1) Privacy Notice

2) Explicit Consent

3) Complaints Procedure

1) Lowbourne Osteopaths Privacy Notice 2018




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) which is EU wide and far more extensive than its predecessor the Data Protection Act, along with the Privacy and Electronic Communications Regulations (PECR), seek to protect and enhance the rights of EU 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 and its storage within the EEA.


1 - Your Practice Lowbourne Osteopaths Ltd, based at 39 Lowbourne Melskham SN12 7ED, which hereafter for the purposes of this Privacy Notice will be referred to as the Osteopaths, is pleased to provide the following information:


2 - Who we are
The Osteopaths diagnose and treat health conditions. Treatments are carried out in accordance with the Institute of Osteopathy’s patient charter
http://www.iosteopathy.org/osteopathy/the-patient-charter/. The practice may also provide other treatments, about which our staff will be pleased to provide more details.


3 - Personal Data
a) For the purposes of providing treatment, Osteopaths may require detailed medical information. We will only collect what is relevant and necessary for your treatment. When you visit our practice, we will make notes which may include details concerning your medication, treatment and other issues affecting your health. This data is always held securely, is not shared with anyone not involved in your treatment, although for data storage purposes it may be handled by pre-vetted staff who have all signed an integrity and confidentiality agreement. To be able to process your personal data it is a condition of any treatment that you give your explicit consent to allow Osteopaths to document and process your personal medical data. Contact details provided by you such as telephone numbers, email addresses, postal addresses may be used to remind you of future appointments and provide reports or other information concerning your treatment.
b) For marketing purposes, the Osteopaths may also use the contact details provided by you to respond to your enquiries, including making telephone contact and emailing information to you which the practice believes may be of interest to you.
c) In making initial contact with the practice you consent to Osteopaths maintaining a marketing dialogue with you until you either opt out (which you can do at any time) or we decide to desist in promoting our services. Osteopaths may occasionally also act on behalf of its patients in the capacity of data processor, when we may promote other practitioners based at our premises, who may not be employed by us. Osteopaths do not broker your data and you can ask to be removed from our marketing database by emailing or phoning the practice using the contact details provided at the end of this Privacy Notice.
d) Some basic personal data may be collected about you from the marketing 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.
e) Osteopaths’ 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. WordPress.org uses cookies to help Osteopaths to identify and track visitors and their website access preferences. Osteopaths’ website visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using Osteopaths’ website.
f) Osteopaths will only collect the information needed so that we can provide you with the services you require, the business does not sell or broker your data.


4 - Legal basis for processing any personal data
To meet our contractual obligations obtained from explicit Patient Consent and legitimate interest to respond to enquiries concerning the services provided.


5 - Legitimate interests pursued by Osteopaths
To promote treatments for patients with all types of health problems indicated for osteopathic care.


6 – Consent
Through agreeing to this privacy notice you are consenting to Osteopaths processing your personal data for the purposes outlined. You can withdraw consent at any time by using the postal, email address or telephone number provided at the end of this Privacy Notice.


7 – Disclosure
Osteopaths will keep your personal information safe and secure, only staff engaged in providing your treatment will have access to your patient records, although our administration team will have access to your contact details so that they can make appointments and manage your account. Osteopaths will not disclose your Personal Information unless compelled to, in order to meet legal obligations, regulations or valid governmental requests. The practice 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 its staff.


8 - Retention Policy
Osteopaths will process personal data during the duration of any treatment and will continue to store only the personal data needed for eight years after the contract has expired to meet any legal obligations. After eight years all personal data will be deleted, unless basic information needs to be retained by us to meet our future obligations to you, such as erasure details. Records concerning minors who have received treatment will be retained until the child has reached the age of 25.


9 - Data storage
All Data is held in the United Kingdom. Osteopaths does not store personal data outside the EEA.


10 - Your rights as a data subject
At any point whilst Osteopaths are 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.


In the event that Osteopaths 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. At your request Osteopaths can confirm what information it holds about you and how it is processed.


11 - You can request the following information:


·         Identity and the contact details of the person or organisation (Osteopaths) 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 Osteopaths and information about these 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, erasure, 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 (ICO).


·         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.


12 - To access what personal data is held, identification will be required
Osteopaths will accept the following forms of identification (ID) when information on your personal data is requested: a copy of your driving licence, 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 Osteopaths is dissatisfied with the quality, further information may be sought before personal data can be released.All requests should be made to This email address is being protected from spambots. You need JavaScript enabled to view it. or by phoning +44 01225 704883 or writing to us at the address further below.


13 Complaints
In the event that you wish to make a complaint about how your personal data is being processed by Osteopaths you have the right to complain to us. If you do not get a response within 30 days, you can complain to the ICO.


The details for each of these contacts are:


Caspar Hull, 39 Lowbourne Melksham, SN12 7ED, 01225 704883 This email address is being protected from spambots. You need JavaScript enabled to view it.


Wycliffe House, Water Lane, Wilmslow, SK9 5AFTelephone +44 (0) 303 123 1113 or email:





2) Explicit Consent


I explicitly consent to you creating and storing medical records concerning my treatment, which may include details concerning my medication, treatment and other issues affecting my health conditions, in accordance with the General Data Protection Regulation (GDPR). I understand that these records will be retained for eight years, (or until I reach 25 in the case of someone aged 16 - 18), when treatment is ceased in order to comply with the Institute of Osteopathy legal guidelines. I understand that these records will be processed in accordance with your 2018 Privacy Notice, a copy of which I have seen.




I have read and understood the above information and give my explicit consent:








For future appointments and administration, our preferred communication route/s is:




[ ] Telephone


[ ] Email


[ ] Post


[ ] Other (please state) ……………………………………………………………….………………




Promotional Information


For the purposes of promoting healthcare including offers and advice the Practice would also like to stay in touch with you, with information that may be of interest to you.

For providing promotional information you can stay in touch with me using the following methods:


[ ] Telephone


[ ] Email


[ ] Post


[ ] Other (please state) ………………………………………………



Copies of these can also be accessed at Lowbourne Osteopaths clinic.





3) Complaints Procedure






If you believe your complaint is to do with the sort of service you received from our practice,or the behaviour of one of our osteopaths ,then contact us directly and talk it through.The majority of problems are caused by misunderstandings and can easily be resolved locally. We take any complaint about an osteopath very seriously.The steps we take to investigate and deal with them are governed by rules set by the Privy Council.


If you are still not satisfied,or the complaint is more serious,you should contact the General Osteopathic Council at their Fitness to Practise department,as the GOsC may have the power to deal with it. All our osteopaths are registered with the GOsC.




You can telephone the GOsC to discuss your complaint.If you decide to lodge a formal complaint with them, they will ask you to provide as much information as you can about your allegations.They  need this in writing,so they may ask you to fill in a form to help .




Once you have contacted the GOsC your complaint will be assessed by a Screener,to make sure it is something the GOsC should be dealing with.The Screener will look carefully at all the information you have given .If need be,they may contact you to clarify certain details.


Having considered all the information and evidence available,the Screener may decide not to act on the complaint at this stage.If this happens,they will tell you why they are not taking your complaint further.It may be because:  the practitioner is not registered with the GOsC; the complaint is not serious enough; the complaint is not related to an osteopath's practice;  there is unlikely to be sufficient evidence to support the complaint.


The Screener will not reject a complaint without first consulting with a lay member of the Investigating Committee (IC).Where the Screener cannot proceed with a case,they may still want the osteopath formally notified that the matter will be taken into account should there be further investigation to see whether enough evidence can be gathered to support your allegations.However serious your complaint is,they must have sufficient evidence to make a case at a hearing.If they cannot do this,your case will not proceed.


If the GOsC investigate a complaint,they will tell the osteopath about the allegations,and the osteopath has the right to respond.They shall need your agreement to contact the osteopath and so your identity will be revealed.They will also send a copy of the allegations to the osteopath.






The Screener will report to the Investigating Committee (IC).This is made up of osteopaths and lay members.Their job is to assess the complaint,the supporting evidence and any response from the osteopath.They must then decide whether there should be a public hearing.


After considering the Screener's report,the IC can:  refer the case to the Health Committee (HC) if the osteopath appears to have a health problem (please contact GosC if you would like more information on how the HC works);  decide to take no further action;  refer the allegations for a public hearing.


If the IC decides on a public hearing,the GOsC will instruct their solicitors to prepare the case against the osteopath.




All Professional Conduct Committee (PCC) hearings are held in public and must follow formal procedures,like a court case.The press may attend.The PCC will listen to both sides and then,in private and with help from a legal assessor,consider which facts are proved and whether these amount to: serious incompetence;  unacceptable conduct; or a conviction for a serious criminal offence.


Although you may have made the original complaint,your role in any PCC hearing is that of a witness,and you may be asked to give evidence on oath.The PCC will always include at least one lay GOsC member to see each case from the public interest point of view.




The Professional Conduct Committee (PCC) will usually announce its decision after the hearing and in the presence of everyone who took part.If the case is proven,the osteopath or his/her legal representative may give mitigation before the PCC considers what action to take.An osteopath's name will be removed from the Register (meaning they cannot practise as an osteopath) only in the most serious cases.


Other steps the PCC might take are: > suspending an osteopath from practice,for a period of time; > imposing conditions on the osteopath's practice or allowing them to continue work in a limited way; > formally admonishing the osteopath.


The PCC cannot order an osteopath to compensate a client or pay a fine.






An osteopath can appeal against a decision to remove or restrict their registration to one of the following Courts:


 Court of Session in Scotland,  High Court of Justice in Northern Ireland,  High Court of Justice in England and Wales


Decisions of the Professional Conduct Committee can also be appealed against by the Council for Healthcare Regulatory Excellence (CHRE).




The offices of the General Osteopathic Council (GOsC) are based at:



TEL:020 7357 6655 FAX:020 7357 0011







Safeguarding Vulnerable Adults 


Definition of a vulnerable adults 

Definition of “vulnerable adults” where a local authority or organisation has reasonable cause to suspect that an adult · has needs for care and support and they are · experiencing, or is at risk of, abuse or neglect, and · as a result of those needs is unable to protect himself or herself against the abuse or neglect or the risk of it. 


It is about promoting good practice when responding to specific concerns. The organisation or local authority must make whatever enquiries it thinks necessary to enable it to decide whether any action should be taken in the adult’s case and, if so, what and by whom.

 Adult safeguarding” is the process of protecting adults with care and support needs from abuse or neglect to spot those at risk and take steps to protect them. 

The LO LTD must be notified of any vulnerable adults who wish to become clients or guests of our organisation.

When attending as a guest with a client or group it is the responsibility of that organisation to ensure their needs are met.

LO LTD will respond to all allegations or concerns regarding the abuse of vulnerable adults, in accordance with these policies and procedures 



Responding to disclosures of abuse in responding to a disclosure of abuse, a helper should: 

1. Listen to the information and accept what they hear without passing judgment or minimising the information; 

2. Not put words into the child’s or vulnerable adult’s mouth or make judgmental statements about any person; 

3. Take into account the child’s or vulnerable adult’s level of understanding, their culture and use of language; 

4. Not interrogate the child or vulnerable adult as it is not their responsibility to investigate but should instead be calm and reassuring; 

5. Not make promises that cannot be kept, for example that the helper will not tell anyone else; 

6. Be clear about what they are going to do next and when; 

7. Tell the child or vulnerable adult who the helper will need to contact i.e. the Safeguarding Lead; 

8. Not promise total confidentiality but explain that the information will be treated with great care and, where necessary shared, on a need to know basis only, to safeguard the child or vulnerable adult; 

9. Make careful notes, using the safeguarding concern report form if possible, as soon as feasible including dates, times, details of the incident, when the recording was made, who was present etc. These records or notes must be kept securely; 


10. Contact the Safeguarding Lead, or, in their absence, a Safeguarding Advisor as soon as possible to inform and consult with them about the need for action, including the need to make a referral to adult’s or child’s services or the police; 

11. If a Safeguarding Advisor is unavailable, it is possible to consult adult’s or child’s services or the police directly, without giving personal details of the vulnerable adult or child. The advice given may be that a referral must be made in which case this must be done immediately; 

12. Provide the child or vulnerable adult or their carer/guardian with some means of contact and be clear about how and when they will be contacted with feedback as to what will happen next; 

13. Never leave a child or vulnerable adult or their carer/guardian to wait to hear from someone else, e.g. a police officer or social worker, without any idea of timescale or place; 

14. Not contact the person about whom the allegation or concern is being raised to tell them about the allegation or concern because this could put the child or vulnerable adult in serious danger, for example, where there is domestic violence taking place, and/or prejudice any investigation; and 

15. Where the concerns or allegations are about a LO LTD member, a helper or another adult in a position of trust, do not inform the person in question because, again, this might prejudice any police investigation - always contact a Safeguarding Advisor.  




All safeguarding concerns should be referred to a Group’s Safeguarding Lead in the first instance before onward referral to a Safeguarding Advisor. In all circumstances, the LO LTD safeguarding procedures should be followed. 

If a helper or member of staff receives a disclosure of abuse or has any safeguarding concerns about a child or vulnerable adult, the concern must be reported, in person or by telephone, to the Group’s Safeguarding Lead or Deputy Safeguarding Lead. 

The Safeguarding Lead or Deputy Safeguarding Lead shall then report the concern to the Group’s Safeguarding Advisor again, either in person or by telephone, as soon as possible though always within 24 hours of the helper or member of staff becoming aware of the concern. 

The verbal report should be followed with the completion of an LO LTD safeguarding concern report form. 

The helper who first received the disclosure or raised the concern should have input in the completion of the report form. 

All safeguarding concerns reported to a Safeguarding Advisor will, wherever possible, be assessed on the same day or within 24 hours and a decision made on the threshold of concern about the child or vulnerable adult. 

If the Safeguarding Advisor makes an assessment that the concern reaches the threshold of significant harm, the concern should be referred to the statutory authorities, for example, statutory services, adult’s/child’s services or the police, by the Safeguarding Advisor, for further investigation. 

In addition to completion of the LO LTD safeguarding concern report form, some statutory authorities may require the completion of local referral forms. 

If the Safeguarding Lead and/or Deputy Safeguarding Lead and Safeguarding Advisor make an assessment that the concern does not reach the threshold of significant harm or the need for intervention, the concern and any decisions or actions taken should still be recorded and the record passed to LO directors to be retained. 

If the clubs allocated Safeguarding Advisor is unavailable, details of another available Safeguarding Advisor can be obtained by contacting LO LTD directors directly. 

If there are immediate concerns about a child’s or vulnerable adult’s safety and it is not possible to contact a Safeguarding Advisor, the emergency situations procedure, and contact the police.

Safeguarding concerns shall be recorded on the LO LTD safeguarding concerns report form which can be found at on the intranet under the ‘safeguarding’ tab. The report form has an on-going chronological event log attached to it and the Safeguarding Lead or Safeguarding Advisor, shall record all discussions, actions taken and decisions made in the log accurately and timely. 

Any future discussion about the child or vulnerable adult referral should be noted in the log. All safeguarding concerns report forms should be kept in a secure drawer or locker whilst with BEC in person or by registered delivery. The following steps should be observed in recording a safeguarding concern. The individual should: 

1. Whenever possible and practical make contemporaneous notes during any conversation; 

2. Ask for permission to take notes before doing so and explain the importance of recording the information; 

3. Explain that the person giving the information can have access to the records made in respect of their own information; 

4. Where it is not appropriate to take notes at the time, make a written record as soon as possible afterwards and always before the end of the day.

5. Only record details of the injuries associated with a safeguarding concern. Other safeguarding information should be recorded on a safeguarding concern report form. Sufficient information must be entered on the vulnerable persons record, to indicate that there is a current safeguarding incident and where that information is held; 

6. Record the time, date, location, format of information (e.g. letter, telephone call, direct contact) and the names of the persons present when the information was given; 

7. Ensure that the record is signed and dated by the person making it; 

8. Include as much information as possible, but, be clear about what information is fact, hearsay or, opinion and must not make assumptions or speculate; 

9. Include the context and background leading to the disclosure; 

10. Maintain a log of actions and decisions and record times, dates and the names of people contacted and spoken to as well as their contact details; 

11. Include full details of previous concerns or referrals to statutory services and the police, if known; 

12. Ensure all original notes or documents are retained if notes are made somewhere other than the safeguarding concern report form. These original notes will form part of the evidence chain in any criminal investigation; 

13. Within 24 hours, pass all original records, including rough notes, to the Safeguarding Advisor. If this has to be done by post, the documents should be sent via registered delivery; and 

14. If any original document is urgently needed, scan and forward it via secure email. Originals and electronic documents must be retained securely in the safeguarding file.


Allegations against members or guests


 If any BEC member or helper becomes aware that another BEC member or helper who works with a child or vulnerable adult has: 

· behaved in a way that has harmed or may have harmed a child or vulnerable adult; or 

· possibly committed a criminal offence against or related to a child or vulnerable adult; or 

· behaved towards a child or vulnerable adult in a way that indicates they are unsuitable to work with children and/or vulnerable adults that individual must notify their Safeguarding Lead/Safeguarding Advisor immediately. 

In all cases where safeguarding allegations are made against BEC members or helpers, which indicate that they may be unsuitable to continue working with children or vulnerable adults, that person will automatically be suspended, pending investigation. 

This will be the case, even if the concern or allegation is not linked to an activity or behaviour conducted within working hours or while working as a volunteer for BEC

Such action does not presume guilt and the decision to suspend will not be made lightly. It will only be made after careful consideration of the initial facts by the Safeguarding Advisor, the Safeguarding Committee.

For LO LTD members, LO LTD disciplinary procedures will be followed and will be clearly separated from safeguarding enquiries and criminal investigations. 

LO LTD recognises that it has a continuing duty of care to a suspended member or helper. Therefore, it is important to provide support for the person against whom the allegation is made during the investigative process and action should be taken to reinstate them quickly, if the allegations are found to be false. A named support person, not connected with the investigation, will be allocated in each case by the Safeguarding Advisor. 

That support person’s role will be purely pastoral and guidance will be provided as to their remit that is relevant in each case. The support person will be in a position to signpost suspended members and helpers to other external support networks, for example, local GPs or the Samaritans. LO LTD will, via a Safeguarding Advisor or member of the Safeguarding Committee, also refer any safeguarding concerns or allegations about its staff or helpers immediately to local authority services via the Local Authority Designated Officer (LADO) in England & Wales. The role of the LADO is set out in the Government guidance ‘Working Together to Safeguard Children 2013’. The LADO is usually located with childrens’ social services. The police may also be involved at this time. In Scotland the procedure is as described in the National Guidance 201412. Suspension process for helpers while in the UK The BEC committee or nominated officer is responsible for suspending any helper. 


If a decision is made to suspend a helper while in the UK, the person suspended should: 

1. be informed, by the LO LTD committee or nominated representative, as soon as possible; 

2. receive a personal visit by two LO LTD representatives who should deliver a written notice of suspension advising the suspended person that they are prevented from continuing the work of LO LTD or giving anyone the impression that they represent LO LTD;

3.sign a copy of the notice of suspension to confirm that they have received the notice and understand the terms; 

4. be removed from all LO LTD premises and activities;

5. be advised if an investigation has been triggered into their conduct. For example, the police, social services or an internal disciplinary process.

Useful contacts;

Local authority- to be confirmed at Wiltshire County council

CQC – Quality care standards 03000 616161   This email address is being protected from spambots. You need JavaScript enabled to view it. .

Wiltshire police 101