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New legal protection (GDPR) for personal information is effective from May 2018. This tells you what personal information I hold and why, and what your rights are.
The Purpose of processing Client Data
I hold and use client data in order to provide you with the best possible treatment options, support and advice.
Lawful Basis for holding and using Client Information
The lawful basis under which I hold and use for information is:
My requirement to hold your information for the following legal reasons
- Complementary and Natural Healthcare Council (CNHC) requirements to retain information for 8 years
- ‘claims occurring’ insurance: (records to be kept for 7 years after last treatment)
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 Code of Practice and Ethics of my membership body.
What information I hold and what I do with it
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
- Treatment details and related notes
- Photos of your feet with your permission
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.
Protecting Your Personal Data
I am committed to ensuring that your personal data is secure. In order to prevent and managerial procedures to safeguard and secure the information we collect from you.
I will contact you using the contact preference/s you have given me.
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 practitioner’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 practitioner to make changes to your personal information if it is incorrect or incomplete
- The right to erasure (also called “the right to be forgotten”)
- The right to restrict processing of personal data: You have the right to request limits on how your practitioner 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 practitioner 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 email me at the email address 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 practitioner 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 practitioner may not be able to treat you.
- Your practitioner 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.