YOUR PERSONAL INFORMATION – GENERAL DATA PROTECTION REGULATION (GDPR)
GDPR is bringing in new legal protection for personal information from May 2018. This tells you the personal information I gather via my website, and why, and what your rights are.
Therapist’s Name: Fiona Mossman
Telephone No: 07979 655 965
Email address: firstname.lastname@example.org
The Purpose of processing Client Data
In order to give professional reflexology and massage treatments, I will need to gather and retain potentially sensitive information about your health. I will only use this information for informing reflexology and massage treatments and any advice I may give you regarding your health and wellbeing. I take basic contact details and information via my website to allow me to contact you, handle bookings and to process my accounts.
Lawful Basis for holding and using Client Information
As a full member of the Association of Reflexologists (AoR), I abide by the AoR 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
- my requirement to hold your information for the following legal reason ‘claims occurring’ insurance
- 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 Code of Practice and Ethics.
What information I hold and what I do with it
In order to give professional reflexology and massage treatments, I will need to ask for and keep information about your health. I will only use this for informing reflexology and massage 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.
Interacting with my website
My website complies to the DPA (Data Protection Act 1998) and it already complies to the GDPR (General Data Protection Regulation).
What are cookies?
Cookies are small files saved to your computer hard drive that track, save and store information about your interactions and usage of the website. This allows the website, through its server to provide you with a tailored experience within this website.
Website Visitor Tracking
Like most websites, my site uses Google Analytics (GA) to track user interaction. This data lets me know the number of people using my site, to better understand how they find and use my web pages and to see their journey through the website.
Although GA records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to me. GA also records your computer’s IP address which could be used to personally identify you but Google do not grant us access to this.
Should you choose to add a comment on any posts published on my blog, the name and email address you enter with your comment will be saved to this website’s database, along with your computer’s IP address and the time and date that you submitted the comment. This information is only used to identify you as a contributor to the comment section of the respective blog post and is not passed on to any of the third-party data processors detailed below. Only your name will be shown on the public-facing website although if the supplied email address is linked to a Gravatar account, your Gravatar photo will also be displayed.
Your comment and its associated personal data will remain on the site until I remove the comment or remove the blog post.
Should you wish to have the comment and its associated personal data deleted, please email me here using the email address that you commented with.
If you are under 16 years of age you MUST obtain parental consent before posting a comment on our blog.
How Long I Retain Your Information for
I am required by my insurance company to keep your treatment information for 7 years after your last treatment
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 I collect from you.
I will only contact you using the contact preferences you give me in relation to:
- Appointment times
- Reflexology or massage information related to your health and wellbeing
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.