Privacy Policy
This notice refers to personal data, which is defined as information concerning any individual that is not already in the public domain. The General Data Protection Regulation (GDPR) introduced new legal protection for personal information in May 2018. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal and its storage.
This policy tells you what personal information is gathered, why and what your rights are.
Name and Contact Details
Lindsay Mitchell
Down to Earth Reflexology
29 Sollershott East, Letchworth, Herts SG6 3JN
Email: lindsay@downtoearthreflexology.co.uk Tel: 07813 711458
Who is Down to Earth Reflexology?
Down to Earth Reflexology provides Reflexology Treatments. Treatments are carried out in accordance with the Association of Reflexology’s Code of Conduct.
Data Controller
All data is stored and managed by Down to Earth Reflexology.
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 may be offered.
Data that is collected via my website is basic contact details (Name, Email address, Telephone number and Enquiry Reason) and used to allow me to contact you and handle potential 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 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 reasons:
- ‘Claims Occurring’ Insurance
- Law regarding Children’s Records
- Your Consent
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.
Data Held and its Purpose
- Medical Information: for the purposes of providing treatment, Down to Earth Reflexology may require detailed medical information. I will only collect what is relevant and necessary for your treatment. When you visit the practice, I will make notes which may include details concerning your medication, treatment and other issues affecting your health. This data is always held securely, is not shared with anyone not involved in your treatment. To be able to process your personal data it is a condition of any treatment that you give your explicit consent to allow Down to Earth Reflexology to document and process your personal medical data.
- Contact Details: provided by you such as telephone numbers, email addresses, postal addresses may be used to remind you of future appointments, provide reflexology information or information related to your health.
- Marketing: Down to Earth Reflexology may also use the contact details provided by you to respond to your enquiries, including making telephone contact or emailing information to you which I believe may be of interest to you. From time to time Down to Earth Reflexology may contact you with special offers and promotions (from which you may unsubscribe from at any time). In making initial contact with the practice you consent to Down to Earth Reflexology maintaining a marketing dialogue with you until you either opt out (which you can do at any time) or I decide to desist in promoting Down to Earth Reflexology’s services. You can ask to be removed from our marketing database by emailing or phoning the practice using the contact details provided.
Down to Earth Reflexology will only collect the information needed so that the services you require can be provided and 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. Down to Earth Reflexology will not sell or broker your data.
Retaining Your Data
Down to Earth Reflexology will store your personal data for the required length of time to meet legal obligations, as outlined below:
- All records to be held for 8 years
- ‘Claims Occurring’ Insurance records to be kept for 7 years after last treatment
- Law regarding Children’s Records to be kept until the child is 25 years old or if 17 when treated, then 26 years old
After these durations all personal data will be deleted, unless basic information needs to be retained to meet future obligations to you, such as erasure details.
Data Storage
All data is held in the United Kingdom, with the exception of customer emails stored on Mailchimp (for the purposes of sending out newsletters and marketing offers) which has achieved GDPR compliancy under the EU-US Privacy Shield. Subscribers are able to manage their subscription preferences and can additionally contact Down to Earth Reflexology to unsubscribe at any point.
Protecting Your Personal Data
Down to Earth Reflexology is committed to ensuring that your personal data is secure. In order to prevent unauthorised access or disclosure, appropriate technical, physical and managerial procedures have been put in place to safeguard and secure the information collected from you. Your data will not be transferred outside the EU without your consent.
Your Rights
At any point whilst Down to Earth Reflexology are in possession of, or processing your personal data you have the following rights:
- Right of access – you have the right to request a copy of the information that is held about you
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records
- Right to restriction of processing – where certain conditions apply you have a right to restrict the processing of your data
- Right of portability – you have the right to have the data we hold about you to be transferred to another organisation
- Right to object – you have the right to object to data being used or used for certain purposes
- Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling
In the event that Down to Earth Reflexology refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge. At your request Down to Earth Reflexology can confirm what information it holds about you and how it is processed.
Full details of your rights can be found at www.ico.org.uk. If you wish to exercise any of these rights, please use the contact details given below. If you are dissatisfied with the response you can complain to the Information Commissioner's Office, using their contact details below.
Down to Earth Reflexology's Rights
Whilst in possession of your data, Down to Earth Reflexology has the following rights:
- If you don’t agree to me (your therapist) 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 computers and IT systems, as long as your details are protected from being seen by others without your permission.
Complaints
In the event that you wish to make a complaint about how your personal data is being processed by Down to Earth Reflexology you have the right to complain directly to:
Lindsay Mitchell, Down to Earth Reflexology
29 Sollershott East, Letchworth, Herts SG6 3JN
Email: lindsay@downtoearthreflexology.co.uk Tel: 07813 711458
If you do not get a response within 30 days, you can complain to the:
Information Commissioner's Office
Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Tel: 0303 123 1113
