OPERAi Privacy Policy



Introduction


As is true of most companies, Referral Management Services Limited needs to collect and use your personal information for various purposes.


Referral Management Services Limited (RMSL) t/a FDS Consultants is a company registered in England and Wales under the registration number 11362661. Our registered address is 61a King Street, Knutsford, Cheshire, England, WA16 6DX. All references to ‘RMSL’, ‘we’, ‘us’, ‘our’ are references to Referral Management Services Ltd t/a FDS Consultants.


We understand that you care about your privacy, and we take that seriously.


This Privacy Notice describes RMSL’s policies and practices regarding its collection and use of your personal data.


Data protection officer

RMSL has appointed an external data protection officer for you to contact if you have any questions or concerns about RMSL’s personal data policies or practices. RMSL’s data protection officer’s name and contact information are as follows:

Gemserv Limited

dpo@referral.solutions


How we collect and use your personal information

We collect your personal information through various channels including, but not limited to, the following:


  • Business cards
  • Face to face meetings when conducting our business
  • Forms you fill in
  • Where we engage with our partners that enable you to register to visit our site, we may receive your personal data relevant to the visit
  • directly from you such as when:
    • you register to use our software
    • let us know how you want to hear from us and what you hear from us about
    • you contact us directly
  • indirectly from you, such as when you interact with our website. When you do this we collect and use technical data automatically about your equipment, browsing actions and patterns. We collect and use this personal data by using cookies and other similar technologies. We also receive technical data about you if you visit other websites employing our cookies (for more details, go to our Cookie policy).

When we are a data processor only

This privacy policy does not apply where we are processing personal information strictly as a  data processor on behalf of a third party as we do not collect personal data directly. In this case, you should look to that third party such as your dental practice, who will be answerable for how we process that personal information and its privacy policy.


The types of data we collect

Personal Data for Online Learning Packages: When you register to undertake online training, we may collect your first name, last name, job title, GDC number, employer name, work address, work email, work phone number and content of communications. In some instances, only when appropriate, we may ask you for other personal data, although this will always be optional, for example, your dietary requirements.


Personal Data for Software Registration: When you register for the referrals service, we will collect your first name, last name, job title, GOC number, employer name, work address, work email, work phone number


Personal Data for Service Communications: When you register for our services we may send you service messages if there is planned or unexpected service outage which affect the services we provide to you. We may collect your first name, last name, job title, employer name, work address, work email and work phone number.


Personal Data for Feedback purposes: When you submit a feedback form/user survey via our website about our services. We will collect first name, last name and email address and may also collect the Practice Name, personal/work telephone number and a Unique Reference Number if your feedback relates to a particular referral.


Personal Data for Patient Experience purposes: When you consent to the registered practice sharing information with us. We may collect your first name, last name and mobile number

For more information, please see the Appendix below.


Why we collect your information

Purposes

As is true of most companies, RMSL needs to collect and use your personal information for various purposes, namely the following:

  • Registration: Personal information we collect to access our training packages
  • Security:Personal information we collect to ensure security is maintained for services being provided to you
  • Legal reasons:Personal information we are required to collect by law
  • Patient Experience: Personal information we collect from practices to gain feedback on the services provided to you as a patient where RMSL has received a referral from a practice but only if you have explicitly consented to receive SMS messages to your provider for this specific purpose.

The legal basis for collecting and using your personal information for the above purposes are legitimate interests, consent and legal obligation.

For more information on RMSL’s legal bases and legitimate interests please refer to the Appendix below or contact us at dpo@referral.solutions


Automated decision making

We do not make any automated decision-making or profiling using your personal information.


How long we keep your personal information

The information we collect will be stored for the duration of your interest in RMSL’s services, for the duration of events, and in some instances longer, if required by regulatory authorities. Please see the Appendix for more information.


Our communications policy

We will always exercise restraint and send you materials that we feel are relevant as a patient or customer.


We may also include forms on our website which enable you to sign up for specific events if you wish to or download content such as insights or information about our services. Any data we collect from these specific forms will only be processed and used for purposes relating to the event or topic that the form relates to. It will not be used as consent to send you any other unrelated content.


Sharing your personal information

The personal information RMSL collects from you is stored in one or more databases hosted by third parties located in the European Economic Area (EEA). These third parties do not use or have access to your personal information for any purpose other than cloud storage and retrieval.


If we do this, we require third parties to respect the security of your personal information and to treat it in accordance with the law. In addition, all of our third-party service providers are required to take appropriate security measures to protect your personal information in line with our data and security policies.


We do not allow our third-party service providers to use your personal information for their own purposes. We only permit them to process your personal information:

  • for specified purposes, and
  • in accordance with our instructions.

We may share your information with other organisations located in the EEA. We may also have to share your personal information with law enforcement authorities or share your personal information with a regulator/commissioner (such as the General Optical Council, Digital Health and Care Wales or the Care Quality Commission).


The list of parties is shown below:

Organisation Data shared Reason for sharing
CRM system provider Name, job title, email, telephone numbers, postal address, This cloud-based database is used to store your personal information in relation to sending you service messages. To send SMS messages to patients who have consented to complete PROMS/PREMS questionnaires.
Web, email, social media platforms Name, job title, email, telephone numbers, postal address, These service providers help us to respond to any of your enquiries
Email, mail and surveys distribution providers First name, last name, job title, company name, work email, postal address These service providers help us to deliver email and mail communications to you.
Commissioners First name, last name, postcode, DOB, pre/post-operative information submitted by you as part of the review of your care To comply with our obligations as an NHS Provider
Regulatory bodies First name, last name, NHS number, postal address, relevant medical information To comply with our legal obligations as an NHS Provider
Professional bodies such as the General Optical Council First name, last name, company name, work email, postal address and relevant patient information (if appropriate) Raising a concern about a medical professional

Your rights

Under the GDPR data subjects have the following rights:

  • The right to be informed of any data processing
  • The right of access to your personal data
  • The right to rectification of your personal data, in some circumstances
  • The right to erasure of your personal data, in some circumstances
  • The right to restrict processing of your personal data, in some circumstances
  • The right to data portability, in some circumstances
  • The right to object to the processing of your personal data, in some circumstances
  • The right to withdraw consent to the processing of your personal data, where applicable.

If you wish to exercise your rights as a data subject where we act as a data controller, please contact us at dpo@referral.solutions


If you wish to exercise your rights as a patient such as wishing to gain a copy of your referral or for copies of your own dental record, please contact the dental practice you were referred from.

Additionally, if you are aged under 13, we may require your parents’ or guardian’s consent for you to exercise any of your rights.


Security of your information

To help protect the privacy and confidentiality of your personal information, we maintain physical, technical and administrative safeguards. We update and test our security technology on an on-going basis. We restrict access to your personal data to those employees who need to know that information to provide benefits or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees’ privacy responsibilities.


Appendix 1 – Further details on your information

The following details the information we may collect (depending on a processing activity), the appropriate legal basis and justification and the retention period for such data.

Information collected Legal basis Justification Retention period
Name Legitimate interest & Consent This data may need be retained in order to identify you. RMSL has a legitimate interest to identify data subjects for the provision of services to partners and patient experience feedback 2 years from the last contact
Company Name Legitimate interest RMSL has a legitimate interest to identify data subjects for the provision of services to partners. 2 years from last contact
Email Address Legitimate interest. & Consent This data may need to be retained in order to identify you and communicate with you. RMSL has a legitimate interest to identify and communicate with data subjects for the provision of services to partners. 2 years from last contact
Phone Number Legitimate interest & Consent This data may need to be retained in order to identify you and communicate with you. RMSL has a legitimate interest to identify and communicate with data subjects for the provision of services to partners. 2 years from last contact
Address Legitimate interest & Consent This data may need to be retained in order to identify you and communicate with you. RMSL has a legitimate interest to identify and communicate with data subjects for the provision of services to partners. 2 years from last contact
Job Title Legitimate interest This data may need to be retained in order to identify you. RMSL has a legitimate interest to identify data subjects for the provision of services to partners. 2 years from last contact
Communication Preferences and /or Interests Legitimate interest & Consent RMSL uses consent and legitimate interest to capture communication preferences for the provision of services to data subjects and partners. 2 years
Content of Communications Legitimate interest RMSL has a legitimate interest to communicate with data subjects for the provision of services to partners. 2 years

(Updated 10/03/2026)

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