YOUR PERSONAL INFORMATION - GENERAL DATA PROTECTION REGULATION (GDPR)
The GDPR brings new legal protection for personal information from May 2018. This tells you what personal information I hold and why, and what your rights are. Once you have read it please complete and sign the declaration at the bottom.
Who I am and how to contact me:
38 Mayfield Road, Bury St Edmunds, IP33 2QT
Data Controller Contact Details:
The Purpose of processing Client Data
In order to give professional treatments, I will need to gather and retain potentially sensitive information about your health. I will only use this information for informing the treatments I offer, and 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
As a member of the Association of Reflexologists (AoR), a member of the Federation of Holistic Therapists (FHT), I abide by Code of Practice and Ethics for these organisations. 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 and FHT Confidentiality as defined in their Code of Practice and Ethics.
What information I hold and what I do with it
In order to give professional treatments, I will need to ask for and keep information about your health. I will only use this for informing the treatments I offer, 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 (which I will take from you at first consultation)
Treatment details and related notes (which I will take after each consultation)
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:
a) claims occurring insurance: for which I am required to keep my records for 7 years after the last treatment
b) law regarding children’s records: for which I am required to keep my records until the child is 25, or if 17 when treated then until they are 26.
c) registration with The Complementary and Natural Health Care Council: for which I am required to retain information for 8 years after the last treatment.
I 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 business operations, these are:
Email: I use Gmail by Google, which is based outside of the UK. They have committed to complying with all applicable privacy laws, and details of their commitment can be found here: https://policies.google.com/privacy.
Website: My website is provided through WebHealer. They do not hold any personal data on my behalf, and while any emails received via my website are done so via the WebHealer mail system for privacy reasons they are not accessible to staff at WebHealer and are not stored on any of their systems.
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 your first contact with me, and during our first consultation, in relation to:
Reflexology information or information related to your health
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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.
A hard copy of this privacy statement will be provided at our first consultation, where you will be asked to sign this final declaration: I have seen this document and understand that you will hold and use my personal information, using it in order to provide me with the best possible treatment options and advice in line with the statements above. I have received a copy of this document.
Note: for children under 16 a parental or guardian signature is required.