Legal

Registered Office: Portman Healthcare Ltd, 6 Pittville Lawn, Cheltenham, GL52 2BD Company number 6740579

Privacy statement

Portman Healthcare is committed to protecting and respecting your privacy and to meeting our obligations under the Data Protection Act of 1998. Portman Healthcare will comply with the law in the collection and processing of personal data and will deal promptly with any subject access request.
We collect data about patients who use our services that is relevant to their healthcare and that allows Portman Healthcare to deliver its services to our patients. We process personal information about our patients, customers, suppliers and employees.

The types of data we may collect are listed below and we will only use that data in ways relevant to carrying out our legitimate purposes and functions and in a way that is not detrimental to the interests of our patients or employees. Portman Healthcare will take particular care in the collection and storage of any personal sensitive data. Everyone working within Portman Healthcare has a legal duty to keep information about you confidential. Similarly, anyone who receives information from us has a legal duty to keep it confidential.

Model publication scheme

Guide to information provided by NHS dentists under the model publication scheme click here for details

Collection of data:

The dental professionals caring for you keep records about your health and any treatment and care you receive from our practices. These records help to ensure that you receive the best possible care. They may be written down in paper records or held on computer. These records may include:

  • Basic details about you such as name, address, date of birth, next of kin, etc.
  • Contact we have had with you such as appointments.
  • Notes and reports about your health, treatment and care.
  • Results of x-rays.
  • Relevant information from people who care for you and know you well such as health professionals and relatives.
  • Financial information for payment of any treatments

It is essential that your details are accurate and up to date. Always check that your personal details are correct when you visit us and please inform us of any changes as soon as possible.

How your personal information is used:

Your records are used to direct, manage and deliver the care you receive to ensure that:

  • The dental professionals involved in your care have accurate and up to date information to assess your oral health and decide on the most appropriate care for you.
  • Healthcare professionals have the information they need to be able to assess and improve the quality and type of care you receive.
  • Your concerns can be properly investigated if a complaint is raised.
  • Appropriate information is available if you see another dental professional, or are referred to a specialist.
  • From time to time we may use your contact information to send you details of products and services offered in our practices that directly relate to your oral healthcare.

We may collect technical data about the type of Internet browser and computer operating system that you use. This information does not identify you as an individual and is used only for tracking of site use.

Disclosure of your information

Portman Healthcare may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 and in accordance with the Data Protection Act 1998.

Portman Healthcare may disclose your personal information to third parties

  • In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
  • If Portman Healthcare or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use, and other agreements; or to protect the rights, property, or safety of Portman Healthcare, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud prevention and credit risk reduction.

Your rights

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data or unsubscribing via our email communications. You can also exercise the right at any time by contacting us at:

Information Governance
Portman Healthcare Ltd,
6 Pittville Lawn,
Cheltenham, GL52 2BD

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Access to information

The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 for computerised records and up to £50 for any non-digital x-ray copies that are required to provide you with details of the information you have requested.

Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.

Modern Slavery Act

At Portman, we are committed to improving our practices to combat modern slavery and human trafficking within our business operations.
We are relentless in our pursuit of delivering quality and excellent dental care to our patients, using our professional expertise with integrity and aligning our actions to the highest standards of business conduct and ethical practices.

Modern slavery is a crime and a violation of fundamental human rights. This statement underlines our commitment and actions to ensuring modern slavery is not taking place anywhere in and around our organisation.

This statement is made on behalf of Portman pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement.

Organisation’s structure

Portman Healthcare (Holdings) Ltd is a limited company registered in England, UK (registered company number 9114888).

Established in 2008, we provide privately funded dental care to patients throughout the UK through the brand of Portman Dental Care. Our business consists of a group of dental practices across the UK and was founded by Sam Waley-Cohen, who is the Chief Executive Officer.

Portman Healthcare Ltd is the main trading company of the Portman Dental Care group. Other companies also trade under this brand

Portman operates as follows:

 

As at 1 April 2017:

  • we had more than 50 dental practices operating across the UK;
  • we employ in excess of 500 employees;
  • we engage with over 300 dental consultants/ specialists;
  • we engage with approximately 2,500 suppliers per annum.

Our ethos, vision and values

Our vision is to be the best private-focused dental group in the world. We aim to achieve this by:

  • putting patient care at the heart of everything we do;
  • delivering innovative and world class dental care;
  • always looking to develop and improve;
  • by being at the heart of every local community; and
  • by being an amazing place to work.

In respect of our colleagues, we have implemented a range of internal policies and procedures to ensure best practice and compliance with UK employment laws, e.g. these include; transparent recruitment processes, annual pay reviews, equal opportunities initiatives and protections, health and safety procedures.

Our central value is to treat everyone how we would want to be treated and we apply this principle to our colleagues, patients and third-party contacts.

As a group, we work to the highest professional standards and comply with all laws, regulations and rules which are relevant to our business. Our vision of being at the heart of the local community, aims to improve the impact of our business on the surrounding areas to our practices.

In turn, we expect the same high standards from those we work with and are committed to ensuring that there is no modern slavery or human trafficking practices in our supply chains or in any part of our business relationships. To help achieve this, and to ensure that our colleagues are aware of the role they can play, our Anti-Slavery Policy is published within all our practices and all teams are currently undergoing, or have undergone, training in this area.

We are committed to working with each of our practices to ensure that our Anti-Slavery Policy is complied with and we manage any breaches or concerns promptly. We have also amended our Whistle-blowing Policy to include guidance around combating anti-slavery and clarifying the protections available for employees who wish to raise a concern without the fear of disciplinary action.

Our supply chains

Portman’s supply chain consists of over 2,500 suppliers, the vast majority of whom are primarily based in the UK. Our suppliers include:

  • Professional services – accountants, legal advisors, recruitment agents;
  • Self-employed clinicians;
  • Dental laboratory, material and product suppliers;
  • Marketing and advertising services;
  • Repairs and maintenance services;
  • IT and communication systems;
  • General office and practice suppliers;

Suppliers paid over £10,000 per year make up 2.5% of our supplier spend and suppliers paid over £100,000 per year make up 0.5% of our supplier spend.

Due Diligence in respect of our supply chains

Our Anti-Slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships, and implementing and enforcing effective systems and controls to prevent slavery and human trafficking practices in our supply chains.

To help identify any potential risks within our supply chains (including in respect of new suppliers and commercial arrangements), we undertake a due diligence assessment taking into consideration the following factors:

Geographical location of the business or manufacture/supply of goods;

Industry sector – we recognise that certain sectors suffer greater exposure to slavery and human trafficking practices;

Value of the contract / commercial arrangement;

Supplier’s dependency upon our business;

The supplier’s own commitment to ethical practices, e.g. commitment to equal opportunities and diversity in the workplace, anti-slavery practices, compliance with the national minimum wage and national living wage, anti-bribery practices etc.

In the event that any supplier / commercial arrangement is considered to be a potential risk, we will undertake further due diligence until we are satisfied that we have achieved compliance with the law and ethical practices.

For all new supplier or business partners, we will not engage their services unless they share our values demonstrated in this Statement. Should any supplier fail to meet these standards, we will offer to help them identify the steps they will need to take to comply.

We are advising suppliers that we are adopting a zero-tolerance approach to modern slavery and human trafficking, and should any supplier or business partner not comply with Portman Healthcare’s approach, or be prepared to sign our Code of Conduct, we will cease to trade with their company until they have provided us with adequate reassurance of compliance.

As at April 2017, we identified that:

  • 100% of our direct suppliers were located within the UK or other low risk countries;
  • 2.9% are companies in high-risk sectors such as hospitality and leisure, service, retail, construction, and food and beverage industries;
  • 0.5% are greater than £100k of spend in the last 12 months;
  • 0% are greater than £20k of spend in the last 12 months and are an overseas supplier.

General due diligence processes to combat slavery and human trafficking

We have also put in place systems, procedures and best practices to help combat anti-ethical practices and modern slavery within our supply chains and general business operations. For example, we:

  • continually monitor potential risk areas in our supply chains;
  • protect whistle blowers to ensure that they are not discouraged from raising any concerns relating to unethical or illegal practices;
  • ensure supplier adherence to our values and ethics;
  • adopt robust recruitment processes in line with UK employment laws, including: ‘right to work’ document checks; contracts of employment and checks to ensure everyone employed is 16 and above;
  • collaborate with suppliers to help them understand and work towards their own obligations under the Modern Slavery Act;
  • engage with reputable businesses and individuals with a proven track record of legal compliance and good ethical standards;
  • have robust policies in place to ensure the new joiner has the Right to Work in the UK, and have confirmed their identity prior to the commencement of their placement;
  • adopt a supply chain compliance programme, which consists of reviewing each new supplier in line with the principles of this statement;
  • train our colleagues and business partners on their obligations under the applicable laws and regulations. Completion of our anti-slavery training module will form part of our annual training programme;
  • will develop a procedure to monitor how our suppliers comply with our supplier Code of Conduct;
  • pay and reward our employed colleagues in accordance with market rates, which is reviewed annually and bench-marked;
  • provide our employed colleagues with enhanced benefits and welfare options to support our people’s (and their families) lifestyle choices; and
  • promote and encourage transparency within our supply chains.

We also have a dedicated compliance team which is responsible for ensuring that we comply with the principles and commitments set out in this statement. Our compliance team consists of a Compliance Manager and a number of Compliance Facilitators, and are supported by our Head of People, Purchase Ledger Team, and external professional advisors to ensure we act in accordance with the law.

Our effectiveness in combating slavery and human trafficking within our organisation and supply chain is measured by reference to the number reports received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 30 September 2017.
This statement was approved by our Board of Directors on 8 June 2017.