The purpose of processing Client Data

In order to give professional holistic treatments, I will need to gather and retain potentially sensitive information about your health. I will only use this information for informing treatments and associated recommendations concerning aspects of health and wellbeing which I will offer to you.

Data Controller Contact Details: Emma Jayne Eversden

Lawful Basis for holding and using Client Information

As a full member of both the Association of Reflexologists (AOR) and the Massage Training Institute (MTI) I abide by their respective Codes of Practice and Ethics. The lawful basis under which I hold and use your information is Contract and Legitimate Interest:

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: contract for me to fulfil my role as a health care practitioner bound under the AoR/MTI Confidentiality as defined in the AoR and MTI Code of Practice and Ethics.

1. We need to collect personal information about your health in order to provide you with the best possible treatment. Your requesting treatment and our agreement to provide that care constitutes a contract. You can of course refuse to provide the information but if you were to do that I would not be able to provide treatment. Health information is considered under the GDPR as a ‘Special Category Data’ condition (h) and we are collecting, processing and storing your information under this condition.
2. We have a ‘Legitimate Interest’ in collecting that information because without it, I couldn’t’ do my job effectively and safely.
3. We also think that it is important that we can contact you in order to confirm your appointments with us or to update you on matters related to your medical care. This again constitutes ‘Legitimate Interest’ but this time it is your legitimate interest.
4. Your information will be kept as a condition for insurance for 7 years from the date of your last treatment. Children’s records are kept until the child is 26.

What information I hold and what I do with it

In order to give professional holistic treatments, I will need to ask for and keep relevant information about your health and wellbeing. I will only use this for informing treatments and any advice I give as a result of your treatment. The information to be held is: • Your contact details (to inform you of changes to your appointments) • Medical history and other health-related information (which I will take from you at first consultation) • Treatment details and related notes (which I will take after each consultation)

I will NOT share your information with anyone else (unless required for legal process) without explaining why it is necessary and, getting your explicit consent.

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: • Appointment times • Reflexology information or information related to your health • Special offers and promotions (you may unsubscribe from this at any time).

Your Rights. GDPR gives you the following rights:

• To be informed: To know how your information will be held and used (this notice).
• Of access: To see your therapist’s records of your personal information, so you know what is held about you and can verify it.
• To rectification: To tell your therapist to make changes to your personal information if it is incorrect or incomplete.
• To erasure (also called “the right to be forgotten”): For you to request your therapist to erase any information they hold about you.
• To restrict processing of personal data:You have the right to request limits on how your therapist uses your personal information.
• To data portability: under certain circumstances you can request a copy of personal information held electronically so you can reuse it in other systems.
• To object: To be able to tell your therapist you don’t want them to use certain parts of your information, or only to use it for certain purposes.
• To lodge a complaint with the Information Commissioner’s 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-the-general-data-protection-regulation-gdpr/individual-rights/.

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

Therapist's Rights

Please note:
* 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 them 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.