s advice, ask if there is anybody else, they need to speak to about their decision.

When a vulnerable person has been identified a relevant note should be added to their record to ensure awareness extends to all team members who deal with the patient. It is important that we maintain a consistent level of service, and that a vulnerable patient receives adequate care irrespective of which team member they liaise with. Any such notes should describe the reasons for the assessment of the patient as vulnerable and be respectful.

Mental capacity
Mental capacity relates to the ability of the individual to understand and to retain and evaluate relevant information in order to be able to decide based on that information.

If a team member believes that a vulnerable patient is unable to decide for themselves, they should attempt to identify a carer or next of kin who is authorised to act on their behalf with respect to their financial affairs. In many cases, a parent or spouse will represent the interests of the vulnerable patient. All team members who deal directly with patients, regardless of position, must familiarise themselves with this policy and ensure they understand it completely.

Product literature
It is acknowledged that there are limits to what we can reasonably do to form a view as to whether a patient has, or may have, some form of capacity limitation. However, it is good practice, in product literature provided to patients prior to providing a relevant product or service, to invite patients to disclose (on a voluntary basis) whether there are any issues relating to their health or general well-being which may be relevant to the consideration of any product or decision. Any such invitation should make clear that the information provided will be used solely to facilitate an informed service being provided.

If a patient provides information which indicates that they do, or may, have some form of mental capacity limitation that might impact on their ability to make an informed decision, this should not lead to them automatically being denied access to the product or service being sought. It should act as a trigger for us to consider what reasonable steps might be taken in order to amend our usual processes to ensure that the patient is treated fairly and a positive outcome result for them.

Training
Our vulnerable patient lead is Naishad Patel. All team members undergo training on safeguarding vulnerable patients during our induction process and annually. We review all policies relating to safeguarding and vulnerable patients annually.

Additional Support
If we identify a patient who may be in need of specialist advice which we are unable to offer. We will refer them to, or we will seek guidance from an appropriate organisation such as:
• Stepchange
• Money Advice Trust
• CAB
• Samaritans
• Age UK
• Alzheimers Society
• Mind

Sources of guidance we refer to:
• Equality Act 2010
• Mental Capacity Act 2005
• CONC 2.10 Contact with customers
• Mental Capacity Guidance
• Irresponsible Lending Guidance
• MALG Consumers with mental health problems & debt
• MALG 12 steps to treating vulnerable consumers fairly