YOUR PERSONAL INFORMATION - GENERAL DATA PROTECTION REGULATION (GDPR)
GDPR (implemented by DPA2018 in the UK) brought 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.
My Contact Details:
Any reference to I, we, us, our refers to Luna Wellness UK. Luna wellness UK controls the website www.lunawellnessuk.com
The Purpose of processing Client Data
In order to give professional reflexology treatments, I will need to gather and retain potentially sensitive information about your health. I will only use this information for informing reflexology 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.
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.
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. 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 Confidentiality as defined in the AoR Code of Practice and Ethics.
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 (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:
‘claims occurring’ insurance: (records to be kept for 7 years after last treatment)
law regarding children’s records (records to be kept until the child is 25 or if 17 when treated, then 26)
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:
Reflexology information or information related to your health
News, special offers and promotions (you may unsubscribe from this at any time)
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.
If you would like to: access, correct, amend or delete any personal information we have about you, you are invited to contact me at firstname.lastname@example.org.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
A copy of this document will be sent to you should you contact me via email, and a hard copy will be provided at our first treatment in order to confirm that you have understood and accepted the privacy statement and your rights under the GDPR.
Please be aware that if you send me any sensitive medical/health information, I will only hold and use this if we proceed to treatment, at which time I will require explicit consent from you to hold this data. If
we do not proceed to treatment I will erase this information.
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 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.