Privacy Policy
Last updated 22 October 2026
This policy explains what personal information the practice holds about you, why, how long it keeps it, and what you can do about it. It applies to everyone who contacts the practice and everyone who becomes a patient, including children.
Who we are
The data controller is Ben Ingram Limited (company number 09392382), trading as Dr Ben Ingram Private General Practice and registered with the Care Quality Commission as Ravn Health. It is registered with the Information Commissioner's Office under number ZB747907. Dr Ben Ingram provides your care personally, and where this policy says "I" or "me", it means him acting for the company.
Write to 10 Carnation Crescent, Sittingbourne, Kent, ME10 4RY, email contact@drbeningram.com, or call 07808 792882.
What information I collect
If you send an enquiry, I collect your name, email address, phone number and whatever you choose to tell me. The website form is processed by Netlify, which hosts the site. Please don't send medical details before we've spoken.
If you become a patient, I keep a clinical record: your medical and family history, examination findings, test results, letters to and from other clinicians, prescriptions, photographs you've agreed to, and a note of every consultation. I also record your NHS GP, your next of kin, who you're happy for me to speak to, and how you'd like to be contacted. For a child, I record who has parental responsibility.
If you pay the practice, Stripe processes your card through Semble. I never see or store your card details.
Why I'm allowed to hold it
Under UK GDPR I rely on these lawful bases:
- Your enquiry: my legitimate interest in replying to people who contact the practice, and steps you've asked me to take before we agree anything.
- Your care: the contract between us. Where someone else holds the contract, such as a parent for a child, or a company that pays for your care, I rely on my legitimate interest in giving you safe care.
- Your health information: Article 9(2)(h) of UK GDPR and schedule 1, paragraph 2 of the Data Protection Act 2018, which allow a health professional bound by confidentiality to process health data to provide care.
- Records the law requires me to keep, such as tax records: legal obligation. Defending a legal claim: legitimate interests.
- Website analytics and advertising measurement: your consent, given through the banner, and nothing else.
Consent isn't the basis for keeping your record, because I have to keep it to look after you safely. I still ask before I share it, as the next section explains.
Where your record lives
Your clinical record is kept in one place: Semble, my clinical records system, which stores it securely on my behalf. Everything clinical goes there, including anything you send me by message.
Outside Semble I keep only four things, and only under a code rather than your name: the code itself, appointment dates in my calendar, task reminders with no clinical detail, and a coded list I use to check when tests and screening are due for each patient under national guidance.
Phone, WhatsApp, email and video
You can reach me by phone, WhatsApp or email. These are convenient, but they aren't your record, so I copy anything clinical into Semble the same day. WhatsApp messages are end-to-end encrypted, which means Meta, which runs WhatsApp, can't read them, although it does see that a message was sent. My WhatsApp backups are switched off. Before we use WhatsApp or email I'll check you're happy to, and I won't send results or letters that way unless you ask me to.
Video consultations use a secure platform that works under a data processing agreement with me. I don't record calls unless we've agreed it in advance.
AI tools
I never put your record, your results or anything that identifies you into a general AI tool, such as a public chatbot. None of my clinical systems has AI features switched on. If that changes, I'll name the feature here before I use it.
Who I share your clinical information with
Your record leaves the practice only where your care needs it or the law requires it. It's never sold, never used for marketing, and never sent to an advertising or analytics company.
I share it with:
- the laboratory, when I send a sample
- imaging providers, consultants and hospitals, when I refer you
- the pharmacy you choose, when I prescribe
- the covering GP named in your welcome pack, when they look after you while I'm away
- your private medical insurer, only when you ask me to make a claim or referral through them
- my medical defence organisation and legal advisers, if a claim or complaint is made
- your NHS GP, with your consent
Nothing goes to a company, insurer or anyone else who pays for your care unless you ask me to in writing.
Sometimes the law requires or allows me to share without your consent: to protect a child or an adult at risk, to prevent serious harm, to report certain infectious diseases, under a court order, or when the Care Quality Commission inspects the practice and looks at records to check the quality of care. I share only what's needed and record why. I'll tell you when I've done it, unless that would put someone at risk or defeat the purpose.
Every organisation that handles your information for me, such as Semble, the laboratory, the video platform and Stripe, does so under a written data processing agreement.
Who I share website information with
Website information is handled separately. If you allow it, Google receives data about how this website is used: which pages were viewed, roughly where in the country the visit came from, and which advert or search brought you here.
Your clinical record is never part of this. It lives in Semble, the two systems aren't connected, and no analytics or advertising code runs anywhere near your record.
Where your information is held
Your clinical record is held in the United Kingdom or the European Economic Area. Where any processor transfers data outside those areas, the transfer is covered by UK adequacy regulations or by the International Data Transfer Addendum.
Website analytics is different. If you allow it, that data goes to Google in the United States, under the UK extension to the EU-US Data Privacy Framework, which Google is certified to. This covers website usage only, never your clinical record.
How long I keep it
- Adults: ten years after your last contact with the practice, or after death.
- Children: until their 25th birthday, or their 26th if they were 17 at the last contact, or ten years after death.
- Enquiries that don't lead to care: deleted after twelve months.
- Financial records: six years, as tax law requires.
When you leave, I send a copy of your record to the doctor you choose within 28 days of being asked, and keep my own copy for the periods above. If the practice closes, your record is transferred or kept safely for the same periods.
Your rights
You can ask for a copy of the information I hold about you, in any way you like, not only in writing. I'll provide it within one month and free of charge in almost every case. For a complex request I can take two more months, and I'll tell you why within the first month.
You can ask me to correct anything factually wrong, although I can't remove a clinical opinion that was properly recorded at the time. You can object to processing, ask for it to be restricted, or withdraw consent where consent is what I relied on.
Your right to have your record deleted is limited, because I have to keep it for the periods above.
A young person who understands what's involved can make these requests for themselves. A parent can make them for a younger child.
Cookies and how the site is measured
Nothing is stored on your device until you choose it. When you first arrive you get a banner with two separate choices, both switched off, and no Google tag loads until you turn one on. If you ignore the banner or close it, nothing is stored and nothing is measured. You can change your mind at any time from the Cookie choices link at the foot of every page.
One thing is stored whatever you choose. Your answer is kept in your browser's local storage under bi-consent-v2, so the banner doesn't ask again on every page. It holds your two answers and a version number, and nothing else. The version number means an answer given under an older banner is never read as agreement to something you weren't asked about.
If you allow measurement of how the site is used, Google Analytics sets two cookies. _ga tells one browser from another and lasts two years. _ga_G-91WEFZTTXG holds the state of your visit and lasts two years.
If you allow measurement of which adverts brought people here, Google sets _gcl_au, which links an advert click to what happened next and lasts 90 days.
Those three are the only cookies I ask you for, and the only ones that record how you use the site. Netlify, which hosts the site, may set one of its own to keep the site working, such as holding you on one version of a page while I test a change. That kind of cookie carries no advertising data and doesn't follow you to other websites. Nothing here builds a profile of you, and none of it is sold. If you find something on this site that isn't on this list, tell me and I'll explain it or take it out.
Changing your mind
The Cookie choices link at the foot of every page reopens the banner with your current answers, and you can change either one.
Turning something off stops collection from that point. It doesn't erase what was already collected, none of which carries your name. The cookies expire on the timings above, and Google deletes the records behind them when the retention period on the account runs out. If you want something gone sooner, write to me and I'll tell you what it takes.
If you're unhappy
Tell me first and I'll try to put it right. If you're still unhappy with how I've handled your information, you can complain to the Information Commissioner's Office at ico.org.uk or on 0303 123 1113. You don't have to contact me first.