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 – Body Mind Therapies, based at 39 Rushdene Avenue, Barnet, Herts, EN4 8EN, which hereafter for the purposes of this Privacy Notice will be referred to as Body Mind Therapies, is pleased to provide the following information:
2 – Who we are
The Osteopaths diagnose and treat health conditions. Treatments are carried out in accordance with the Institute of Osteopathy’s patient charter http://www.iosteopathy.org/osteopathy/the-patient-charter/. The practice also provides other treatments:
- Hypnotherapy
- Sound Therapy
- Yoga classes
3 – Personal Data
a) For the purposes of providing treatment, Body Mind Therapies may require detailed medical information. We will only collect what is relevant and necessary for your treatment.
Before you attend our practice, we may send to you a google form to fill asking you some details about your name, your address, your date of birth, your telephone number(s), your email address, emergency contact details, the name of the person who referred you. You may also be asked about your past medical history, including previous musculo-skeletal injury and self-medication, the name of your GP or medical practice you attend and their address. This will be send to the following email address: bodymindtherapies.expert@gmail.com. Once this information is received it is entered in the software Cliniko, which is a clinical software that is compliant with GDPR.
When you visit our practice, we will make further notes regarding your medical history, your medications, blood tests, imaging, other investigations, and other details concerning your 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 Osteopaths 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 primary healthcare practitioners 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, Body Mind Therapies 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 Body Mind Therapies 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. Body Mind Therapies 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 may not be employed by us. Body Mind Therapies 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) Body Mind Therapies’ 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 Osteopaths to identify and track visitors and their website access preferences. Osteopaths’ website visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using Osteopaths’ website.
f) Body Mind Therapies 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 Body Mind Therapies
To promote treatments for patients with all types of health problems indicated for osteopathic care.
6 – Consent
Through agreeing to this privacy notice you are consenting to Body Mind Therapies 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
Body Mind Therapies 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. Osteopaths will not disclose your Personal Information unless compelled to, in order to meet legal obligations, regulations or valid governmental requests. The practice 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
Body Mind Therapies will process personal data during the duration of any treatment and will continue to store only the personal data needed for eight years after the contract has expired to meet any legal obligations. After eight 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 25.
9 – Data storage
All Data is held in the United Kingdom. Body Mind Therapies does not store personal data outside the EEA.
Patient records are stored on Cliniko, a cloud based solution located in Australia. Cliniko has signed a contract with this practice to protect patient data subject rights in accordance with GDPR.
10 – Your rights as a data subject
At any point whilst Body Mind Therapies are in possession of, or processing your personal data, all data subjects have the following rights:
- Right of access – you have the right to request a copy of the information that we hold about you.
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
- Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.
- Right of portability – you have the right to have the data we hold about you transferred to another organisation.
- Right to object – you have the right to object to certain types of processing such as direct marketing.
- Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.
In the event that Body Mind Therapies refuses 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 Body Mind Therapies can confirm what information it holds about you and how it is processed.
11 – You can request the following information:
- Identity and the contact details of the person or organisation (Osteopaths) that has determined how and why to process your data.
- Contact details of the data protection officer, where applicable.
- The purpose of the processing as well as the legal basis for processing.
- If the processing is based on the legitimate interests of Osteopaths and information about these interests.
- The categories of personal data collected, stored and processed.
- Recipient(s) or categories of recipients that the data is/will be disclosed to.
- How long the data will be stored.
- Details of your rights to correct, erasure, restrict or object to such processing.
- Information about your right to withdraw consent at any time.
- How to lodge a complaint with the supervisory authority (ICO).
- Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
- The source of personal data if it wasn’t collected directly from you.
- Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
12 – To access what personal data is held, identification will be required
Body Mind Therapies 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 Body Mind Therapies is dissatisfied with the quality, further information may be sought before personal data can be released. All requests should be made to sabine@bodymindtherapies.expert or s.osteopath@gmail.com or by phoning +44 (0) 7545786607 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 Body Mind Therapies 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:
Sabine Audibert at Body Mind Therapies
Telephone: 07545786607or email: sabine@bodymindtherapies.expert
ICO
Wycliffe House, Water Lane, Wilmslow, SK9 5AF Telephone +44 (0) 303 123 1113 or email: https://ico.org.uk/global/contact-us/email/
Contact forms Website Body Mind Therapies
When we collect information via contact forms, this information is sent to us through a secure email server and in Mailchimp. We collect this data to book appointments and send out marketing emails, if you have opted in to receive such.
Cookies Website Body Mind Therapies
If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
Embedded content from other websites
Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.
Analytics Website Body Mind Therapies
We collect anonymous usage data using Google Analytics. This is so we can continually assess the content on the website and use it to make improvements to the user experience where necessary.
How long we retain your data Website Body Mind Therapies
If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognise and approve any follow-up comments automatically instead of holding them in a moderation queue.
For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.
What rights you have over your data Website Body Mind Therapies
If you have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.
Where we send your data Website Body Mind Therapies
Visitor comments may be checked through an automated spam detection service. Any information collected via signup forms or contact forms are stored in MailChimp.
Additional information Website Body Mind Therapies
How we protect your data
We protect your data using a secure email server and in Mailchimp, using two-factor authentication.
What data breach procedures we have in place Website Body Mind Therapies
We will always protect your data with secure passwords and, if possible, using two-factor authentication. If there is a data breach, we will advise the ICO as is required by European law.
Changes to this Privacy Policy Website Body Mind Therapies
We reserve the right to modify this privacy policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the website. If we make material changes to this policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.
If our store is acquired or merged with another company, your information may be transferred to the new owners so that we may continue to sell products to you.
Questions or Complaints Website Body Mind Therapies
In the event that you wish to make a complaint about how your personal data is being processed by Body Mind Therapies 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:
Sabine Audibert at Body Mind Therapies
Telephone: 07545786607or email: sabine@bodymindtherapies.expert
ICO
Wycliffe House, Water Lane, Wilmslow, SK9 5AF Telephone +44 (0) 303 123 1113 or email: https://ico.org.uk/global/contact-us/email/