GDPR is bringing in new legal protection for personal information from May 2018. I am committed to ensuring that your privacy is protected and this privacy notice tells you what personal information I hold and why, and what your rights are. It sets out how I collect, use and protect any personal data you provide to me via email, sms, telephone and treatment consultation form in relation to reflexology sessions.
I will require you to sign a declaration to confirm that you understand and accept what is outlined in this document at your first session with me.

How to contact Undo:
Holly Moore
07592 569 063
Data Controller: Holly Moore

This privacy policy is effective as of 18th May 2018

The Purpose of Processing Client Data

In order to give professional reflexology treatments, I will need to gather and retain potentially sensitive information about your health. I will only use this information for informing reflexology treatments and associated recommendations concerning aspects of health and wellbeing which I will offer to you. If you get in touch with me via email, sms or telephone to make a booking I will retain your contact details in order to contact you and handle bookings.

Lawful Basis for holding and using Client Information

As a full member of the Association of Reflexologists (AoR) and a registered provider with the Complementary and Natural Healthcare Council (CNHC) I abide by the Code of Practice and Ethics for both of these organisations. 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 and CNHC Confidentiality as defined in their Code of Practice and Ethics.

What information I hold and what I do with it

In order to give professional reflexology treatments, I will need to ask for and keep information about your health. I will only use this for informing reflexology treatments and any advice I give as a result of your treatment. The information to be held is:

    - Your contact details, including your address for home visit treatments
    - 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 (other than as required for legal process) without explaining why it is necessary, and getting your explicit consent.

How Long I Retain Your Information for

I will keep your information for the following periods:

    - ‘claims occurring’ insurance: records are to be kept for 7 years after last treatment.
    - law regarding children’s records: records are to be kept until the child is 25 years old or if 17 years old when treated, then kept until they are 26 years old.
    - registration with the Complementary and Natural Healthcare Council: requires information to be retained for 8 years after last treatment.

I will not transfer your data outside the EU without your consent, though I would like to make you aware of the third party services I use as part of my business.

Email: I use G-Suite powered by Google, which is based outside the UK. However G-Suite is committed to complying with privacy laws, including GDPR and should you wish to you can read more about their privacy policy here.

Website: My website is provided by Squarespace, which is based outside the UK. However Squarespace is also committed to complying with GDPR privacy laws and you can read their privacy policy here.

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 we 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:

    - The right to be informed:
    - To know how your information will be held and used (this notice).
    - The right of access:
    - To see your therapist’s records of your 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 (also called “the right to be forgotten”):
    - For you to request your therapist to 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 you don’t want them to use certain parts of your information, or only to use it for certain purposes.
    - Rights in relation to automated decision-making and profiling.
    - The right 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 on the ICO’s website, which you can see by clicking here.

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 Right

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.

If you contact me via email to arrange an appointment I will send you a copy of this document for your records. At our first treatment I will then require a signed declaration on a hard copy of the document to confirm that you have seen and accepted my privacy statement and understand your rights under the GDPR.