At Linda Hoyland, we are committed to respecting and protecting your privacy.
YOUR PERSONAL INFORMATION – GENERAL DATA PROTECTION REGULATION (GDPR)
GDPR is bringing in new legal protection for personal information from May 2018. This tells you what personal information I gather via my website, and why, and what your rights are.
Therapist’s Name: Linda Hoyland
Therapist’s Contact Details:
Telephone No: 07861 251863
Email address: email@example.com
Data Controller Contact Details: Linda Hoyland
WHAT DATA DO WE COLLECT ABOUT YOU
Personal data means any information capable of identifying an individual. It does not include data where the identity has been removed (anonymous data).
We may process the following categories of personal data about you:
Contact Data means the data we collect when you fill in the online contact form. This data includes your name, email, phone, address and message.
Technical Data means details about the device(s) you use to access our website including your IP address, browser type and version, location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Usage Data includes information about how you use our website. This includes your browsing patterns and information
such as how long you might spend on one of our web pages and what you look at and for on our website, the click stream to and from our website, and page response time.
Marketing & Communications Data includes your preferences in receiving marketing from us and your communication preferences.
HOW IS YOUR PERSONAL DATA COLLECTED
We collect data about you through a variety of different methods including:
Contact Data: You may provide Contact Data by filling in forms on our site or by communicating with us by post, phone, email, social media or otherwise.
Marketing & Communications Data: You may provide this data by using the subscribe to our newsletter form on our website.
HOW WE USE YOUR PERSONAL DATA
Contact Data: We process this data for the purposes of communicating with you and for record keeping. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us and to keep records.
Technical & Usage Data: We process this data to analyse your use of our website, to administer and protect our business and website, to deliver relevant website content to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and also improve our marketing strategy.
Marketing & Communications Data: We process this data to provide relevant updates to you about our business and services. You can unsubscribe or change your mailing preferences at any time by clicking on the links at the bottom of the e-newsletter. Alternatively you can contact us to change your marketing preferences at firstname.lastname@example.org.
Our lawful ground of processing your personal data to send you marketing communications is consent.
DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below:
- Service providers who provide website, IT and system administration services.
- Professional advisers including lawyers, bankers, auditors, accountants and insurers.
- Government bodies that require us to report processing activities such as HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
Some of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is in place:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
- Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
- If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place.
If none of the above safeguards are available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
Please email us at email@example.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to do so.
You acknowledge that the Internet is not a completely secure medium for communication and, accordingly, we cannot guarantee the security of any information you send to us (or we send to you) via the Internet. We are not responsible for any damages which you, or others, may suffer as a result of the loss of confidentiality of such information.
The Purpose of processing Client Data
In order to give professional reflexology and kinesiology treatments, I will need to gather and retain potentially sensitive information about your health. I will only use this information for informing reflexology and kinesiology treatments 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, I abide by the AoR Code of Practice and Ethics.
As a full member of the Kinesiology Federation, I abide by the KF Code of Practice and Ethics.
The lawful basis under which I hold and use your information is
‘claims occurring’ insurance
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 the AoR and KF 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 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 (other than within my own practice, or 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:
8 years due to 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 we collect from you.
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)
In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
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 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 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: www.ico.org.uk
- If you don’t agree to your therapist 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 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.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us so that we can try to resolve any issues for you.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
If you would like further information about data protection you can visit the Information Commissioner’s Office (ICO), which is the UK supervisory authority for data protection issues (www.ico.org.uk).
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What’s a cookie?
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If you want to check or change what types of cookies you accept, this can usually be altered within your browser settings. You can block cookies at any time by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.
We use the following types of cookies:
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