Lower Limb Clinic

    Privacy Policy

    Last updated: February 2026

    1. Introduction

    Lower Limb Clinic ("we", "our", "us") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, store, and share your personal data when you use our website (www.lower-limb.com), attend our clinics, or interact with our services.

    We comply fully with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and the Privacy and Electronic Communications Regulations 2003 (PECR). This policy should be read alongside our Terms & Conditions.

    2. Data Controller

    The data controller responsible for your personal data is:
    Lower Limb Limited
    Company Number: NI636450
    Registered Address: 385 Lisburn Rd, Belfast BT9 7EP
    Email: hello@lower-limb.com
    Phone: 028 9013 9185

    For all data protection enquiries, please contact us at hello@lower-limb.com marked "FAO Data Protection".

    3. What Data We Collect

    We may collect and process the following categories of personal data:

    3.1 Identity & Contact Data

    • Full name, date of birth, gender
    • Address, email address, telephone number
    • Emergency contact details
    • Next of kin details (where clinically relevant)

    3.2 Health & Clinical Data (Special Category Data)

    This is "special category data" under Article 9 of UK GDPR and receives enhanced protections. It includes:

    • Medical history, current medications, and allergies
    • Clinical assessment notes, diagnoses, and treatment plans
    • Biomechanical and gait analysis data
    • Diagnostic imaging (ultrasound scans, clinical photographs)
    • 3D foot scan data used for orthotic manufacturing
    • AI-assisted clinical notes (see Section 8)
    • Referral correspondence with other healthcare providers

    3.3 Financial & Transaction Data

    • Payment card details (processed securely via our PCI DSS-compliant payment provider — we do not store card numbers)
    • Invoices, receipts, and transaction history
    • Gift voucher purchase and redemption records
    • Insurance claim information

    3.4 Technical & Usage Data

    • IP address, browser type and version, operating system
    • Pages visited, time spent on site, referral source
    • Cookie and analytics data (see Section 12)

    4. How We Use Your Data

    We process your personal data only where we have a lawful basis to do so. The table below sets out the purposes for which we process your data and the corresponding lawful basis under UK GDPR:

    PurposeLawful Basis (UK GDPR)
    Providing clinical treatment and careArt. 6(1)(b) — Contract; Art. 9(2)(h) — Health purposes
    Managing appointments and bookingsArt. 6(1)(b) — Contract
    AI-assisted clinical note-takingArt. 6(1)(f) — Legitimate interests; Art. 9(2)(h) — Health purposes
    Processing payments and invoicingArt. 6(1)(b) — Contract
    Sending appointment remindersArt. 6(1)(f) — Legitimate interests
    Complying with legal and regulatory obligations (HCPC, HMRC)Art. 6(1)(c) — Legal obligation
    Safeguarding and child protectionArt. 6(1)(d) — Vital interests; Art. 9(2)(c) — Vital interests
    Improving our website and servicesArt. 6(1)(f) — Legitimate interests
    Managing insurance claims on your behalfArt. 6(1)(b) — Contract; Art. 9(2)(h) — Health purposes
    Marketing (only with your explicit consent)Art. 6(1)(a) — Consent

    Where we rely on legitimate interests, we have carried out a Legitimate Interest Assessment (LIA) to ensure that your interests, rights, and freedoms do not override our legitimate interests. You may request details of our LIA by contacting us.

    5. Special Category Data — Additional Safeguards

    Health and clinical data is classified as "special category data" under UK GDPR and receives additional protections. We process this data under Article 9(2)(h) — processing necessary for the purposes of preventive or occupational medicine, medical diagnosis, the provision of health or social care, or the management of health or social care systems and services. This is further supported by Schedule 1, Part 1, Paragraph 2(2)(f) of the Data Protection Act 2018, which permits processing for the management of health care systems or services.

    All clinicians who access special category data are subject to a duty of confidentiality under HCPC professional standards and the common law duty of confidence.

    6. Third-Party Data Processors

    We use carefully selected third-party services to help us deliver our services. Each processor is bound by a written data processing agreement in accordance with Article 28 of UK GDPR and operates in compliance with applicable data protection law:

    6.1 Cliniko (Practice Management System)

    We use Cliniko to manage patient records, appointments, and clinical notes. Cliniko stores all data on secure, encrypted servers and acts as a data processor on our behalf. Cliniko's servers are located in Australia; appropriate safeguards (including Standard Contractual Clauses and the UK International Data Transfer Agreement) are in place. For more information, see Cliniko's Privacy Policy.

    6.2 Gift Up (Gift Voucher Platform)

    We use Gift Up to manage the sale and redemption of gift vouchers. When you purchase a gift voucher, your name, email address, and payment details are processed by Gift Up on our behalf. Payments are processed securely via Stripe. For more information, see Gift Up's Privacy Policy.

    6.3 Realta Labs (Orthotic Manufacturing)

    Our sister company Realta Labs receives 3D foot scan data and prescription information for the purpose of manufacturing custom orthotic devices. Realta Labs processes this data solely for the fulfilment of your orthotic prescription and is bound by a data processing agreement.

    6.4 Other Processors

    We may also use processors for email communications, website hosting, analytics, and payment processing. All processors are vetted for UK GDPR compliance and are bound by appropriate data processing agreements. A full list of sub-processors is available on request.

    7. Data Storage & Security

    We implement appropriate technical and organisational measures to protect your personal data in accordance with Article 32 of UK GDPR, including:

    • Encrypted storage of all clinical records within Cliniko (AES-256 encryption at rest)
    • Secure access controls — only authorised clinicians can access your health data, with role-based permissions
    • Regular security audits and staff training on data protection
    • Secure disposal of physical records in accordance with NHS and HCPC guidelines
    • SSL/TLS encryption on all website communications
    • Multi-factor authentication for clinical system access
    • Regular review of access logs and security incidents

    8. Use of Artificial Intelligence (AI)

    We use AI-assisted technology during clinical assessments to support accurate and efficient note-keeping. It is important to understand:

    • AI is used as a clinical support tool only — all clinical decisions are made by our qualified, HCPC-registered podiatrists
    • AI may transcribe and summarise assessment conversations to create clinical notes
    • All AI-generated notes are reviewed, verified, and approved by the treating clinician before being added to your record
    • AI-processed data is subject to the same strict confidentiality, security, and retention policies as all other clinical data
    • No AI-generated data is shared with third parties for marketing, training, or any purpose unrelated to your care
    • You have the right to request that AI is not used during your appointment — please inform your clinician at the start of your consultation. Opting out will not affect the quality of your care

    9. Automated Decision-Making & Profiling

    We do not use your personal data for automated decision-making or profiling that produces legal effects or similarly significant effects on you, as defined under Article 22 of UK GDPR. All clinical decisions are made by qualified human clinicians. AI tools (as described in Section 8) assist with administrative tasks only and do not make or influence clinical decisions.

    10. Confidentiality

    All personal and health information you share with us is treated as strictly confidential. We adhere to:

    • The Health and Care Professions Council (HCPC) Standards of Conduct, Performance and Ethics
    • The Royal College of Podiatry guidance on clinical record-keeping and best practice
    • The Caldicott Principles for handling patient-identifiable information
    • The NHS Code of Practice on Confidentiality
    • The common law duty of confidence

    We will never share your personal or health data with third parties for marketing purposes. Information may only be disclosed:

    • With your explicit and informed consent
    • Where required by law or court order
    • For safeguarding purposes (child protection, prevention of serious harm)
    • Where disclosure is required by a regulatory body (e.g., HCPC, ICO)
    • To other healthcare professionals involved in your direct care (with your knowledge)

    11. Data Retention

    We retain your data for the following periods, in line with professional, legal, and regulatory requirements:

    • Adult clinical records: 8 years after the last appointment, or longer if clinically relevant (in accordance with Royal College of Podiatry record retention guidance)
    • Children's clinical records: Until the patient's 25th birthday, or 8 years after the last appointment — whichever is longer
    • Nail surgery and invasive procedure records: 15 years (in line with NHS Litigation Authority guidance)
    • Financial records: 7 years (as required by HMRC)
    • Gift voucher records: 2 years after expiry or redemption
    • Website analytics: 26 months
    • Marketing consent records: Duration of consent plus 1 year

    When retention periods expire, data is securely deleted or anonymised. Clinical records are disposed of in accordance with NHS confidential waste procedures.

    12. Cookies & Electronic Communications (PECR)

    Our website uses cookies in accordance with the Privacy and Electronic Communications Regulations 2003 (PECR). We use:

    • Strictly necessary cookies — required for the website to function. These do not require consent under PECR
    • Analytics cookies — to understand how visitors use our site (e.g., Google Analytics). These are placed only with your consent
    • Third-party cookies — set by services such as Cliniko (online booking) and Gift Up (gift vouchers). These are subject to the third party's own cookie policies

    You can manage cookie preferences through your browser settings or through the cookie consent mechanism on our website. Disabling certain cookies may affect website functionality. For more details on the specific cookies we use, please contact us.

    We will only send you marketing emails with your prior explicit consent, in accordance with PECR. You can withdraw consent at any time by clicking "unsubscribe" in any marketing email or by contacting us directly.

    13. International Data Transfers

    Some of our third-party processors may store or process data outside the UK. Where this occurs, we ensure appropriate safeguards are in place in accordance with Chapter V of UK GDPR, including:

    • UK adequacy regulations — transfers to countries recognised as providing adequate data protection
    • Standard Contractual Clauses (SCCs) — as approved by the UK Secretary of State
    • UK International Data Transfer Agreement (IDTA) — where applicable

    Details of the specific safeguards in place for each international transfer are available on request.

    14. Children's Data

    We treat children under 16 with our Children's Foot Assessment service. In relation to children's data:

    • Consent for processing is obtained from the parent or person with parental responsibility
    • Clinical records for children are retained until the patient's 25th birthday or 8 years after last appointment (whichever is longer)
    • We apply enhanced safeguards to children's data in accordance with the ICO's Children's Code (Age Appropriate Design Code) where applicable to our online services
    • We do not knowingly collect personal data from children through our website without parental consent

    15. Data Breach Procedures

    In the event of a personal data breach, we will:

    • Assess the breach in accordance with our internal data breach response procedure
    • Where required under Article 33 of UK GDPR, report the breach to the ICO within 72 hours of becoming aware of it
    • Where the breach is likely to result in a high risk to your rights and freedoms, notify you directly in accordance with Article 34 of UK GDPR, without undue delay
    • Document all breaches, including those not reported to the ICO, in our internal breach register

    16. Your Rights

    Under UK GDPR, you have the following rights:

    • Right of access (Art. 15) — request a copy of your personal data (Subject Access Request)
    • Right to rectification (Art. 16) — request correction of inaccurate or incomplete data
    • Right to erasure (Art. 17) — request deletion of your data (subject to legal and professional retention requirements)
    • Right to restrict processing (Art. 18) — request limitation of how we use your data
    • Right to data portability (Art. 20) — receive your data in a structured, commonly used, machine-readable format
    • Right to object (Art. 21) — object to processing based on legitimate interests or direct marketing
    • Right to withdraw consent (Art. 7) — where processing is based on consent, without affecting the lawfulness of processing before withdrawal
    • Rights related to automated decision-making (Art. 22) — the right not to be subject to decisions based solely on automated processing (see Section 9)

    To exercise any of these rights, contact us at hello@lower-limb.com marked "FAO Data Protection". We will respond within one calendar month. This period may be extended by up to two further months for complex or numerous requests, in accordance with Article 12(3) of UK GDPR. We will inform you of any extension within one month of receiving your request.

    We may ask you to verify your identity before processing your request. There is no fee for exercising your rights, unless your request is manifestly unfounded or excessive, in which case we may charge a reasonable fee or refuse to act on the request.

    17. Complaints

    If you are unhappy with how we handle your personal data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):

    • Website: ico.org.uk/make-a-complaint
    • Phone: 0303 123 1113
    • Address: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

    We would appreciate the opportunity to address your concerns before you contact the ICO. Please reach out to us at hello@lower-limb.com.

    18. Changes to This Policy

    We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. Any changes will be posted on this page with an updated revision date. Where changes are material, we will take reasonable steps to notify affected individuals. We encourage you to review this policy periodically.