Jayne Russell, 48 Fox Hill, London, SE19 2XE
Purpose of privacy notice
The processing of personal data is governed by the General Data Protection Regulation 2016/679 (the GDPR). This legislation will replace current data privacy law, giving more rights to you as an individual and more obligations to organisations holding your personal data.
This Privacy Notice describes what data I collect, process and use.
Jayne Russell is the data controller (48 Fox Hill, London, SE19 2XE). This means I
decide how your personal data is processed and for what purposes.
What is personal data?
Personal data relates to a living individual who can be identified from that data.
Identification can be by the information alone or in conjunction with any other information available to me.
Special category data is a sub-category of personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. Examples of special category data I may hold about you include your client notes.
Whose information does this privacy notice apply to?
This privacy notice applies to information I collect from:
• attendees at baby massage or weaning classes;
• prospective attendees who contact me via email/phone;
• former clients for massage and nutritional therapy;
• people who subscribe to my newsletter;
Applies to all,
Paper records are stored in a lockable cabinet. Files are only transported when necessary to classes/clinics. When no longer required (minimum 7 years) files are destroyed by shredding or burning.
Attendees and prospective attendees for classes
1. I use your name, address, telephone number and email address to make bookings. I also request your baby’s birth date and any health/medical concerns. I am unable to send or receive encrypted emails so you should be aware that any emails I send or receive may not be protected in transit.
2. I use your name and email address, only if I have your explicit consent or legitimate interest, to send you marketing materials such as a newsletter.
I do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. I do not collect any information about criminal convictions and offences.
Former massage and nutritional therapy clients
Examples of special category data I may hold about you include your client notes.
1. I keep diary records of all appointments for patients attending my practice to keep a record of when you were treated for tax purposes and to secure potential evidence in the event of a criminal prosecution, civil litigation, insurance claim or complaint to my regulatory body FNTP.
2. I keep a record of your presenting complaint and symptoms, any relevant medical and family history, your GP’s name and address and record any treatment given, details of progress of your case, including reviews of treatment planning to enable me to: review the treatment strategy and planning; and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint.
3. I also any information and advice that I have given, especially when
referring patients to any other health professional, to help you to receive the most
appropriate treatment and to secure evidence in the event of criminal
proceedings, civil litigation, an insurance claim or complaint. I secure your consent
to passing on your medical details to another practitioner before this is done.
4. I record any decisions made in conjunction with you to help you to receive the most appropriate treatment and to secure evidence in the event of criminal
proceedings, civil litigation, an insurance claim or complaint.
Complaint from a person would be contained in a file with the details of the
complaint, the identity of the complainant and any other individuals involved in the complaint. I would only use the personal information I collect to process the complaint and to check on the level of service I provide. I usually have to disclose the complainant’s identity to whoever the complaint is about. If a complainant doesn’t want information identifying him or her to be disclosed, I will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis. I may need to provide personal information collected and processed in relation to complaints to my associations FNTP, IAIM or our insurance company.
I will keep personal information contained in complaint files in line with our
retention policy. This means that information relating to a complaint will be
retained for two years from closure. It will be retained in a secure environment
and access to it will be restricted according to the ‘need to know’ principle.
Similarly, where enquiries are submitted to me I will only use the information
supplied to me to deal with the enquiry and any subsequent issues and to check
on the level of service I provide.
How do I process your personal data?
I comply with my obligations under the GDPR by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data. I use your personal data for the purposes set out below.
Subscribers to my newsletter
You will receive marketing communications from us:
(i) as a legitimate interest if you purchased services from me; or
(ii) if you have signed up to receive my newsletter
(iii) in each case, you have not opted out of receiving that marketing.
Sharing your personal data
Your personal data will be treated as strictly confidential, and will be shared with:
-named third parties, only with your explicit consent;
-the relevant authority such as the police or a court, if necessary for compliance with a legal obligation to which we are subject e.g. a court order;
-your doctor or the police if necessary to protect yours or another person’s life;
-the police or a local authority for the purpose of safeguarding a child or vulnerable adults
-my regulatory body, IAIM, FNTP, or my insurance company in the event of a complaint or insurance claim being brought against me
-my solicitor in the event of any investigation or legal proceedings being brought
I will not share your personal data with any third party for marketing purposes.
For further details about the situations when information about you might be shared please see the Information Commissioner’s website at https://ico.org.uk/for-thepublic/personalinformation/sharing-my-info/
How long is your personal data kept?
I keep client records for a period of 7 years, longer in the case of minors
Contact details of your paper files are updated if you contact me with new details. Your other information is not updated unless you see me for another treatment. Your file will be destroyed by shredding or burning after 7 years.
At any time you may request that changes are made to your contact details.
Your rights and your personal data
Unless subject to an exemption under the GDPR, you have certain rights with respect to your personal data as set out below.
The right to request a copy of your personal data which I hold about you.
The right to request that I correct any personal data if it is found to be inaccurate or
out of date.
The right to request your personal data is erased where it is no longer necessary for me to retain such data.
The right to withdraw your consent to the processing at any time. This right does not apply where I am processing information using a lawful purpose other than consent.
The right to request that we provide you with your personal data and where
possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable) [This right only applies where the processing is based on consent or is necessary for the performance of a contract with you and in either case that we are processing the data by automated means].
The right, where there is a dispute in relation to the accuracy or processing of your
personal data, to request a restriction is placed on further processing.
The right to object to the processing of personal data, (where applicable) [This right
only applies where processing is based on legitimate interests (or the performance
of a task in the public interest/exercise of official authority); direct marketing and
processing for the purposes of scientific/historical research and statistics].
The right to be informed if your data is lost. I shall also inform the Information
Commissioner’s Office in accordance with the time limits in the GDPR.
The right to lodge a complaint with the Information Commissioner’s Office.
For further details about these rights please see the Information Commissioner’s website at https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/
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.
To exercise all relevant rights, queries of complaints please in the first instance contact me at: 48 Fox Hill, London SE19 2XE.
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.