GDPR has brought in new legal protection for personal information from May 2018. This tells you what personal information I gather via my website, and why, and what your rights are.
Hilary Leach t/as Hilary Leach Natural Therapies I provide many holistic therapies and am also an Ambassador for Tropic Skincare.
Telephone No: 07799 591086
Address: 61, Weoley Castle Road, Weoley Castle, Birmingham. B29 5QD (I also practise from Renaissance Natural Therapy Centre, Clarence Mews, Harborne, Birmingham. B17 9JT)
I am the Controller of the Personal Data you provide, you can contact me at 61, Weoley Castle Road, Weoley Castle, Birmingham. B29 5QD, telephone 07799 591086 or email [email protected] if you have any queries about the data I hold.
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 treatments and associated recommendations concerning aspects of health and wellbeing which I will offer to you.
What Personal Data do I collect from my website
- I may take basic contact details and information via my website to allow me to contact you and handle bookings.
- If you are purchasing a gift voucher, I will collect the name the gift recipient, so I can fulfil the gift voucher purchase. The information collected will not be used for marketing purposes, nor shared with any other party.
- I use a third-party service, Google Analytics on my website. From this I may collect certain information about your visit, such as the type of browser you use, the date and time you accessed the website, the pages that you access whilst visiting the website and the internet address of the website from which you linked directly to this website. I only use this information for statistical analysis purposes, to help improve and administer the website and it will not be shared with any other party. This information is only processed in a way which does not identify anyone. I do not make, and do not allow Google to make, any attempt to find out the identities of those visiting my website.
Lawful Basis for holding and using Client Information
As a full member of the Association of Reflexologists, the International Federation of Professional Aromatherapists, The British Reflexology Association and the Association of Reproductive Reflexologists, I abide by the each organisation’s 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 Codes of Practice and Ethics.
What information I hold and what I do with it
For clients and treatment enquiries:
- If you send me via email or text any sensitive medical/health information, I will only hold and use this if we proceed to treatment, at which time I will require explicit consent from you to hold this data. If we do not proceed to treatment, I will securely erase this information.
- When a treatment is booked, all clients will be required to read and sign a Privacy Notice under the GDPR guidelines. This will be handed to you during the appointment.
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 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 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.
CCTV for crime prevention
CCTV is used for maintaining the security of property and premises and for preventing and investigating crime only. For these reasons the information processed may include visual images, personal appearance and behaviours. This information may be about staff, customers and clients, offenders and suspected offenders, members of the public and those inside, entering or in the immediate vicinity of the area under surveillance. Where necessary or required this information is shared with the data subjects themselves, employees and agents, services providers, police forces, security organisations and persons making an enquiry.
How Long I Retain Your Information for
I will keep your information for the following periods
- ‘claims occurring’ insurance: (records to be kept for 7 years after last treatment)
- law regarding children’s records (records to be kept until the child is 25 or if 17 when treated, then 26)
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
- Treatment information or information related to your health
- Special offers and promotions (you may unsubscribe from this at any time)
I use the following third-party services:
I use a third-party service, WordPress to publish my website. I use a standard WordPress service to collect anonymous information about users’ activity on the website. For example, the number of users viewing pages on the website, to monitor and report on the effectiveness of the website and help us improve it. WordPress requires visitors that want to post a comment to enter a name and email address.
- Registered members need a cookie to be able to log in. This is ‘strictly necessary’ as WordPress won’t work without it. I do not use these types of cookies for visitors of my website.
- Visitors who leave a comment on a blog post will have a cookie set on their computer. This is not “strictly necessary” as it’s a visitor’s preference. If you choose to leave a comment on one of my blog posts, this requires a cookie to be placed on your device.
I also use third-party cookies.
These are installed by third parties (including Google Analytics) with the aim of collecting information to carry out research into the behaviour and demographics of visitors to my website. I do not gather personal information which could be used to identify visitors or their personal data.
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 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.