Gillian Board Privacy Statement for Foot Health Practice and Reflexology Businesses (updated 14/06/20). Reference no: A8396317
This is a copy of my Privacy Statement which you will be asked to read and sign prior to your first treatment
“The General Data Protection Regulation (GDPR) is a legal framework that sets guidelines for the collection and processing of personal information of individuals within the European Union (EU)” (https://www.investopedia.com). It took effect from 25th May 2018. This statement tells you what personal information I hold and why, and what your rights are. I will review this policy annually to ensure that I am following any changes to data protection regulations.
Use of your personal data
Personal and health information is obtained from the Patient/Client at the first and subsequent treatments. For reflexology using a hard copy health consultation questionnaire and subsequent treatment sheet. For foot treatments, at each appointment, information of current issues and treatment received, is recorded on the Patients' treatment card.The purposes for doing this is to produce personal treatment plans for that person, which may require changes along the way. This includes any associated recommendations concerning aspects of health and wellbeing which I will offer to you.
Photographs may be taken of the feet (hands if undertaking hand reflexology) to record visual observations for the purposes of customising a treatment. These are taken on an electronic device (Tablet or smartphone), and later deleted once I have replicated the observations onto your treatment paperwork.
Telephone numbers may be stored on a smartphone and Emails may be sent to and received from Patients/Clients; if consent to do that has been obtained from the Patient/Client beforehand.
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. 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.
In order to give professional foot and reflexology treatments, I will need to ask for and keep information about your health. I will only use this for informing treatments and any advice I give as a result of your treatment. Information to be held is:
Your contact details
Medical history and other health-related information
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 first explaining why it is necessary, and getting your explicit consent.
How long I Retain Your Information for
I am obliged to keep your personal data for 7 years following the last occasion on which treatment was given (because of “claims occurring” insurance). In the case of Children, records must be kept until the Child is 25 years of age, or if 17 years when treated then kept until they are 26.
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 I collect from you.
I will contact you using the contact preferences you give me in relation to:
-Treatment information and information related to your health
The right to be informed (To know how your information will be held and used)
The right of access (To see therapist records of you 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 (For you to request that your Therapist 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 that you don’t want them to use certain parts of your information, or only use it for certain purposes)
Rights in relation to automated decision-making and profiling
The right to lodge a complaint with the ICO (Information Commissioners’ 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-data-protection/
If you wish to exercise any of these rights, please use the contact details given above. If you are dissatisfied with the response you can complain to the Information Commissioner’s Office; their contact details are at www.ico.org.uk
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 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.
I have seen this document and understand that you will hold and use my personal information, using it in order to provide me with the best possible treatment options and advice in line with the statements above.
I have received a copy of this document.
Note: for children under 16 years of age, a parental/guardian signature is required.
(Updated 14 June 2020)