GENERAL DATA PROTECTION REGULATION (GDPR) – YOUR PERSONAL INFORMATION
GDPR is bringing in new legal protection for your personal information from May 2018. This form tells you what personal information I will hold and why I hold it, along with your rights to this information.
Therapist’s Name: Michelle Dunn – Feet First Reflexology
Therapist’s Contact Details: http://www.feetfirstreflexology.org
Telephone No: 07835 340940
Email address: firstname.lastname@example.org
Address: 29 The Sycamores, Bluntisham, PE28 3XW
Data Controller: Michelle Dunn
Data Protection Officer: Michelle Dunn
The purpose of processing client data
In order to give professional reflexology treatments, I will need to gather and retain potentially sensitive information about you and your health. I will only use this information for reflexology treatments and associated recommendations concerning aspects of health and wellbeing which I will offer to you.
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 interests which is 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.
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 unless legally required to do so without explaining to you first why this is necessary and getting your explicit consent.
How long I retain your information for
I will keep your information for the following periods:
a. For insurance purposes records to be kept for 7 years after last treatment
b. Children’s records are by law kept until the child is 25 or if 17 when treated, then 26
c. CNHC requirements to retain information for 8 years
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. (a copy of these procedure can be requested anytime)
I will contact you using the contact preferences you give me in relation to:
• Appointment times
• Reflexology information or information related to your health
• Special offers and promotions (you may unsubscribe from this at any time)
GDPR gives you the following rights:
• The right to be informed:
To know how I hold and use your personal information
• The right of access:
To see my records of your personal information, so you know what is held about you and can verify it.
• The right to rectification:
To tell me 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 me 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 I use 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 me you don’t want me 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 are dissatisfied with the response you can complain to the Information Commissioner’s Office; their contact details are at: http://www.ico.org.uk
• If you don’t agree to me keeping records of information about you and your treatments, or if you don’t allow me to use the information in the way I need to for treatments, I may not be able to treat you
• I have to keep your records of treatment for a certain period as described above, which may mean that even if you ask me to erase any details about you, I might have to keep these details until after that period has passed
• I can move your records between my computers and IT systems, as long as your details are protected from being seen by others without your permission.