GENERAL PRIVACY NOTICE
Your personal data – what is it?
‘Personal data’ is any information about a living individual, which allows them to be identified from that data (for example a name, photographs, videos, email address, or address). Identification can be by directly using the data itself or by combining it with other information, which helps to identify a living individual. The processing of personal data is governed by legislation relating to personal data, which applies in the United Kingdom including the General Data Protection Regulation (the GDPR) and other legislation relating to personal data and rights such as the Human Rights Act.
Who am I?
This Privacy Notice is provided to you by Kate Willis – Gentlebeing Massage and Bodywork who is the data controller for your data.
Other data controllers I may work with:
- Other therapists
- Statutory agencies – including doctors
I may need to share your personal data that I hold with them so that they can carry out their responsibilities to me. If I and the other data controllers listed above are processing your data jointly for the same purposes, then we may be “joint data controllers” which mean we are all collectively responsible to you for your data. Where each of the parties listed above are processing your data for their own independent purposes then each of us will be independently responsible to you and if you have any questions, wish to exercise any of your rights (see below) or wish to raise a complaint, you should do so directly to the relevant data controller.
A description of what personal data I process and for what purposes is set out in this Privacy Notice.
I will process some or all of the following personal data where necessary to perform my tasks:
- Names, titles and aliases, photographs
- Contact details such as telephone numbers, addresses, and email addresses
- Demographic information such as gender, age, marital status, hobbies
- The data I process may include sensitive personal data or other special categories of data such as mental and physical health, details of injuries and medication/treatment received.
How I use sensitive personal data:
- I may process sensitive personal data in order to comply with legal requirements, professional and insurance requirements and obligations to third parties.
- These types of data are described in the GDPR as “Special categories of data” and require higher levels of protection. I need to have further justification for collecting, storing and using this type of personal data
- I may process special categories of personal data in the following circumstances:
- In order to treat you
- To maintain my records to fulfil my professional, insurance and legal obligations
- Where it is needed in the public interest.
- Less commonly, I may process this type of personal data where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.
Do I need your consent to process your sensitive personal data?
- In limited circumstances, I may approach you for your written consent to allow me to process certain sensitive personal data. If I do so, I will provide you with full details of the personal data that I would like and the reason I need it, so that you can carefully consider whether you wish to consent.
I will comply with data protection law. This says that the personal data I hold about you must be:
- Used lawfully, fairly and in a transparent way
- Collected only for valid purposes that I have clearly explained to you and not used in any way that is incompatible with those purposes
- Relevant to the purposes I have told you about and limited only to those purposes
- Accurate and kept up to date
- Kept only as long as necessary for the purposes I have told you about
- Kept and destroyed securely including ensuring that appropriate technical and security measures are in place to protect your personal data to protect personal data from loss, misuse, unauthorised access and disclosure.
I use your personal data for some or all of the following purposes:
- To provide treatment to you
- To contact you by post, email or telephone
- To enable me to meet all legal and statutory obligations
- To maintain my own accounts and records
- To seek your views, opinions or comments
- To notify you of changes to my services or events
What is the legal basis for processing your personal data?
I process personal data for the performance of my contract with you to treat you, or to take steps to enter into a contract to treat you.
Sharing your personal data
This section provides information about the third parties with whom I may share your personal data. These third parties have an obligation to put in place appropriate security measures and will be responsible to you directly for the manner in which they process and protect your personal data. It is likely that I will need to share your data with some or all of the following (but only where necessary):
- The data controllers listed above under the heading ‘Other data controllers I may work with’
How long do I keep your personal data?
I will keep your records to comply with professional, insurance and legal. To comply with requirements, I must keep your data for 7 years after you finish treatment with me. If you are under 18 years old when I treat you, I must keep your data for 7 years after you have reached the age of 18 or for 7 years after treatment ends, whichever is longer. In general, I will endeavour to keep data only for as long as I need it. This means that I will delete it when it is no longer needed.
Your rights and your personal data
You have the following rights with respect to your personal data. When exercising any of the rights listed below, in order to process your request, I may need to verify your identity for your security. In such cases I will need you to respond with proof of your identity before you can exercise these rights.
- The right to access personal data I hold on you
- At any point you can contact me to request the personal data I hold on you as well as who has access to the personal data and where I obtained the personal data from. Once I have received your request I will respond within one month
- There are no fees or charges for the first request but additional requests for the same personal data or requests which are manifestly unfounded or excessive may be subject to an administrative fee.
- The right to correct and update the personal data I hold on you
- If the data I hold on you is out of date, incomplete or incorrect, you can inform me and your data will be updated.
- The right to have your personal data erased
- If you feel that I should no longer be using your personal data or that I am unlawfully using your personal data, you can request that I erase the personal data I hold
- When I receive your request, I will confirm whether the personal data has been deleted or the reason why it cannot be deleted (for example because I need it for to comply with a professional, insurance or legal obligation).
- The right to object to processing of your personal data or to restrict it to certain purposes only
- You have the right to request that I stop processing your personal data or ask me to restrict processing. Upon receiving the request, I will contact you and let you know if I am able to comply or if I have a legal obligation to continue to process your data.
- The right to data portability
- You have the right to request that I transfer some of your data to another controller. I will comply with your request, where it is feasible to do so, within one month of receiving your request.
- The right to withdraw your consent to the processing at any time for any processing of data to which consent was obtained
- You can withdraw your consent easily by telephone, email, or by post (see Contact Details below).
- The right to lodge a complaint with the Information Commissioner’s Office
- You can contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.
Transfer of Data Abroad
Any personal data transferred to countries or territories outside the European Economic Area (“EEA”) will only be placed on systems complying with measures giving equivalent protection of personal rights either through international agreements or contracts approved by the European Union. My website is also accessible from overseas but your data would not be accessed from overseas from the website.
If I wish to use your personal data for a new purpose, not covered by this Privacy Notice, then I will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, I will seek your prior consent to the new processing.
Changes to this notice
I keep this Privacy Notice under regular review and I will place any updates on this web page. This Notice was last updated in May 2018.
Please contact me if you have any questions about this Privacy Notice or the personal data I hold about you or to exercise all relevant rights, queries or complaints at:
The Data Controller, Kate Willis Gentlebeing Massage and Bodywork, 27 North Street, Beaminster, Dorset, DT3 8DZ.07880 313527
Kate Willis – Gentlebeing Massage and Bodywork. May 2018. For review by end of May 2019 or before if changes required