Your personal information – General Data Protection Regulation (GDPR)
In May 2018, the EU General Data Protection Regulation (GDPR) replaced the Data Protection Directive 95/46/EC and is designed to harmonise data privacy laws across Europe, to protect and empower all EU citizens data privacy and to reshape the way organisations across the region approach data privacy. This document tells you what personal information I gather via my website, and why, and what your rights are.
Therapist’s Name/Identity: Mary Dalgleish
Therapist’s Contact Details: Via Contact Form
Data Controller/Processor Contact Details: As above
GDPR Registration: I have registered with the ICO and this will be renewed each year until I cease trading.
In order to give professional treatments, I will need to gather and retain potentially sensitive information about your health when you come to me for a treatment. I will use this information for informing the treatments and associated recommendations concerning aspects of health and wellbeing, which I will offer to you. Data is rarely used to communicate and be shared outside of the clinical environment. On occasion you maybe asked for permission for the information to be shared with another practitioner or medical service for referred treatment. Full permission will be requested first. I take basic contact details and information via my website to allow me to contact you and handle bookings.
In order to run my CPD training courses in a professional manner, I need to gather information about your eligibility to do the course as well as your contact information to keep you informed about your course enquiry.
Lawful basis for holding and using client information
As a full member of the Federation of Holistic Therapists (FHT) and the Association of Reflexologists (AOR), I abide by the Code of Practice and Ethics of these organisations. The lawful basis under which I hold and use your information is
● Legitimate interest: I am required to retain the information about my clients in order to provide them with the best possible treatment options and advice.
I retain information about students who attend my CPD courses in case they lose certificates and need replacements. With their consent, I can refer clients to them and inform them of other courses I offer.
● Special Category Data – Health Related: I process under special category data, therefore the additional condition under which I hold and use this information is for me to fulfil my role as a healthcare practitioner, bound under the FHT and the AOR Confidentiality clauses as defined in their Codes of Practice and Ethics.
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. (NOTE: I do not hold client’s data electronically)
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:
(NOTE: Head2ToeMassage does not perform any automated decision making or 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 get in touch via my contact form.
If you are dissatisfied with the response, you can complain to the Information Commissioner’s Office- 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 is obliged to keep your records of treatment for a certain period of time, which may mean that even if you ask them to erase any details about you, they may 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.