Restore Reflexology: Privacy and Consent Notice
This notice refers to personal data, which is defined as information concerning any individual (or Data Subject) that is not already in the public domain.
The General Data Protection Regulation (GDPR) which is EU wide and far more extensive than its predecessor the Data Protection Act, along with the Privacy and Electronic Communications Regulations (PECR), seek to protect and enhance the rights of EU data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU and its storage within the EEA. This comes into effect 25 May 2018.
Name and Contact Details
32 Lea Road, Harpenden, Hertfordshire, AL5 4PG
Email: email@example.com Tel: 07495 462 278
Who is Restore Reflexology?
Restore Reflexology provides Reflexology Treatments. Treatments are carried out in accordance with the Association of Reflexology’s Code of Conduct.
a) For the purposes of providing treatment, Restore Reflexology may require detailed medical information. I will only collect what is relevant and necessary for your treatment. When you visit the practice, I will make notes which may include details concerning your medication, treatment and other issues affecting your health. This data is always held securely, is not shared with anyone not involved in your treatment. To be able to process your personal data it is a condition of any treatment that you give your explicit consent to allow Restore Reflexology to document and process your personal medical data. Contact details provided by you such as telephone numbers, email addresses, postal addresses may be used to remind you of future appointments and provide reports or other information concerning your treatment.
b) For marketing purposes, Restore Reflexology may also use the contact details provided by you to respond to your enquiries, including making telephone contact and emailing information to you which the practice believes may be of interest to you.
c) In making initial contact with the practice you consent to Restore Reflexology maintaining a marketing dialogue with you until you either opt out (which you can do at any time) or I decide to desist in promoting Restore Reflexology’s services. Restore Reflexology do not broker your data and you can ask to be removed from our marketing database by emailing or phoning the practice using the contact details provided at the end of this Privacy Notice.
d) Some basic personal data may be collected about you from the marketing forms and surveys you complete, from records of our correspondence and phone calls and details of your visits to our website, including but not limited to, personally identifying information like Internet Protocol (IP) addresses.
f) Restore Reflexology will only collect the information needed so that I can provide you with the services you require, the business does not sell or broker your data.
Legal basis for processing any personal data
To meet our contractual obligations obtained from Client Consent and legitimate interest to respond to enquiries concerning the services provided.
Legitimate interests pursued by Restore Reflexology
To promote treatments for clients with all types of health problems including back pain and neck pain, tennis elbow, frozen shoulders, sciatica, headaches, sports injuries, and other degenerative conditions (to be used alongside traditional allopathic healthcare and not as a substitute) in addition to promoting treatments that promote sleep, relaxation and a sense of well-being.
Through agreeing to this privacy notice you are consenting to Restore Reflexology processing your personal data for the purposes outlined. You can withdraw consent at any time by using the postal, email address or telephone number provided at the end of this Privacy Notice.
Restore Reflexology will keep your personal information safe and secure, only I will have access to your client record. Restore Reflexology will not disclose your Personal Information unless compelled to, in order to meet legal obligations, regulations or valid governmental requests. The practice may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of its staff.
Restore Reflexology will process personal data during the duration of any treatment and will continue to store only the personal data needed for eight years after the contract has expired to meet any legal obligations. After eight years all personal data will be deleted, unless basic information needs to be retained by us to meet our future obligations to you, such as erasure details. Records concerning minors who have received treatment will be retained until the child has reached the age of 25.
All Data is held in the United Kingdom, with the exception of customer emails stored on Mailchimp (for the purposes of sending out newsletters and marketing offers) which has achieved GDPR compliancy under the EU-US Privacy Shield. Subscribers are able to manage their subscription preferences and can additionally contact Restore Reflexology to unsubscribe at any point.
Your rights as a data subject
At any point whilst Restore Reflexology are in possession of, or processing your personal data, all data subjects have the following rights:
Right of access – you have the right to request a copy of the information that we hold about you.
Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.
Right of portability – you have the right to have the data we hold about you transferred to another organisation.
Right to object – you have the right to object to certain types of processing such as direct marketing.
Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.
In the event that Restore Reflexology refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge. At your request Restore Reflexology can confirm what information it holds about you and how it is processed.
You can request the following information:
Identity and the contact details of the person or organisation (Restore Reflexology) that has determined how and why to process your data.
Contact details of the data protection officer, where applicable.
The purpose of the processing as well as the legal basis for processing.
If the processing is based on the legitimate interests of Restore Reflexology and information about these interests.
The categories of personal data collected, stored and processed.
Recipient(s) or categories of recipients that the data is/will be disclosed to.
How long the data will be stored.
Details of your rights to correct, erasure, restrict or object to such processing.
Information about your right to withdraw consent at any time.
How to lodge a complaint with the supervisory authority (ICO).
Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
The source of personal data if it wasn’t collected directly from you.
Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
Restore Reflexology's rights
If you don’t agree to me (your therapist) keeping records of information about you and your treatments, or if you don’t allow me to use the information in the way I need to for treatments, I may not be able to treat you.
I have to keep your records of treatment for a certain period as described above, which may mean that even if you ask me to erase any details about you, I might have to keep these details until after that period has passed.
I can move your records between computers and IT systems, as long as your details are protected from being seen by others without your permission.
In the event that you wish to make a complaint about how your personal data is being processed by Restore Reflexology you have the right to complain to us. If you do not get a response within 30 days, you can complain to the ICO. The details for each of these contacts are:
Jacqui Brabin, Restore Reflexology, 32 Lea Road, Harpenden, Hertfordshire, AL5 4PG
Telephone: 07495 462278 or email firstname.lastname@example.org