GENERAL DATA PROTECTION REGULATION (GDPR) - your personal information
GDPR is bringing in new legal protection for personal information from 25 May 2018. This Privacy Notice informs you what personal information I gather via my website, and why, and what your rights are.
Data Controller: Mrs Sarah Clark - Complementary Therapist
Telephone number: 01202 775474
Email address: [email protected]
Address: Windsor Road, Christchurch, Dorset, BH23 2EE
The Purpose of processing Client Data
In order to give professional therapies, I will need to gather and retain potentially sensitive information about your health. I will only use this information to ensure therapies are suitable for you and for associated recommendations concerning aspects of health and wellbeing which I will offer to you.
I take basic contact details and information via my website to allow me to contact you and handle bookings.
Lawful Basis for holding and using Client Information
I am a member of the Federation of Holistic Therapists (FHT) and I abide by their Code of Practice and Ethics.
The lawful basis under which I hold and use your information is:-
• legitimate interests, i.e. my requirement to retain the information in order to provide you with the best possible therapy options and advice
• my requirement to hold your information where you have received a therapy for:-
a. Legal reasons in relation to my FHT membership and insurance, for a minimum of 10 years;
b. HMRC tax requirements for the following 6 tax years after payment, i.e. I would retain a record for Gift Voucher purchased or other items purchased such as my crystal jewellery.
What information I hold and what I do with it
In order to give professional therapies, I will need to ask for and keep information about your health. I will only use this for informing therapies and any advice I give as a result of your therapy. The information to be held is:
• Your contact details
• Medical history and other health-related information (which I will take from you at first consultation) and changes to thus information which are recorded before each subsequent therapy given.
• Therapy details and related notes (which I will take after each therapy)
I will NOT share your information with anyone else (other than 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 -
• Where a gift voucher has been purchased a copy of the request/payment for the following 6 tax years.
• Hiscox requirements to retain information for 10 years after last therapy.
* Email, text and telephone messages received will be deleted within 30 days of receipt.
Your data will not be transferred outside the EU without your consent.
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 I collect from you. Paper records will be destroyed securely once the retention period has expired.
I will contact you using the contact preferences you give me in relation to:
• Appointment times
• Special offers and promotions (you may unsubscribe from this at any time by emailing, texting or calling me)
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 my records of your personal information, so you know what is held about you and can verify it.
• The right to rectification:
To tell me 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 me to erase any information I hold about you. (Please see retention periods for holding information which will limit your right to earsure where I am required to hold information for legal reasons.)
• The right to restrict processing of personal data:.
You have the right to request limits on how I use 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. (Please note I do not hold client health records on computer.)
• The right to object:.
To be able to tell me you don’t want me 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 at www.ico.org.uk
• if you don’t agree to me keeping records of information about you and your therapies or if you don’t allow me to use the information in the way I need I will not be able to accept you as a client.
• I am required to keep your records of therapies for a certain period as described above, which may mean that even if you ask me to erase any details about you, it is unlikely this will be possible until after the relevant retention period has passed unless the data to be erased was incorrect or requires amendment.
• The health records I retain are all on paper and not held on a computer. Any email, text or telephone enquiries received will be deleted within 30 days