What personal information do I collect?
In order to treat you, I will ask you to provide certain information. This includes:
- Date of birth
- Home address
- Email address
- Telephone number
- Medical history.
To this, over time, I will add details of the conditions for which you have consulted me and the remedies and other therapies that I have prescribed or recommended.
How do I collect this personal information?
All the information collected is obtained directly from you. This is usually at the point of your initial consultation. The information is collected via a ‘medical history form’ which I ask you to complete prior to or at the initial consultation. At the point at which you provide your personal information, I will also request that you provide consent for me to store and use your data. Your consent is required in order to ensure my compliance with data protection legislation. Subsequently, I will add to this initial information with details of the consultations you hold with me.
How do I use this personal information?
I use your personal information to analyse the conditions for which you have consulted me and to prescribe remedies and other therapies.
I will communicate with you by email, other digital methods, by telephone and by post.
With whom do I share your personal information?
I do not share your personal information
How long do I keep your personal information?
I need to keep your information for as long as you continue to consult me. Since patients often return for more consultations after a period of absence, I will keep your information for seven years after your last consultation. In the case of children, 7 years after their 18th Birthday . If they are 17 years when they come for a consultation information will be kept till they are 26 years old. At that point, your file will be securely destroyed and any digital information will be erased from my computer systems.
How your information can be updated or corrected
To ensure that I have accurate and up-to-date information, you need to inform me of any changes you believe I should make to the personal information I hold. You can do this by contacting me by any of the methods previously described.
Under data protection legislation, you have the right to inspect the personal information I hold about you. You can make a request to do so by contacting me and I will endeavour to respond within 14 working days.
How do I store your personal information?
My patient files are paper-based and are held securely within my consulting room (or occasionally in computer files). I take steps to protect your personal information against loss or theft, as well as unauthorised access, disclosure, copying, use, or modification.
Your email address, if you have one, is held securely on the servers of my email providers, currently ntlworld and Google mail held securely on Virgin.
Changes to this policy
This policy may change from time to time. If I make any material changes, I will make you aware of them.
If you have any queries about this policy, need it in an alternative format, or have any complaints about my privacy practices, please contact me in the following ways:
34 Tresham St
By phone: 01536 516220 / 07929128537
Policy review date: Every 2 years, e.g. May 2020
DATA PROTECTION POLICY
Scope of the policy
Why this policy exists
This data protection policy ensures that SW:
- complies with data protection law and follows good practice
- protects the rights of patients
- is open about how she stores and processes patients’ data
- protects herself from the risks of a data breach
Data protection principles
The General Data Protection Regulation identifies 8 data protection principles.
Principle 1 – Personal data shall be processed lawfully, fairly and in a transparent manner
Principle 2 – Personal data can only be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
Principle 3 – The collection of personal data must be adequate, relevant and limited to what is necessary compared to the purpose(s) data is collected for.
Principle 4 – Personal data held should be accurate and, where necessary, kept up to date. Every reasonable step must be taken to ensure that personal data that are inaccurate are erased or rectified without delay.
Principle 5 – Personal data which is kept in a form which permits identification of individuals shall not be kept for longer than is necessary.
Principle 6 – Personal data must be processed in accordance with the individuals’ rights.
Principle 7 – Personal data must be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
Principle 8 – Personal data cannot be transferred to a country or territory outside the European Union unless that country or territory ensures an adequate level of protection for the rights and freedoms of individuals in relation to the processing of personal data.
Certain of these principles are expanded upon in the sections that follow.
Lawful, fair and transparent data processing
SW requests personal information from patients and potential patients for the purpose of consulting with them and providing them with advice and guidance on homeopathic treatments. The forms used to request personal information may contain a privacy statement informing patients and potential patients why the information is being requested and what the information will be used for. Patients should be asked to provide consent for their data to be held and a record of this consent along with patient information will be securely held. Patients will be informed that they can, at any time, remove their consent and will be informed as to what to do should they wish to do so.
Processed for Specified, Explicit and Legitimate Purposes
Patients will be informed how their information will be used and SW will seek to ensure that patients’ information is not used inappropriately. Appropriate use of information provided by patients includes:
- Communicating with patients in order to make, change or cancel consultations
- Assessing the conditions and issues reported by patients and devising and prescribing relevant remedies and therapies.
SW will ensure that patients’ information is managed in such a way as to not infringe an individual’s rights which include:
- The right to be informed
- The right of access
- The right to rectification
- The right to restrict processing
- The right to data portability
- The right to object.
Adequate, Relevant and Limited Data Processing
SW’s patients will only be asked to provide information that is relevant to support consultations and prescription. This includes:
- Date of birth
- Postal address
- Email address
- Telephone number
- Medical history.
Where additional information may be required, this will be obtained with the specific consent of the patient who will be informed as to why this information is required and the purpose for which it will be used.
There may be occasional instances where a patient’s information needs to be shared with a third party due to an accident or incident involving statutory authorities. Where it is in the best interests of the patient or of SW, in these instances where SW has a substantiated concern then consent does not have to be sought from the individual.
Accuracy of Data and Keeping Data up to Date
SW has a responsibility to ensure that patients’ information is kept up to date. Patients will be required to let SW know if any of their personal information changes.
Accountability and Governance
SW is responsible for ensuring that her practice remains compliant with data protection requirements and can provide evidence that it has. For this purpose, those from whom data is required will be asked to provide written consent. The evidence of this consent will then be securely held as evidence of compliance.
SW has a responsibility to ensure that data is both securely held and processed. This includes:
- using strong passwords for information held within computer systems
- restricting access to computer and paper-based files
- using password protection on laptops and PCs that contain or access personal information
- using password protection or secure cloud systems
- providing adequate virus-protection and firewall software to secure computer-based systems.
Subject Access Request
SW’s patients are entitled to request access to the information that is held by her. The request needs to be received in the form of a written request to SW.
On receipt of the request, the request will be formally acknowledged and dealt with within 14 days unless there are exceptional circumstances as to why the request cannot be granted. SW will provide a written response detailing all information held on the individual. A record shall be kept of the date of the request and the date of the response.
Data Breach Notification
Were a data breach to occur, action shall be taken to minimise the harm. SW will inform any patients where she believes their personal information has been compromised. Where necessary, the Information Commissioner’s Office will be notified.
If a patient contacts SW to say that they feel that there has been a breach by SW, she will ask the patient to provide an outline of their concerns. If the initial contact is by telephone, SW will ask the patient to follow this up with an email or a letter detailing their concern. The concern will then be investigated fully and a response made to the patient. Breach matters will be subject to a full investigation, records will be kept and all those involved notified of the outcome.
Policy review date: Every 2 years, e.g. May 2020
PRIVACY (&CONSENT) NOTICE. via the Association of Reflexologists.
This is for clients interested in having or who have had the following therapies with myself. Reflexology, Indian head Massage, Reiki, Attunement to Reiki, and Allergy Testing.
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: Charlotte Shusha Walmsley
Therapist’s Contact Details:
Telephone No: 01536 516220 / 07929128537
Address: 34 Tresham St, Kettering, Northants, NN16 8RS.
Data Controller Contact Details: Charlotte Shusha Walmsley
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.
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
- my requirement to hold your information for the following legal reason
- ‘claims occurring’ insurance
- law regarding children’s records.
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, head massage ,reiki, or allergy testing treatments, I will need to ask for and keep information about your health. I will only use this for informing the above 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 con
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.
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)
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 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.