Accessing Your Orthodontic Records UK
You have a legal right to request a copy of your orthodontic records — X-rays, photographs, study models and clinical notes — from any UK practice that holds them. This guide explains how a Subject Access Request works, how long a practice has to respond, what it can charge, and how to get records transferred if you switch orthodontist.
Your right of access under UK GDPR
Under UK GDPR, every patient has the right to request a copy of the personal data a practice holds about them, including clinical data. This is known as a Subject Access Request (SAR). For orthodontic patients, this covers your clinical notes, X-rays (OPGs, lateral cephalograms and any CBCT scans), intra-oral and facial photographs, study models or digital scans, treatment plans, correspondence about your care, and billing records. The right applies whether you are still an active patient, have completed treatment, or have not attended the practice for years — as long as the practice still holds the records within its retention period.
How to make a request
A request does not need to use any particular form of words or cite GDPR by name — simply asking a practice, in writing, for a copy of your records is enough to trigger the process. Email or a letter is best practice because it creates a clear, dateable record of when the request was made. Include your full name, date of birth, the practice you attended (if different from the one you are contacting), and roughly when you were treated, since older records may be archived separately from current patient files. If you want a specific subset of records — for example, only your final debond photographs, or just your X-rays — say so, though a practice may still provide the full record set if it is not practical to separate items out.
The one-month response deadline
A practice must respond to a Subject Access Request within one calendar month of receiving it. This can be extended by up to two further months for requests that are complex or where a patient has made a number of requests, but the practice must tell you within the first month if it is applying an extension and explain why. If a deadline passes with no records and no explanation, this is a compliance failure you can escalate — see the section on withheld records below.
What a practice can charge
In most cases, a practice cannot charge a fee for a first Subject Access Request. A reasonable administrative fee can only be charged where a request is manifestly unfounded or excessive — for example, repeated identical requests — or where you ask for further copies of material already provided. In practice, most UK orthodontic providers will supply a first set of records, including digital copies of X-rays and photographs, free of charge. Be wary of any practice quoting a substantial fee simply to release your basic records; you can query this and, if unresolved, raise it with the Information Commissioner's Office.
Retention periods for orthodontic records
UK dental and orthodontic records must be retained for a minimum period after treatment finishes, so that they remain available if there is ever a query about your care. For adult patients, the standard minimum retention period is 11 years from the end of treatment. For patients who were children when treatment started, records must be kept until the patient's 25th birthday, or 11 years from the end of treatment if that is later — reflecting the longer period within which a claim could potentially be brought on behalf of a child. Some practices retain records for longer than the legal minimum as a matter of policy. If you were treated many years ago and the practice no longer exists, records may have been transferred to a successor practice, an NHS body, or a specialist records-storage service — the local Integrated Care Board (ICB) can often help trace where NHS orthodontic records ended up.
Transferring records when you change practice
If you are moving to a new orthodontist mid-treatment, or seeking a second opinion, you are entitled to a copy of your records to take with you — you do not need the sending practice's permission beyond making the request. Ask the new practice what they specifically need, since starting fresh records (a full new set of X-rays, for instance) may not be necessary or in your interest if adequate records already exist and can simply be transferred. Digital records — scans, digital X-rays and photographs — can usually be sent electronically within days. Physical items such as plaster study models or older film X-rays may take longer to locate and post, particularly if they are held in off-site archive storage.
What to do if records are withheld or delayed
If a practice does not respond within the required timeframe, or refuses a request without a lawful reason, first put your concern in writing to the practice, referencing the date of your original request. If this does not resolve the issue, you can complain to the Information Commissioner's Office (ICO), which regulates data protection compliance in the UK and can investigate and require action. For NHS-funded orthodontic treatment, you can also raise the matter through the practice's NHS complaints process or with NHS England. A practice withholding records to gain leverage in an unrelated dispute — for example, an unpaid invoice — is not a lawful reason to refuse a Subject Access Request.
Useful related pages
This guide is for general information only. It is not a diagnosis, treatment plan, or substitute for advice from a registered dentist or orthodontist.
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