GDPR brought in new legal protection for personal information from May 2018. This tells you what personal information I hold and why, and what your rights are.
Reflexology & Massage Therapy
As a full member of the Federation of Holistic Therapies and Association of Reflexologists, I abide by their Codes of Practice and Ethics. The lawful basis under which I hold and use your information is my requirement to hold your information for the following legal reasons
a. ‘claims occurring’ insurance
b. CNHC requirements to retain information
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 Confidentiality as defined in their Code of Practice and Ethics.
Balancing U provides nutritional therapy services to clients to improve their health through diet and lifestyle interventions. Through nutritional therapy consultations, dietary and lifestyle analysis and biochemical testing, I aim to understand the underlying causes of your health issues which I will seek to address through personalised dietary therapy, nutraceutical prescription (supplements) and lifestyle advice.
I use this information in order to provide you with direct healthcare. This means that the legal basis of our holding your personal data is for legitimate interest.
What information I hold and what I do with it
In order to give professional treatments, I will need to ask for and keep personal information. I will only use this for informing treatments and any advice I give as a result of your treatment. You provide me with personal data in the following ways:
This may include the following information:
I will NOT share your information with anyone else (other than within my own practice, or as required for legal process) without explaining why it is necessary, and getting your explicit consent.
I will keep information about you confidential. I will only disclose your information with other third parties with your express consent with the exception of the following categories of third parties:
I may share your information with supplement companies and biochemical testing companies as part of providing you with direct healthcare. I will not include any sensitive information
I will seek your express consent before sharing your information with your GP or other healthcare providers. However if I believe that your life is in danger then I may pass your information onto an appropriate authority (such as the police, social services in the case of a child or vulnerable adult, or GP in case of self-harm) using the legal basis of vital interests.
I may share your case history in an anonymised form with my peers for the purpose of professional development. This may be at clinical supervision meetings, conferences, online forums, and through publishing in medical journals, trade magazines or online professional sites. I will seek your explicit consent before processing your data in this way.
Information I get from other sources
I may obtain sensitive medical information in the form of test results from biochemical testing companies. I use this information in order to provide you with direct healthcare. This means that the legal basis of me holding your personal data is for legitimate interest.
I may obtain sensitive information from other healthcare providers. The provision of this information is subject to you giving me your express consent. If I do not receive this consent from you, I will not be able to coordinate your healthcare with that provided by other providers which means the healthcare provided by me may be less effective.
How Long I Retain Your Information for
Following completion of your healthcare I retain your personal data for the period defined by my professional associations BANT, AoR, FHT and registrant body, CNHC. This enables me to process any complaint you may make. In this case the legal basis of me holding your personal data is for contract administration.
I will keep your information for the following periods
• ‘claims occurring’ insurance: (records to be kept for 7 years after last treatment))
• 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.
I will contact you using the contact preferences you give me in relation to:
• Appointment times
• Treatment information or information related to your health
Every individual has the right to see, amend, delete or have a copy, of data held that can identify you, with some exceptions. You do not need to give a reason to see your data.
If you want to access your data you must make a subject access request in writing to [email protected] Under special circumstances, some information may be withheld. I shall respond within 20 working days from the point of receiving the request and all necessary information from you. My response will include the details of the personal data I hold on you including:
You have the right, subject to exemptions, to ask to:
I do not carry out any automated processing, which may lead to automated decision based on your personal data.
If you would like to invoke any of the above rights then please write to the Data Controller at 140 Alwyn Road, Bilton, Rugby CV22 7RA or email [email protected]
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 have a complaint regarding the use of your personal data then please contact write to the Data Controller at 140 Alwyn Road, Bilton Rugby CV22 7RA or email [email protected]
If your complaint is not resolved to your satisfaction and you wish to make a formal complaint to the Information Commissioner’s Office (ICO), you can contact them on 01625 545745 or 0303 1231113, www.ico.org.uk