1. What I do
I provide lessons in the Alexander Technique.
2. How I Obtain Your Personal Data
Information provided by you
You provide me with personal data in the following ways:
- By completing a personal details form
- Through email, telephone or post
- By taking payment
This may include the following information:
- Basic details such as name, address, and contact details
- Details of contact I have had with you such as referrals and appointment requests
- Basic health information including any relevant previous medical history
- Bank details
I use this information in order to provide you with Alexander Technique lessons. This means that the legal basis of my holding your personal data is for legitimate interest.
Following completion of your lessons I will retain your personal data for the period defined by my professional association STAT and registrant body, CNHC. This enables me to process any complaint you may make. In this case the legal basis of my holding your personal data is for contract administration.
3. How I Use Your Personal Data
I act as a data controller for use of your personal data to provide Alexander Technique lessons. I act as a data controller and processor in regard to the processing of credit cards and online payments.
I undertake at all times to protect your personal data, including any health and contact details, in a manner which is consistent with my duty of professional confidence and the requirements of the General Data Protection Regulation (GDPR) concerning data protection. I will also take reasonable security measures to protect your personal data storage.
I may use your personal data where there is an overriding public interest in using the information e.g., in order to safeguard an individual, or to prevent a serious crime; also where there is a legal requirement such as a formal court order.
4. Do I Share Your Information With Other Organisations?
I will keep information about you confidential. I will only disclose your information with other third parties with your express consent with the exception of the following categories of third parties:
- My registrant body, CNHC, and professional association, STAT, for the processing of a complaint made by you.
- Anyone to whom I may transfer my rights and duties under any agreement I have with you
- Any legal or crime prevention agencies and /or to satisfy and regulatory request e.g., CNHC, if I have a duty to do so or if the law allows me to do so.
5. What are Your Rights?
Every individual has a right to see, amend, delete or have a copy, of data held that can identify you, with some exceptions. You do not need to give a reason to see your data.
If you want to access your data you must make a subject access request in writing to me at email@example.com. Under special circumstances some information may be withheld. I shall respond within 20 working days from the point of receiving the request and all necessary information from you. My response will include the details of the personal data I hold on you including:
- Sources from which I acquired the information
- The purpose of processing the information
- Persons or entities with whom I am sharing the information
You have the right, subject to exemptions, to ask to:
- Have your information deleted
- Have your information corrected or updated where it is no longer accurate
- Ask me to stop processing information about you where I am not required to do so by law or in accordance with STAT and CNHC guidelines
- Receive a copy of your personal data, which you have provided to me, in a structured, commonly used and machine readable format and have the right to transmit that data to another controller, without hindrance from me.
- Object at any time to the processing of personal data concerning you
I do not carry out any automated processing, which may lead to automated decision based on your personal data.
If you would like to invoke any of the above rights then please write to me at the following address – 1 Beattock Rise, Muswell Hill, London, N10 3DS, or email firstname.lastname@example.org.
6. What Safeguards Are in Place To Ensure Data That Identifies Me Is Secure?
I only use information that may identify you in accordance with GDPR. This requires me to process personal data only if there is a legitimate basis for doing so and that any processing must be fair and lawful.
Within the health sector, we also have to follow the common law duty of confidence, which means that where identifiable information about you has been given in confidence, it should be treated as confidential and only shared for the purpose of providing direct healthcare. I will protect your information, inform you of how your information will be used, and allow you to decide if and how your information can be shared.
I will also ensure the information I hold is kept in secure locations, restrict access to information to authorised personnel only, protect personal and confidential information held on equipment such as laptops with encryption (which masks data so that unauthorised users cannot see or make sense of it). I will ensure external data processors that support me are legally and contractually bound to operate and prove security arrangements are in place where data that could or does identify a person are processed.
I am registered with the Information Commissioners Office (ICO) as a data controller and collects data for a variety of purposes. A copy of the registration is available through the IOC website.
7. How Long Do You Hold Confidential Information For?
All records held by my practice will be kept for the duration specified by guidance from my professional association, STAT.
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If you have a complaint regarding the use of your personal data then please contact me by writing to me at 1 Beattock Rise, London N10 3DS, or emailing email@example.com and I will do my best to assist you.
If your complaint is not resolved to your satisfaction and you wish to make a formal complaint to the Information Commissioner’s Office you can contact them on 01625 545745 or 0303 1231113.
Data Protection Policy
1.1 Purpose of Policy
1.2 I need to gather and use certain information about individuals.These can include clients, suppliers, employees and other people the organisation has a relationship with or may need to contact.
This policy describes how this personal data will be collected, handled and stored to comply with the General Data Protection Regulation.
1.3 Policy StatementI am committed to a policy of protecting the rights and privacy of clients and others in accordance with General Data Protection Regulation.
I am committed to:
- comply with both the law and good practice
- respect individuals’ rights
- be open and honest with individuals whose data is held
- register my details with the Information Commissioner’s Office (ICO)
1.4 Personal DataI may hold data for the following purposes:
- Provision of direct healthcare
- Marketing and newsletters
1.5 Data Protection PrinciplesThere are six data protection principles that are core to the General Data Protection Regulation. I will make every possible effort to comply with these principles at all times in our information-handling practices. The principles are:
1) Lawful, fair and transparentData collection must be fair, for a legal purpose and I must be open and transparent as to how the data will be used.
2) Limited for its purposeData can only be collected for a specific purpose.
3) Data minimisationAny data collected must be necessary and not excessive for its purpose.
4) AccurateThe data I hold must be accurate and kept up to date.
5) RetentionI cannot store data longer than necessary.
6) Integrity and confidentialityThe data I hold must be kept safe and secure.
1.6 Key risks
The main risks are in two key areas:
- information about individuals getting into the wrong hands, through poor security or inappropriate disclosure of information
- individuals being harmed through data being inaccurate or insufficient
2 ResponsibilitiesI am the data controller for all personal data held by me and am responsible for:
- Analysing and documenting the type of personal data I hold
- Checking procedures to ensure they cover all the rights of the individual
- Identifying the lawful basis for processing data
- Ensuring consent procedures are lawful
- Implementing and reviewing procedures to detect, report and investigate personal data breaches
- Storing data in safe and secure ways
- Assessing the risk that could be posed to individual rights and freedoms should data be compromised
3 Data Recording, Security and Storage
3.1 Data accuracy and relevanceI will ensure that any personal data I process is accurate, adequate, relevant and not excessive, given the purpose for which it was obtained. I will not process personal data obtained for one purpose for any unconnected purpose unless the individual concerned has agreed to this or would otherwise reasonably expect this.
3.2 Data securityI will keep personal data secure against loss or misuse. Where other organisations process personal data as a service on my behalf, I will establish what, if any, additional specific data security arrangements need to be implemented in contracts with those third-party organisations.
3.3 Storing data securely
- In cases when data is stored on printed paper, it will be kept in a secure place where unauthorised personnel cannot access it
- Printed data will be shredded when it is no longer needed
- Data stored on a computer will be protected by strong passwords that are changed regularly. A password manager will be used to create and store passwords.
- Data stored on CDs or memory sticks will be encrypted or password protected and locked away securely when they are not being used
- Cloud services used to store personal data will be assessed for compliance with GDPR principles. An authenticator app will be used to access cloud data.
- Data will be regularly backed up.
- All servers containing sensitive data must be protected by security software
- All possible technical measures will be put in place to keep data secure
3.4 Data retentionI will retain personal data for no longer than is necessary. This shall be in accordance with the guidelines of my professional association, BANT.
4 Accountability and TransparencyI will ensure accountability and transparency in all our use of personal data. I will keep written up-to-date records of all the data processing activities that I do and ensure that they comply with each of the GDPR principles.
I will regularly review our data processing activities and implement measures to ensure privacy by design including data minimisation, pseudonymisation, transparency and continuously improving security and enhanced privacy procedures.
5 ConsentI will ensure that consents are specific, informed and plain English such that individuals clearly understand why their information will be collected, who it will be shared with, and the possible consequences of them agreeing or refusing the proposed use of the data. Consents will be granular to provide choice as to which data will be collected and for what purpose. I will seek explicit consent wherever possible.
I will maintain an audit trail of consent by documenting details of consent received including who consented, when, how, what, if and when they withdraw consent. For online consent, I may use a cryptographic hash function to support data integrity. Alternatively I will maintain the consents information in a spreadsheet with links to the consent forms.
I will regularly review consents and seek to refresh them regularly or if anything changes.
6 Direct MarketingI will comply with both data protection law and Privacy and Electronic Communication Regulations 2003 (PECR) when sending electronic marketing messages. PECR restricts the circumstances in which I can market people and other organisations by phone, text, email or other electronic means.
I will seek explicit consent for direct marketing. I will provide a simple way to opt out of marketing messages and be able to respond to any complaints.
7 Subject Access Requests
7.1 What is a subject access request?An individual has the right to receive confirmation that their data is being processed, access to their personal data and supplementary information which means the information which should be provided in a privacy notice.
7.2 How to deal with subject access requestsI will provide an individual with a copy of the information requested, free of charge. This will occur within one month of receipt. I will endeavour to provide data subjects access to their information in commonly used electronic formats (as described in section 4.3).
If complying with the request is complex or numerous, the deadline can be extended by two months, but the individual will be informed within one month.
I can refuse to respond to certain requests, and can, in circumstances of the request being manifestly unfounded or excessive, charge a fee. If the request is for a large quantity of data, I can request the individual specify the information they are requesting.
Once a subject access request has been made, I will not change or amend any of the data that has been requested. Doing so is a criminal offence.
7.3 Data portability requestsI will provide the data requested in a structured, commonly used and machine-readable format. This would normally be a PDF file, although other formats are acceptable. I must provide this data either to the individual who has requested it, or to the data controller they have requested it be sent to within one month.
8 Transferring data internationallyThere are restrictions on international transfers of personal data. I will not transfer personal data abroad without express consent.
9 Third Parties
9.1 Using third party controllers and processorsAs a data controller and/or data processor, I will have written contracts in place with any third-party data controllers (and/or) data processors that I use. The contract will contain specific clauses which set out our and their liabilities, obligations and responsibilities.
As a data controller, I will only appoint processors who can provide sufficient guarantees under GDPR and that the rights of data subjects will be respected and protected.
As a data processor, I will only act on the documented instructions of a controller. I acknowledge my responsibilities as a data processor under GDPR and will protect and respect the rights of data subjects.