GDPR is bringing in new legal protection for personal information from May 2018. This tells you what personal information I gather via my website and once you become a client of mine, and why. It also explains what your rights are.
My Name: Sue Haynes
My Contact Details:
Phone: 07884 432214
Address: Regent Park, 150 Nursery Lane, Leeds, LS8 1PN
Data Controller Contact Details: As above
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 to inform your treatments and associated recommendations concerning aspects of your health and well-being which I will offer to you. I also take basic contact details and information via my web contact form to allow me to contact you and handle bookings.
Lawful Basis for holding and using Client Information
As a full member of the Association of Reflexologists, I abide by the AoR Code of Practice and Ethics for reflexology. The lawful basis under which I use your information is my legitimate interests, i.e. my requirement to obtain your information in order to provide you with the best possible treatment options and advice.
The lawful basis under which I hold your information is for ‘claims occurring’ insurance, the law regarding children’s records and my obligations as a CNHC registrant for reflexology.
As I hold special category data (i.e. health related information) for reflexology treatments, 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 AoR Confidentiality Rules 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 treatments, I need to ask for and keep information about your health. I will only use this for informing treatments and any advice I give as a result of your treatment. The information I hold is:
- Your contact details (all therapies)
- Medical history and other health-related information (reflexology only)
- Treatment details and related notes (reflexology only)
I will NOT share your information with anyone else, unless required for legal process, without explaining why it is necessary, and getting your explicit consent.
I will keep your information for 8 years (CNHC requirement) or until you are 26 if you are a child (the law regarding children’s records).
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.
I will contact you only using the contact preferences you have given me and will never contact you for marketing purposes.
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 email me at the address above. If you are dissatisfied with my response you can complain to the Information Commissioner’s Office; their contact details are at: www.ico.org.uk
My rights (as your therapist)
- If you don’t agree to me keeping records of information about you and your treatments, or if you don’t allow me to use the information in the way I need to for treatments, I may not be able to treat you
- I have to keep your records of treatment for a certain period as described above, which may mean that even if you ask me to erase any details about you, I might have to keep these details for reasons already outlined
- I can move my client records between my computer and IT systems, as long as your details are protected from being seen by others without your permission