General Data Protection Regulation (GDPR)
YOUR PERSONAL INFORMATION
The GDPR brings new legal protection for personal information from May 2018. This tells you what personal information I hold and why, and what your rights are.
Who I am and how to contact me:
Therapist's name: Monica Jane Mills
Telephone no: 07506 714 668
Address: 19 Earlspark Avenue, Bieldside, Aberdeen AB15 9BU
Data Controller contact details:
Monica J Mills (as above)
The Purpose of processing Client Data
In order to give professional treatments, I will need to gather and retain potentially sensitive information about your health. I will only use this information for informing the treatments I offer, and associated recommendations concerning aspects of health and wellbeing which I will offer to you. I take basic contact details and information via my website to allow me to contact you and handle bookings.
Lawful Basis for holding and using Client Information
As a full member of the Association of Reflexologists (AoR), and a registrant with the Complementary and Natural Healthcare Council (CNHC), I abide by a strict Code of Practice and Ethics for these organisations. 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.
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 and CNHC Confidentiality as defined in their respective Code of Practice and Ethics.
What information I hold and what I do with it
In order to give professional treatments, I will need to ask for and keep information about your health. I will only use this for informing the treatments I offer, 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 at first consultation)
- Treatment details and related notes
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.
How long I retain your information for
I will keep your information for the following periods:
a) Claims occurring insurance
I am required to keep my records for seven years after the last treatment
b) Law regarding children’s records
I am required to keep my records until the child is 25, or if 17 when treated, until they are 26.
c) CNHC registration requirements
I am required to retain information for eight years after the last treatment.
I will not transfer your data outside the EU without your consent, although you need to be aware that I do use a third party service as part of my business operation, as follows:
My website is written and designed by myself, and is powered through PhD Interactive and their WebHealer solution. They do not hold any personal data on my behalf, and while any emails received via my website are done so via the WebHealer mail system for privacy reasons they are not accessible to staff at WebHealer and are not stored on any of their systems. The full privacy statement from PhD Interactive can be found here: http://www.phdinteractive.co.uk/privacy/
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 we collect from you.
I will contact you using the contact preferences you give me in your first contact with me, and during our first consultation, in relation to:
- appointment times
- reflexology information or information relating to your health
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 that you do not 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 do not 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 can be found at: www.ico.org.uk
If you do not agree to your therapist keeping records of information about you and your treatments, or if you do not 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.