Your personal information and GDPR
The GDPR, effective from 25 May 2018, relates to legal protection for personal information. This document tells you what personal information I hold and why, and what your rights are. This also includes any personal information I gather through my website, outlining why it is gathered and what your rights are. Once you have read this Privacy Statement please complete and sign the declaration at the bottom of this document.
Therapist’s Name/Identity: Jane Singleton Reflexology
Therapist’s Contact Details:
Telephone No: 07787 566034
Email address: firstname.lastname@example.org
Address: 130 Manor Road, Barton Seagrave, Kettering, NN15 6WD
Data Controller Contact Details: Jane Phillips (Founder of Jane Singleton Reflexology)
Data Protection Officer (as above)
The purpose of processing client data
In order to give professional reflexology treatments, I will need to gather and retain potentially sensitive information about your health. I will only use this information for informing reflexology treatments and associated recommendations concerning aspects of health and wellbeing which I will offer to you. If you contact me by email, text, ‘What’s App’, via my website, or any other social media platforms, I will take basic contact details and information to allow me to contact you and handle bookings. I may also take sensitive information about your current or past health and wellbeing in order to fulfil my role as a healthcare practitioner, bound under the Association of Reflexologist’s confidentiality as defined in its Code of Practice and Ethics.
Lawful basis for holding and using client information
As a member of the Association of Reflexologists (AoR), I abide by the AoR Code of Practice and Ethics. The lawful basis under which I hold and use your information is my legitimate interests (i.e. my requirement to retain the information in order to provide you with the best possible treatment options and advice).
As I hold special category data (i.e. health related information), the Additional Condition under which I hold and use this information is: for me to fulfil my role as a health care practitioner bound under the AoR Confidentiality as defined in the AoR Code of Practice and Ethics.
What information I hold and what I do with it
In order to give professional reflexology treatments, I will need to ask for and keep information about your health. I will only use this for informing reflexology treatments and any advice I give as a result of your treatment. The information to be held is:
- Your contact details
- Medical history and other health-related information (some of which you may share with me via your initial contact with me, but the majority of which I will take from you at our first consultation)
- Treatment details and related notes (which I will take after each consultation)
- If you purchase a gift voucher I will collect information about the gift recipients so I can fulfil this purchase
I will NOT share your information with anyone else (other than within my own practice, or as required for legal process) without explaining why it is necessary, and getting your explicit consent.
How long I retain your information for
I will keep your information for the following periods
a) for 7 years after your last treatment (for claims occurring insurance purposes)
b) if treatment related to a child, until the child is 25 or if 17 when treated, then 26 (legal requirement)
I personally will not transfer your data outside the EU without your consent, although you need to be aware that I do use third party services as part of my operations. These are:
Email & Website – My email and website hosting is provided by Heart Internet, arranged via my website designer, Red2design. Both are UK based companies & have their own Privacy Statements on their website which can be found at https://www.heartinternet.uk/terms/heart-internet-privacy-statement & https://www.red2design.co.uk/about-us/privacy-statement/. These organisations do not hold any personal data on my behalf.
Paypal & Internet banking – if you choose to make payments via these methods, please refer to Paypal’s and your own bank’s privacy policies before making these payments.
Facebook, Instagram – If you choose to contact me through Social Media, or interact with me via my Facebook Group/s, you should refer to Facebook and Instagram’s Privacy Policies before doing so.
Please be aware that the internet is not a secure environment and assurance cannot be guaranteed with regard to the security of any information beyond the precautions set out within this and the above privacy referenced privacy statements for the third party services I access.
Protecting your personal data
I am committed to ensuring that your personal data is secure. In order to prevent unauthorised access or disclosure, I have put in place appropriate technical, physical and managerial procedures to safeguard and secure the information we collect from you.
I will contact you using the contact preferences you give me in relation to:
- Appointment times/reminders
- Reflexology information or information related to your health
- Special offers, promotions and updates via an e-newsletter (you may unsubscribe from this at any time)
GDPR gives you the following rights:
- The right to be informed: To know how your information will be held and used (this notice).
- The right of access: To see your therapist’s records of your personal information, so you know what is held about you and can verify it.
- The right to rectification: To tell your therapist to make changes to your personal information if it is incorrect or incomplete.
- The right to erasure (also called “the right to be forgotten”): For you to request your therapist to erase any information they hold about you
- The right to restrict processing of personal data:. You have the right to request limits on how your therapist uses your personal information
- The right to data portability: under certain circumstances you can request a copy of personal information held electronically so you can reuse it in other systems.
- The right to object: To be able to tell your therapist you don’t want them to use certain parts of your information, or only to use it for certain purposes.
- Rights in relation to automated decision-making and profiling.
- The right to lodge a complaint with the Information Commissioner’s Office: To be able to complain to the ICO if you feel your details are not correct, if they are not being used in a way that you have given permission for, or if they are being stored when they don’t have to be.
Full details of your rights can be found at https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
If you wish to exercise any of these rights, please use the contact details given above.
If you are dissatisfied with the response you can complain to the Information Commissioner’s Office; their contact details are at: www.ico.org.uk
- If you don’t agree to your therapist keeping records of information about you and your treatments, or if you don’t allow them to use the information in the way they need to for treatments, the therapist may not be able to treat you.
- Your therapist has to keep your records of treatment for a certain period as described above, which may mean that even if you ask them to erase any details about you, they might have to keep these details until after that period has passed.
- Your therapist can move their records between their computers and IT systems, as long as your details are protected from being seen by others without your permission.