How to Transfer Your Dental Records and Scans Between Private Clinics Under UK Data Protection Laws

Introduction

Changing dental practices is more common than many people realise. Whether you are relocating within London, seeking a second opinion, or continuing an ongoing treatment such as orthodontics or implant therapy, one of the first practical questions tends to be: how do I get my dental records and scans transferred to my new clinic?

Many patients are unsure of their rights in this situation, particularly when it comes to private dental care. Some worry about whether their previous clinic is obliged to release their records, whether there will be a charge, and how long the process might take. Others may be mid-way through a treatment plan — such as clear aligner therapy — and need their digital scans and clinical notes to avoid unnecessary delays or repeated assessments.

The good news is that under UK data protection laws, you have clear, enforceable rights to access and transfer your dental records. This article explains how to transfer dental records between private clinics, what the law says, what to expect from your request, and how to ensure treatment continuity during the process.

How to Transfer Dental Records Between Private Clinics in the UK

Yes. Under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, you have a legal right to access your dental records and request their transfer between private clinics. Your previous clinic must respond to a Subject Access Request within one calendar month and cannot unreasonably withhold your clinical notes or diagnostic images.

Your Legal Rights to Dental Records Under UK GDPR

Under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, your dental records are classified as special category personal data — specifically, health data — and are therefore subject to the highest level of legal protection.

As a patient, you have the right to:

• Access your records free of charge via a Subject Access Request (SAR)
• Receive a copy of your records within one calendar month of making the request
• Request data portability in a commonly used, machine-readable format where the data was originally processed by automated means (for example, digital scans stored electronically)
• Have inaccuracies corrected if your records contain errors

These rights apply equally to private dental clinics, which are classed as data controllers under the law. A private clinic cannot charge you for a standard Subject Access Request unless the request is deemed "manifestly unfounded or excessive."

It is worth noting that whilst the law governs your access to records, the General Dental Council (GDC) also sets professional standards requiring dental practitioners to maintain accurate records and treat patients with respect — which includes cooperating with reasonable record transfer requests.

What Dental Records and Scans Can You Request?

When making a request to transfer your records between private clinics, it is helpful to understand exactly what your dental records may include. Comprehensive dental records typically contain:

• Clinical notes from each appointment, including examination findings, diagnoses discussed, and treatments carried out
• Treatment plans with planned procedures and timescales
• Radiographs (X-rays), both traditional periapical images and panoramic (OPG) scans
• CBCT (Cone Beam CT) scans, commonly used in implant planning and orthodontic assessments
• Intraoral digital scans, including STL files used in clear aligner and orthodontic treatment
• Photographs, including intraoral and facial records
• Medical history forms and consent records
• Correspondence, including referral letters

When transferring mid-treatment — such as during clear aligner therapy — digital scan files (STL format) and progress records are particularly important. Your new treating clinician will need these to assess where treatment currently stands and how best to proceed. If you are exploring aligner treatment and want to understand what a full clinical assessment involves, you can learn more about aligner treatment at Pro Aligners.

How to Make a Subject Access Request to Your Dental Clinic

Making a Subject Access Request (SAR) is the formal mechanism by which you can request your dental records. Here is a step-by-step guide to the process:

Step 1 – Submit Your Request in Writing

Whilst the law does not require you to submit your SAR in writing, doing so creates a clear record. You can send an email or letter to your dental clinic addressed to the Data Protection Officer (DPO) or practice manager. Clearly state:

• Your full name and date of birth
• Your patient number (if known)
• The specific records you are requesting (e.g., all clinical notes, radiographs, STL scan files)
• Your preferred format for receiving the records (e.g., digital files via secure email or USB)

Step 2 – Verify Your Identity

The clinic will need to verify your identity before releasing records. This is a standard data protection requirement. Acceptable identification typically includes a copy of your passport or driving licence.

Step 3 – Wait for the Response

By law, the clinic must respond within one calendar month. In complex cases, this may be extended by a further two months, but the clinic must notify you of this extension within the first month and provide a reason.

Step 4 – Receive and Review Your Records

Once received, review your records carefully. If anything appears incomplete or inaccurate, you may raise this with the practice directly or contact the Information Commissioner's Office (ICO) if you believe your rights have not been upheld.

Understanding the Difference Between Access and Data Portability

It is worth clarifying two separate rights that often cause confusion:

Right of Access (SAR): This allows you to receive a copy of your personal health data held by a clinic. The clinic can provide this in whatever format is practical — for example, printed clinical notes or scanned PDFs of X-rays.

Right to Data Portability: This is a more specific right under UK GDPR Article 20 that allows you to receive your data in a structured, commonly used, machine-readable format and, where technically feasible, have it transmitted directly to another controller (in this case, your new clinic). However, this right only applies where:

• The processing was based on consent or contract, and
• The processing was carried out by automated means

For digital dental scans — such as STL files or CBCT data stored electronically — data portability may well apply. For handwritten clinical notes that have been digitised, standard access rights would typically be the relevant route.

If you are unsure which right applies to your specific situation, the Information Commissioner's Office (ICO) provides clear public guidance on its official website.

Can a Private Clinic Charge You for Transferring Records?

Under UK GDPR, responding to a standard Subject Access Request must be provided free of charge. However, there are some limited circumstances where a fee may be applicable:

• If requests are manifestly unfounded or excessive, the clinic may charge a reasonable fee reflecting administrative costs, or refuse the request (with justification)
• Some clinics may charge for the physical reproduction of records in specific formats — for example, burning a CBCT scan to a disc — though this should be communicated transparently

If a clinic refuses your request or charges what you believe to be an unreasonable fee without adequate explanation, you have the right to raise a complaint with the ICO and, separately, the GDC if the refusal relates to professional conduct.

The Clinical Science Behind Why Transferring Records Matters

From a clinical perspective, your dental records are not simply administrative documents — they are an essential part of safe, continuous care.

Radiographs and CBCT scans allow clinicians to assess bone density, root morphology, the presence of any lesions or pathology, and the proximity of anatomical structures such as nerves. Without access to previous imaging, a new clinician may need to take additional radiographs, which involves a small but non-zero radiation dose. Access to existing images reduces this need where clinically appropriate.

Digital intraoral scans (STL files) are especially important in orthodontic and aligner treatment. These three-dimensional models of your dentition form the basis of treatment planning software. If you are mid-way through an aligner course, your new clinician needs these files to assess tooth movements achieved to date and to plan any remaining treatment — without necessarily repeating the full scanning process.

Clinical notes provide your new dentist with a history of treatment decisions, materials used, responses to treatment, and any complications encountered. This context enables safer, more personalised care and avoids duplication of investigations.

If you would like to understand more about why scan quality matters for planning and continuity, this explainer on 3D intraoral scanners vs putty moulds provides a helpful overview.

When You Might Need Professional Dental Assessment After a Record Transfer

Transferring records from one clinic to another does not automatically substitute for a new clinical examination. There are several situations where a comprehensive assessment at your new clinic would be clinically appropriate:

• Mid-treatment transfers: If you are in the middle of aligner therapy, implant treatment, or restorative work, your new clinician will typically want to carry out their own clinical assessment to confirm progress and suitability before continuing
• Time-lapsed records: If your records are more than 12–18 months old, clinical changes may have occurred that would not be captured in historical records alone
• Complex treatment histories: Where multiple treatments have taken place over several years, a thorough clinical review helps ensure the new clinician has a complete and accurate picture
• Symptoms or concerns: If you are experiencing any dental discomfort, sensitivity, or changes in your oral health during a transition between clinics, these symptoms should be assessed clinically — records alone cannot substitute for examination

Patients who are changing provider while still in active orthodontic care may also want to read what happens to your aligner treatment plan if your clinician leaves, as many of the continuity principles overlap.

Dental symptoms and treatment options should always be assessed individually during a clinical examination.

Oral Health Tips During a Clinic Transition

Changing dental clinics need not result in a gap in your oral health routine. Here are some practical steps to protect your dental health during the transition:

• Maintain your home care routine — twice-daily brushing with fluoride toothpaste and daily interdental cleaning remain the most important things you can do for your dental health
• Do not delay seeking care for acute concerns — if you develop toothache, swelling, or sensitivity during the transition, seek care promptly from your new clinic or, if necessary, an emergency dental service
• Keep a personal copy of your records — once you receive your records, keep a digital copy for your own reference; this can be helpful if further transfers are ever needed
• Communicate openly with both clinics — being transparent about your treatment history, ongoing concerns, and the nature of your transfer helps both your outgoing and incoming clinicians provide appropriate care
• Register with your new clinic promptly — avoid gaps in your care by registering with your new clinic as soon as possible and booking an initial consultation

To find out more about what an initial assessment involves, you can book a consultation with Pro Aligners.

Key Points to Remember

• Under UK GDPR and the Data Protection Act 2018, you have a legal right to access and request transfer of your dental records from any private clinic
• Your request must be responded to within one calendar month and should ordinarily be provided free of charge
• Dental records include clinical notes, radiographs, CBCT scans, intraoral digital scans (STL files), photographs, and treatment plans
• Submitting a written Subject Access Request to the clinic's Data Protection Officer is the clearest and most straightforward approach
• Transferring records does not replace a new clinical assessment — your new clinician will typically want to review your dental health directly before continuing or amending any treatment plan
• If a clinic unreasonably refuses your request, you can escalate to the Information Commissioner's Office (ICO) or, where relevant, the General Dental Council (GDC)

Frequently Asked Questions

How long does a dental clinic have to respond to a record transfer request in the UK?

Under UK GDPR, a private dental clinic must respond to a Subject Access Request within one calendar month of receiving the request and verifying your identity. In cases of complexity or high volume of requests, this may be extended by up to a further two months, but the clinic must inform you within the first month and provide a clear reason for the delay. If the clinic fails to respond within the required timeframe, you can raise a complaint with the Information Commissioner's Office (ICO).

Can my previous dental clinic refuse to give me my records?

In most circumstances, no. Under UK GDPR, you have a legal right to receive your personal health data. A clinic may refuse a request only if it is deemed "manifestly unfounded or excessive," and even then must provide justification. If you believe a refusal is unjustified, you can complain to the ICO and, where professional conduct is concerned, the General Dental Council (GDC). It is relatively rare for legitimate requests to be refused outright.

Will I need to pay to have my dental records transferred?

Standard Subject Access Requests under UK GDPR should be provided free of charge. However, a clinic may charge a reasonable fee if it can demonstrate that the request is manifestly unfounded or excessive, or if you are requesting records in a specific physical format (such as a CBCT scan on disc) that incurs genuine reproduction costs. Any fee should be communicated clearly and transparently. If you are unsure whether a charge is appropriate, the ICO provides guidance on this.

What happens to my aligner treatment if I change clinics mid-course?

If you are mid-way through clear aligner therapy and change clinics, your new treating clinician will typically need to review your digital scan files (STL), treatment plan, and clinical notes to assess progress to date. Depending on how far into treatment you are, they may be able to continue directly or may wish to carry out a new clinical assessment and potentially revised scans before proceeding. The specifics depend on the aligner system used and the clinical judgement of your new clinician. Suitability for continuing any treatment plan is always subject to individual assessment.

Are dental X-rays and CBCT scans included in a Subject Access Request?

Yes. Radiographs, panoramic (OPG) X-rays, and CBCT (Cone Beam CT) scans are all part of your dental health record and must be included in a Subject Access Request response. They may be provided as digital files (for example, DICOM format for CBCT data) or via other appropriate means. If you specifically need these images for continuity of treatment, it is helpful to clearly state this in your request and indicate your preferred format.

What should I do if my new clinic says it cannot open the digital scan files provided?

Compatibility issues between different dental software platforms can occasionally arise, particularly with proprietary scan formats. If your new clinic cannot open the files provided, ask your previous clinic whether an alternative or more universally compatible format (such as STL) is available. It may also be worth checking whether your aligner manufacturer holds its own records of your digital models, as some providers retain files directly. Your new clinician can advise on the most practical solution for your specific situation.

Conclusion

Understanding how to transfer your dental records and scans between private clinics is an important aspect of taking control of your own dental healthcare journey. Whether you are relocating, seeking a second opinion, or continuing an ongoing treatment plan, UK data protection law is firmly on your side. You have a clear legal right to access your health records — including clinical notes, radiographs, digital scans, and treatment plans — and to have them transferred within a reasonable and legally defined timeframe.

The process is generally straightforward: submit a written Subject Access Request to your previous clinic, verify your identity, and await the records within one calendar month. If you encounter difficulties, the ICO provides a clear route for escalation.

Importantly, receiving your records is the beginning of the process, not the end. Your new clinician will typically want to conduct their own assessment to ensure your care is tailored to your current dental health and individual circumstances. Dental symptoms and treatment options should always be assessed individually during a clinical examination.

If you have any questions about your ongoing dental treatment in London or would like to discuss how to continue your care with our team, you can contact Pro Aligners directly.

This article is general information only and should not be taken as legal advice.

Disclaimer: This article is intended for general educational purposes only and does not constitute personalised dental advice. Individual diagnosis and treatment recommendations require a clinical examination by a qualified dental professional.