I understand that your privacy is important to you and that you care about how your personal data is used. I respect and value the privacy of all of my clients and will only collect and use personal data in ways that are described here, and in a way that is consistent with my obligations and your rights under the law.
1. Information About Me
Registered Address : 37 Kemble Court, Milton Keynes, MK15 9AX
Trading Address : The Imagine Wellbeing Clinic, Newlands, Milton Keynes, MK15 0DL
Data Protection Officer: Tanya Brown
Email address: firstname.lastname@example.org
Telephone number: 01908 683 995 / 07813 096643
Postal Address: C/O The Imagine Wellbeing Clinic, Newlands, Milton Keynes MK15 0DL
I am regulated by the Complementary and Natural Healthcare Council (CNHC).
I am a member of The Association for Professional Hypnosis and Psychotherapy (APHP), The British BrainWorking Research Society (BBRS), Complementary and Natural Healthcare Council.
I am insured through Balens Limited.
2. What Does This Notice Cover?
This Privacy Information explains how I use your personal data; how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
3. What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that I use is set out in Part 5, below.
4. What Are My Rights?
Under the GDPR, you have the following rights, which I will always work to uphold:
a) The right to be informed about my collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact me to find out more or to ask any questions using the details in Part 11.
b) The right to access the personal data I hold about you. Part 10 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by me is inaccurate or incomplete. Please contact me using the details in Part 11 to find out more.
d) The right to be forgotten, i.e. the right to ask me to delete or otherwise dispose of any of your personal data that I have. Please contact me using the details in Part 11 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to me using your personal data for a particular purpose or purposes.
g) The right to data portability. This means that you can ask me for a copy of your personal data held by me to re-use with another service or business in many cases.
h) Rights relating to automated decision-making and profiling. I do not use your personal data in this way.
For more information about my use of your personal data or exercising your rights as outlined above, please contact me using the details provided in Part 11.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about my use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
5. What Personal Data Do You Collect?
I may collect some or all of the following personal data (this may vary according to your relationship with me):
• Date of birth;
• Email address;
• Telephone number;
• GP name and surgery;
• Payment information;
• Medical History;
• Medication details;
• Sex life or sexual orientation;
• Data as related to your reason for consultation, including but not limited to, reason/s for consultation, mental, emotional and physical, life events, lifestyle, family and friends, religious or political views, criminal offences, preferences and interests;
Your personal data is not obtained from any third party.
6. How Do You Use My Personal Data?
Under the GDPR, I must always have a lawful basis for using personal data. This may be because the data is necessary for my performance of a contract with you, because you have consented to my use of your personal data, or because it is in my legitimate business interests to use it. Your personal data will be used for the following purposes:
• Supplying my services to you. Your personal details are required in order for me to enter into a contract with you.
• Communicating with you. This may include responding to emails, Facebook messages (Tanya Brown Clinical HynoTherapy & BWRT), or telephone calls from you.
I do not use your personal data for marketing purposes.
I do not use any automated systems for carrying out decision making or profiling
7. How Long Will You Keep My Personal Data?
I will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
• Paper-based : All personal data provided by you is to be kept safe and in good condition for eight years from the date of your last visit; or, for a child (i.e. below the age of eighteen years of age), until his/her 25th birthday or 26th birthday if client is 17 years of age when treatment ended.
• Email : Emails will be kept for up to three months after which time they will be deleted. Where relevant to the client’s case history, emails may be printed and retained further as paper-based data.
• Facebook : Messages are replied to deleted. If potentially relevant for your treatment, a handwritten note, or print out of you message and my reply is added to your file.
8. How and Where Do You Store or Transfer My Personal Data?
I will only store your personal data in the UK. This means that it will be fully protected under the GDPR.
The security of your personal data is essential to me, and to protect your data, I take a number of important measures, including the following:
• No personal data is stored online or on computer hardware or software.
• Personal data sent via email is deleted by the earliest means e.g. once printed on to paper copy or noted in your client file; or, where no paper record is required, no more than three months from its receipt.
• Messages sent via my Facebook page are deleted once I have responded.
• Arttdigital are responsible for the hosting of the www.tanyabrown.co.uk website. Arttdigital are classified as a data processor; however, during normal day to day running and maintenance of the website they have no access to any of your user personal data. Emails are stored on secure servers maintained by the service provider (Kualo, who state they are fully GDPR compliant). If/when an email provision issue arose, Arttdigital will seek my consent to access the account; providing adequate time for any existing emails to be removed.
• All client paper-based data is kept in a locked cabinet at my registered address.
• I do not retain any identifiable data in connection with the payment transaction history.
9. Do You Share My Personal Data?
I will not share any of your personal data with any third parties for any purposes, other than those listed below:
• In some limited circumstances, I may be legally required to share certain personal data, which might include yours, if I am involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
• Where another healthcare professional involved in your case management requests copies of your data; and your consent is obtained and provided to me in writing (the completion and signing of a consent form), you will be provided with a secure envelope containing the data to pass on to your healthcare professional.
• In non-personalised form, i.e. no clearly identifying features such as, but not limited to, name and address, your case may be discussed for the purposes of supervision/mentoring and ongoing professional development. This could be as shared with a supervisor or mentor, or for continual professional development as part of a group with the express purpose of inviting feedback and/or sharing knowledge gleaned from client cases. In all cases, client anonymity is considered paramount.
10. How Can I Access My Personal Data?
If you want to know what personal I have about you, you can me for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to my administrative costs in responding.
I will respond to your subject access request within one month of receiving it. Normally, I aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the I receive your request. You will be kept fully informed of my progress.
11. How Do I Contact You?
To contact me about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Tanya Brown). Email is my preferred means.
Email address: email@example.com.
Telephone number: 01908 683995 or 07813 096643.
Postal Address: 37 Kemble Court, Milton Keynes, MK15 9AX.
12. Changes to this Privacy Notice
I may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if I change my business in a way that affects personal data protection.
Any changes will be made available via the website Privacy Notice.