YOUR PERSONAL INFORMATION - GENERAL DATA PROTECTION REGULATION (GDPR)
GDPR is bringing in new legal protection for personal information from May 2018. This notice tells you what personal information I gather during therapy sessions and via my website, and why, and what your rights are.
Therapist's contact details:
5 Bank Lane,
Forres IV36 1NU
Grace Pirnie - registered with the ICO (Information Commissioners Office)
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. I take basic contact details and information via my website to allow me to contact you and handle bookings and gift voucher orders.
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. The lawful basis under which I hold and use your information is:
a) My legitimate interests i.e.my requirement to retain the information in order to provide you with the best possible treatment options and advice
b) My requirement to hold your information for the following legal reasons
- ‘claims occurring’ insurance
- law regarding children’s records
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 (which I will take from you at first consultation)
• Treatment details and related notes (which I will take after each consultation)
I keep hand written notes only for client consultations and these are stored securely in a locked filing cabinet within a locked room. I am the only person that has access to them. No sensitive client data is stored electronically.
Contact details for appointments, cancellations, enquiries are processed through my website contact form, email account and iPhone. Gift vouchers are processed through my website shop page.
I will not store contact details from any potential client enquiries who do not proceed to treatment.
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.
As I am treating as the result of a referral, I have to share certain details with:
the organisation that referred you.
The information to be shared would be:
I receive referrals for funding purposes for client sessions, i.e., therapy funded by charitable organisations and health insurance companies - they specifically require the recipient's name on the invoice. This is the only information that is provided for funding purposes. No private consultation information is shared.
How Long I Retain Your Information for
I will keep your information for the following periods:
a. ‘claims occurring’ insurance: (records to be kept for 7 years after last treatment)
b. law regarding children’s records (records to be kept until the child is 25)
Client data will be incinerated after this time period.
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 we collect from you.
I will contact you using the contact preferences you give me in relation to:
• Appointment times
• Reflexology information or information related to your health
• Special offers and promotions (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.