This data protection policy ensures that RCHT:
• 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 himself from the risks of a data breach
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.
RCHT requests personal information from patients and potential patients for the purpose of consulting with them and providing them with advice and guidance on treatments. The forms used to request personal information will contain a privacy statement informing patients and potential patients why the information is being requested and what the information will be used for. Patients will 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.
Clients will be informed how their information will be used and RCHT 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
RCHT will ensure that patients’ information is managed in such a way as to not infringe an individual patient's rights which include:
• The right to be informed
• The right of access
• The right to rectification
• The right to erasure
• The right to restrict processing
• The right to data portabilityThe right to object
RCHT’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
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 RCHT, in these instances where RCHT has a substantiated concern, then consent does not have to be sought from the patient.
RCHT has a responsibility to ensure that patients’ information is kept up to date. Patients will be required to let RCHT know if any of their personal information changes.
RCHT is responsible for ensuring that their 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.
RCHT 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
RCHT’s patients are entitled to request access to the information that is held by RCHT. The request needs to be received in the form of a written request to RCHT.
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. RCHT will provide a written response detailing all information held on the member. A record shall be kept of the date of the request and the date of the response.
Were a data breach to occur, action shall be taken to minimise the harm. RCHT will inform any patients where she believes their personal information has been compromised. Where necessary, the Information Commissioner's Office would be notified.
If a patient contacts RCHT to say that they feel that there has been a breach by RCHT, he will ask the patient to provide an outline of their concerns. If the initial contact is by telephone, RCHT 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.
In order to provide treatment to you, I will ask you to provide certain information. This includes:
• Date of birth
• Home address
• Email address
• Telephone number
To this, over time, I will add details of the conditions for which you have consulted me and the treatments and other therapies that we have prescribed or recommended.
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 ‘Client Questionnaire’ which we ask you to complete prior to or at the initial consultation. At the point at which you provide your personal information, we will also request that you provide consent for us to store and use your data. Your consent is required in order to ensure my compliance with data protection legislation. Subsequently, we will add to this initial information with details of the consultations you hold with us.
We use your personal information to analyse the conditions for which you have consulted us, and to prescribe treatments, supplements and other therapies.
We will communicate with you by email, other digital methods, by telephone and by post.
We do not share your personal information.
We need to keep your information for as long as you continue to consult us and for a period of 8 year after your treatment has finished. Since patients often return for more consultations after a period of absence, we will keep your information for eight years after your last consultation. At that point, your file will be securely destroyed and any digital information will be erased from our computer systems.
To ensure that we have accurate and up-to-date information, you need to inform us of any changes you believe we should make to the personal information we hold. You can do this by contacting us by any of the methods previously described.
Under data protection legislation, you have the right to inspect the personal information we hold about you. You can make a request to do so by contacting us and we will endeavour to respond within 14 working days.
The information provided in the initial Client Questionnaire is stored in our business computers and external hard drives. Both are encrypted and password protected.
All other files and case notes are paper-based and are held securely within our consulting room. We 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 our email providers, currently rosecottageholistictherapies.com (hosted by GoDaddy) and Google mail, G-Suit.
This policy may change from time to time. If we make any material changes, we 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 our privacy practices, please contact us:
Rose Cottage Holistic Therapies
Edward Wright - firstname.lastname@example.org
Ayre Adams - email@example.com
This is the privacy notice for Rose Cottage Holistic Therapies. In this document, "we", "our", or "us" refer to Edward Wright & Ayre Adams, trading as Rose Cottage Holistic Therapies.
The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.
If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.
If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.
1. Information we process because we have a contractual obligation with you
When you create an account on our website, buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.
In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.
We may use it in order to:
We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.
Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable.
We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
2. Information we process with your consent
Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including our products and services, you provide your consent to us to process information that may be personal information.
Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply.
Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example to monitor the performance of a particular page on our website.
If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.
We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by instructing us firstname.lastname@example.org. However, if you do so, you may not be able to use our website or our services further.
3. Information we process because we have a legal obligation
We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation.
For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.
This may include your personal information.
4. Information provided on the understanding that it will be shared with a third party
Our website allows you to post information with a view to that information being read, copied, downloaded, or used by other people.
In posting personal information, it is up to you to satisfy yourself about the privacy level of every person who might use it.
We do store it, and we reserve a right to use it in the future in any way we decide.
Once your information enters the public domain, we have no control over what any individual third party may do with it. We accept no responsibility for their actions at any time.
Provided your request is reasonable and there is no legal basis for us to retain it, then at our discretion we may agree to your request to delete personal information that you have posted. You can make a request by contacting us at email@example.com.
5. Complaints regarding content on our website
If you complain about any of the content on our website, we shall investigate your complaint.
If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate.
Free speech is a fundamental right, so we have to make a decision as to whose right will be obstructed: yours, or that of the person who posted the content that offends you.
If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.
6. Information relating to your method of payment
At the point of payment, you are transferred to a secure page on the website PayPal or if paying by credit/debit card payment is taken via Stripe payment gateway. No payment details are kept on our website or servers. All payment data is fully secure and safe and processed through stripe who is fully PCI compliant.
7. Sending a message to our support team
When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need.
We record your request and our reply in order to increase the efficiency of our business.
We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.
Cookies are small text files that are placed on your computer's hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.
Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.
Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.
9. Personal identifiers from your browsing activity
Requests by your web browser to our servers for web pages and other content on our website are recorded.
We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.
We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.
If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.
10. Our use of re-marketing
Re-marketing involves placing a cookie on your computer when you browse our website in order to be able to serve to you an advert for our products or services when you visit some other website.
11. Information we obtain from third parties
Although we do not disclose your personal information to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal information from third parties whose services we use.
No such information is personally identifiable to you.
12. Third party advertising on our website
Third parties may advertise on our website. In doing so, those parties, their agents or other companies working for them may use technology that automatically collects information about you when their advertisement is displayed on our website.
We do not have control over these technologies or the data that these parties obtain. Accordingly, this privacy notice does not cover the information practices of these third parties.
13. Credit reference
To assist in combating fraud, we share information with credit reference agencies, so far as it relates to clients or customers who instruct their credit card issuer to cancel payment to us without having first provided an acceptable reason to us and given us the opportunity to refund their money.
14. Data may be processed outside the European Union
Our website is hosted in the United Kingdom.
We may also use outsourced services in countries outside the European Union from time to time in other aspects of our business.
Accordingly data obtained within the UK or any other country could be processed outside the European Union.
15. Access to your personal information
16. Removal of your information
If you wish us to remove personally identifiable information from our website, you may contact us at firstname.lastname@example.org.
This may limit the service we can provide to you.
17. Verification of your information
When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
18. Use of site by children
19. Encryption of data sent between us
We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.
Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.
20. How you can complain
21. Retention period for personal data
Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:
22. Compliance with the law
However, ultimately it is your choice as to whether you wish to use our website.
We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.