The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).
Data controller – A controller determines the purposes and means of processing personal data.
Data processor – A processor is responsible for processing personal data on behalf of a controller.
Data subject – Natural person – i.e the consumer, website visitor, customer or client (you)
Categories of data – Personal data and special categories of personal data
Personal data – The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example, name, passport number, home address or private email address – this is information that you are likely to give to us via an online or offline form. Online information that you might share with us can be tracked by some software – identifiers include IP addresses confirming your geographical location, and cookies for example.
Special categories personal data – The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.
Processing – means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Third party – means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
2. Who are we?
HHWS is the data controller and our nominated contact is Seema Bhattessa. This means we decide how your personal data is processed and for what purposes. You can contact us by email at: firstname.lastname@example.org
The purpose(s) of processing your personal data
We may use your personal data, but only if you have provided it to us, for the following purposes:
Contacting you to check you are still interested in hearing from us and that your data record is correct
Contacting you to let you know about new services and special offers
Contacting you following a treatment to check how you have responded to treatment
Contacting you to confirm or amend your appointment date and time
Contacting you prior to a treatment to discuss suitability
3. The categories of personal data concerned
With reference to the categories of personal data described in the definitions section, we process the following categories of your data:
Personal data – name, phone number, address, email, date of birth
Special categories of data – in order to provide safe and appropriate treatments, we will ask you for information relating to your health and medical history which may include height, weight and reference to illnesses or disabilities and information about your lifestyle choices e.g. diet, and your occupation. This data will be stored in a locked cabinet for reference only during treatments. We will also ask for details of your GP in case of emergency. We will also gather information about your animals, if you are receiving an animal related service. This may include species, breed, height and weight as well as veterinary details and medical history.
We have obtained your personal data from:
Your completion of the enquiry form online, a message sent to us via social media or email, and telephone conversation or message, or, completion of the newsletter sign-up box online. Your therapist will also ask you to complete a treatment for prior to your appointment.
What is our legal basis for processing your personal data?
Our lawful basis for processing your general personal data:
Contractual basis – we are obliged to keep a record of the information you have provided to us to decide whether treatment is right for you and where you have signed to give your consent to treatment and use of treatment products. We must also keep a record of transactions for HMRC.
Legitimate interest – you have made us aware that you are interested in our services.
Lawful consent – you have given us permission to contact you and you can retract this consent at any time. We will keep your details for 7 years before contacting you to update them or remind you that you have the option to remove them. In the case of children and young adults, data will be kept until the subject is 25 years old.
4. Storing and sharing your personal data
Your personal data will be treated as strictly confidential and will be shared only with medical professionals in the case of an emergency or with the police where UK Law dictates our obligation.
We use secure sharing software including: Gmail and Google Drive and on our website, which is protected with an SSL certificate. Data about you and/or your animal(s) is kept on a secure cloud based system on a password locked home computer with up to date virus and malware protection software. This information can be accessed on portable devices such as mobile phones, tablet or laptop, which are all locked when not in use and password protected by relevant anti-virus software.
Some data such as phone numbers are kept on a mobile phone used for personal and business use. Basic contact details are written in a paper day book to allow visits to take place.
Payments are usually by credit/debit card or cash. We do not store client bank account numbers or credit/debit card numbers.
5. How long we keep your personal data
We keep your personal data for no longer than reasonably necessary for a period of 7 years after your last treatment or last enquiry to ensure continuity of treatment.
6. Providing us with your personal data
We require your contact details: name, phone number and address as well as your health information to ensure it is safe to perform treatments on you and so that we can make you aware of any changes to guidelines following receipt of a treatment.
7. Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
The right to request a copy of the personal data which we hold about you;
The right to request that we 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 to retain such data;
The right to withdraw your consent to the processing at any time, where consent was your lawful basis for processing the data;
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 i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes 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 i.e. 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).
To access what personal data is held, identification will be required. We will accept the following forms of identification (ID) when information on your personal data is requested: a copy of your driving license, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required.
8. Transfer of Data Abroad
We use Google Analytics at the top level to track how many users we have on our website but we do not look at any data relating to individual users and cannot identify you from these reports. We also use Gmail as an email service to send and receive email. The Google statement on GDPR is shown via this link: https://privacy.google.com/businesses/compliance/#?modal_active=none
9. Automated Decision Making
We do not use automated decision making.
10. Further processing
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we 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.
12. How to make a complaint
To exercise all relevant rights, queries and complaints please in the first instance contact me, Seema Bhattessa (email@example.com) - Business Owner and Data Processor
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on – 03031231113 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, England.