The processing of personal data is governed by the General Data Protection Regulation 2016/679 (the GDPR). This legislation will replace current data privacy law, giving more rights to you as an individual and more obligations to organisations holding your personal data.
Who am I?
Lindsay Fieldhouse is the data controller for Halo Acupuncture Clinic. This means I decide how your personal data is processed and for what purposes.
Whose information does this privacy notice apply to?
This privacy notice applies to information I collect from:
· prospective clients;
· former clients;
· visitors to the website;
What is personal data?
Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. Examples of personal data I may hold about you include your contact and appointment details.
Special category data is a sub-category of personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. Examples of special category data I may hold about you include your patient notes.
How do I process your personal data?
I comply with my obligation under the GDPR by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data. I use your personal data for the purposes set out below.
Sections 1 – 14 apply to the clients, prospective clients, former clients and visitors to the clinic.
1. I use your name, address, telephone number and email address to make and rearrange appointments. I am unable to send or receive encrypted emails so you should be aware that any emails I send or receive may not be protected in transit. I will also monitor any emails sent to me, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send me is within the bounds of the law.
2. I keep a permanent attendance register which records all appointments for clients attending the clinic to keep a record of when you were treated for tax purposes and to secure potential evidence in the event of a criminal prosecution, civil litigation, insurance claim or complaint to my regulatory body, the British Acupuncture Council.
3. I may use your date of birth to help identify clients with the same name to avoid mistakes being made as to safe and appropriate treatment, for identification purposes if referring a client to another health practitioner, and for identification purposes if writing to a registered medical practitioner so that they correctly identify the client.
4. I use your presenting complaint and symptoms reported by you for the purposes of making a full traditional diagnosis, formulating treatment strategy and treatment planning.
5. I use any relevant medical and family history you have told me for making a full traditional diagnosis, formulating treatment strategy and treatment planning.
6. I use your GP’s name and address in the event that I need to contact your GP including in an emergency and because it is a mandatory requirement in the British Acupuncture Code of Professional Conduct.
7. I use any clinical findings about your health and wellbeing for making a full traditional diagnosis, and formulating treatment strategy and treatment planning.
8. I keep a record of and refer to that record of any treatment given and details of progress of your case, including reviews of treatment planning to enable me to: review the full traditional diagnosis, treatment strategy and planning; and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint.
9. I record and use any information and advice that I have given, especially when referring patients to any other health professional, to help you to receive the most appropriate treatment and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint.
10. I record any decisions made in conjunction with you to help you to receive the most appropriate treatment and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint.
11. I keep accident records for any patients, visitors or staff who are involved in accidents at the clinic in accordance with UK Health and Safety legislation including the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations (RIDDOR) to comply with the law and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint.
12. In the event of an adverse incident occurring to any of the clients I report the matter to the British Acupuncture Council and to my insurance company to enable the insurance company to deal with any potential claims and to help the British Acupuncture Council to develop its safe practice guidelines, as well as providing research data and information for the BAcC’s insurers and other interested parties.
13. Where relevant I maintain records of the clients consent to treatment, or the consent of their next-of-kin in order to be able to prove that the client (and/or parent/guardian/next of kin) has given informed consent to treatment to secure evidence in the event of a civil claim, criminal prosecution, insurance claim or complaint.
14. I store all paper records in a secure, locked filing cabinet.
Section 15 applies to those who complain about the services
15. When I receive a complaint from a person I make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint.
I will only use the personal information I collect to process the complaint and to check on the level of service I provide. I usually have to disclose the complainant’s identity to whoever the complaint is about. If a complainant doesn’t want information identifying him or her to be disclosed, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis. We may need to provide personal information collected and processed in relation to complaints to the British Acupuncture Council or our insurance company.
I will keep personal information contained in complaint files in line with our retention policy. This means that information relating to a complaint will be retained for two years from closure. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.
Similarly, where enquiries are submitted to me I will only use the information supplied to me to deal with the enquiry and any subsequent issues and to check on the level of service I provide.
Sections 16 – 17 apply to the website users
16. I use a third party service (1&1 IONOS Ltd) to help maintain the security and performance of the website. To deliver this service it processes the IP addresses of visitors to the website.
17. I use a third party service, (Wix.com Ltd.) to host the website. This site is hosted at (Wix.com Ltd.), which is run by (Wix.com Ltd.). It uses a standard (Wix.com Ltd.) to collect anonymous information about users' activity on the site, for example the number of users viewing pages on the site, to monitor and report on the effectiveness of the site and help us improve it. (Wix.com Ltd.) requires visitors that want to make an enquiry to enter a name and email address. For more information about how (Wix.com Ltd.) processes data, please see (https://www.wix.com/about/privacy).
18. I use a third party service for bookings (10to8). Names, emails and phone numbers are collected for the purpose of sending appointment confirmation and reminders and allows for contact between users and myself.