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Your Personal Information – General Data Protection Regulation (GDPR)
GDPR brought in new legal protection for personal information in May 2018. This tells you what personal information I gather via my website, and why, and what your rights are.
Please be aware that if you send me 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 erase this information.
Charlotte Horsley - West Horsham Reflexology
Data Controller Contact Details: Charlotte Horsley
Telephone No: 07956 312 118
Address: 19, The Crescent. Horsham. West Sussex. RH12 1NA
Email address: email@example.com
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.
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 my legitimate interest 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 Confidentiality 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 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 will NOT share your information with anyone else (other than 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:
• Membership of the CNHC requires me to retain information for 8 years. In addition, ‘claims occurring’ insurance requires that records are kept for 7 years after the last treatment.
• The law regarding children’s records requires me to keep records until the child is 25 or if the child is 17 when treated, then until the child is age 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:
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.