Data Protection Policy

GDPR 2018 Privacy Notice

Scope

This document refers to personal data, which is defined as information concerning any living person (a natural person who hereafter will be called the 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.

1 – East Sussex Massage, based at Saltley Farm, South Lane, East Sussex TN21 9NN and 26 Tower Street, Heathfield, TN21 8PB which hereafter for the purposes of this Privacy Notice will be referred to as East Sussex Massage, is pleased to provide the following information:

2 – Who we are
East Sussex Massage assess and treat your symptoms. Treatments are carried out in accordance with the Sports Massage  Association and other relevant associations. The practice also provides other treatments, about which we will be pleased to provide more details.

3 – Personal Data
a) For the purposes of providing treatment, East Sussex Massage may require detailed medical information. We will only collect what is relevant and necessary for your treatment. When you visit our practice, we 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, although for data storage purposes it may be handled by pre-vetted staff who have all signed an integrity and confidentiality agreement. To be able to process your personal data it is a condition of any treatment that you give your explicit consent to allow the clinic 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. As part of our obligations as alternative healthcare therapists there may be circumstances related to your treatment, on-going care or medical diagnosis that will require the sharing of your medical records with other healthcare practitioners e.g. GPs, consultants, surgeons and/or medical insurance companies. Where this is required we will always inform you first unless we are under a legal obligation to comply.
b) For marketing purposes, the East Sussex Massage 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 East Sussex Massage maintaining a marketing dialogue with you until you either opt out (which you can do at any time) or we decide to desist in promoting our services. East Sussex Massage may occasionally also act on behalf of its patients in the capacity of data processor, when we may promote other practitioners based at our premises, who work alongside us. East Sussex Massage 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.
e) East Sussex Massage’s website uses cookies, which is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. WordPress.org uses cookies to help East Sussex Massage to identify and track visitors and their website access preferences. East Sussex Massage website visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using East Sussex Massage’s website.
f) The clinic will only collect the information needed so that we can provide you with the services you require, the business does not sell or broker your data.

4 – Legal basis for processing any personal data
To meet our contractual obligations obtained from explicit Patient Consent and legitimate interest to respond to enquiries concerning the services provided.

5 – Legitimate interests pursued by East Sussex Massage
To promote treatments for patients with all types of health problems indicated for treatment.

6 – Consent
Through agreeing to this privacy notice you are consenting to East Sussex Massage 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.

7 – Disclosure
East Sussex Massage will keep your personal information safe and secure, only staff engaged in providing your treatment will have access to your patient records, although our administration team will have access to your contact details so that they can make appointments and manage your account. East Sussex Massage will not disclose your Personal Information unless compelled to, in order to meet legal obligations, regulations or valid governmental requests. East Sussex Massage 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.

8 – Retention Policy
East Sussex Massage will process personal data during the duration of any treatment and will continue to store only the personal data needed for seven years after the contract has expired to meet any legal obligations. After seven 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 21.

9 – Data storage
All Data is held in the United Kingdom. East Sussex Massage does not store personal data outside the EEA. Information is stored alphabetically as paper notes in locked filing cabinets at the clinic premises. If a home visit is conducted they stay with the therapist at all times, until returned to the locked filing cabinet at the end of the day. Archived notes are stored in the same place for access. In the event of clinic closure or death of the data processor, the following arrangements are in place for patient’s to access their records: Upon patients written requests, other colleges/present receptionist or the East Sussex Massage data controller’s daughter: Chantal Prince (Osteopath) will have access to the filing cabinets and data.

In the event of East Sussex Massage being sold the future owner will have the legal duty to comply with this data protection policy.

Any photos taken on password protected clinic software, will be deleted once their course of treatment has been conducted and patient’s progress has been shown to the patient and documented in their patient records, unless written permission by the patient is provided for their use in promotion and advertising for East Sussex Massage.

10 – Your rights as a data subject
At any point whilst East Sussex Massage are in possession of, or processing your personal data, all data subjects have the following rights:

In the event that East Sussex Massage refusing 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 East Sussex Massage can confirm what information it holds about you and how it is processed.

11 – You can request the following information:

12 – To access what personal data is held, identification will be required
East Sussex Massage will accept the following forms of identification (ID) when information on your personal data is requested: a copy of your driving licence, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If East Sussex Massage is dissatisfied with the quality, further information may be sought before personal data can be released. All requests should be made to eastussexmassage@yahoo.co.uk or by phoning +44 (0)7762 576 495 or writing to us at the address further below.

13 Complaints
In the event that you wish to make a complaint about how your personal data is being processed by East Sussex Massage 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:

Sarahjane Prince

East Sussex Massage

Telephone 07762 576 495         or email: info@eastsussexmassage.co.uk

ICO
Wycliffe House, Water Lane, Wilmslow, SK9 5AF Telephone +44 (0) 303 123 1113 or email: https://ico.org.uk/global/contact-us/email/