YOUR PERSONAL INFORMATION - GENERAL DATA PROTECTION REGULATION (GDPR)
Who I am and how to contact me:
Michelle Smith Therapies
15 Orkney Place
Email: [email protected]
Data Controller Contact Details:
I have registered with the ICO and this is renewed automatically each year.
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) and a registered provider with the Complementary and Natural Healthcare Council (CNHC), 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 CNHC 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. This could be for the following reasons:
1) In the case of provision of free taster sessions I may share your contact details and written feedback / evaluation with the organisation that has paid for those taster sessions only in order for them to further develop and assess their outreach programmes. No medical or health information disclosed to me at those sessions will be provided.
2) Where the treatment has been provided in the case of your agreement to be a case study for my continued professional development, I will share your information with the registered trainer for that course if case studies form a requirement of my final assessment and approval to practise professionally. Your name, contact details, medication and reason for medication, date of birth, occupation, presenting conditions with any medical diagnosis, your condition and relevant markers, details of the treatment I have given you and why, comments that either of us have about the treatment/s, and changes in your condition or situation limited to the time that you are a case study.
3) Where you have been referred for treatment.
How Long I Retain Your Information for:
I will keep your information for the following periods:
claims occurring insurance: for which I am required to keep my records for 7 years after the last treatment
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.
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 my email provider, G Suite by Google, is based outside of the UK. They have committed to complying with all applicable privacy laws, including the GDPR, and more information about that commitment can be found by clicking here.
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 / Therapies information or information related to your health
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 on the ICO's website.
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 copy of this document will be sent to you should you contact me via email, and a hard copy will be provided at our first treatment in order to confirm that you have understood and accepted my privacy statement and your rights under the GDPR.