CONTROL AND CHANGE
GDPR 2018 PRIVACY NOTICE
At Control and Change we understand that your privacy is important to you and that you care about how your personal data is used. We are committed to protecting and respecting your privacy.
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.
For the purpose of the General Data Protection Regulation, the data controller Control and Change, based at Lordswood Osteopathic Clinic, Lordswood Leisure Centre, North Dane Way, Chatham, Kent, ME5 8YE, which hereafter for the purposes of this Privacy Notice will be referred to as the “we”, “us” or “our”, are pleased to provide the following information:
What is Personal Data
Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioners Office (ICO).
a) For the purposes of providing treatment, we may require detailed medical, mental health or personal 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 us to document and process your personal 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, we 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 us 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. We may occasionally also act on behalf of our patients in the capacity of data processor, when we may promote other practitioners based at our premises, who may not be employed by us. We 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) Personal data may be collected about you from the marketing forms and surveys you complete, health and/or nutritional therapy questionnaires or forms, 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 or by making payments online or by credit/debit cards.
f) We 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.
g) If you send us an email, we may collect your name, your email address, and any other information which you choose to give us, and we may use them to respond to your email. We will not share any of your data with any third parties for any purposes [other than storage on an email server].
h) We will use this information: to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
i) to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data (the registration form/GDPR form). Examples currently in use, but not limited to, can be seen below:
All credit card transactions happen via the iZettle payment services. We do not store any credit card information you provide. We recommend that you review their privacy and security policies.
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.
Legitimate interests pursued by us
To promote treatments for patients with different types of mental health or dietary problems indicated for hypnotherapy, the control system and nutritional therapy care.
Through agreeing to this privacy notice you are consenting to us processing your personal data for the purposes outlined. You can withdraw consent at any time by using the postal, email address or tele- phone number provided at the end of this Privacy Notice.
We 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. We 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.
External Third Parties Service
• Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in the UK who provide CONSULTANCY, BANKING, LEGAL, INSURANCE AND ACCOUNTING SERVICES.
• HM Revenue & Customs, regulators and other authorities ACTING AS PROCESSORS based IN THE UNITED KINGDOM WHO REQUIRE REPORTING OF PROCESSING ACTIVITIES IN CERTAIN CIRCUMSTANCES.
Data Retention Policy
We 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, accounting or reporting obligations and requirements. 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.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
All Data is held in the United Kingdom. We do not store personal data outside of the EEA.
Your rights as a data subject
At any point whilst we 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
• 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
• Right of portability – you have the right to have the data we hold about you transferred to another
• 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 we refuse 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 we can confirm what information it holds about you and how it is processed.
You can request the following information:
• Identity and the contact details of the person or organisation (us) 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 us 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.
To access what personal data is held, identification will be required. We 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 we are dissatisfied with the quality, further information may be sought before personal data can be released. All requests should be made to email@example.com or by phoning +44 07902 633694 or writing to us at the address further below.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Control and Change and the osteopathic clinic do not have CCTV inside the clinic, however, the Lordswood Leisure Centre does have CCTV covering the car park and all the internal corridors including the one leading to the main door of the Lordswood Osteopathic Clinic. The recordings from these CCTV cameras are kept onsite and the controller of these is the Lordswood Leisure Centre’s General Manager - Mr Spencer Grimwade. The recordings are not stored by any other outside company and are kept onsite for two weeks, after which time they are then deleted. Should you wish to have access to these recordings please contact Mr Spencer Grimwade on 01634 682862.
The Mind Body Spirit Centre does not have CCTV inside the centre, however, whilst driving through the Moto and Travelodge area, your car maybe filmed. If you have any questions or concerns information can be found on theirs sites: https://moto-way.com and https://www.travelodge.co.uk respectively. If a stay over 2 hours is likely, your car registration number can be entered into the parking system at the Travelodge, ensuring there are no parking tickets. Parking tickets can be invalidated if they are brought to our attention immediately.
In the event that you wish to make a complaint about how your personal data is being processed by us, 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:
Paul Wren, Control and Change, Lordswood Osteopathic Clinic, Lordswood Leisure Centre, North Dane Way, Chatham, Kent, ME5 8YE. Tel: 07902 633694 or email: firstname.lastname@example.org
The main site for contact has been mention before in this document and listed first below. The two other addresses are used for client sessions only and no post or contact.
Control and Change, Lordswood Osteopathic Clinic, Lordswood Leisure Centre, North Dane Way, Chatham, Kent. ME5 8YE
Medway Physiotherapy, Sports & Acupuncture Centre, 50 Wattling Street, Gillingham, Kent. ME7 2YN
The Centre Mind body Spirit, Next to the Travelodge, Moto Service Station, Gillingham, Kent. ME8 8PQ
Wycliffe House, Water Lane, Wilmslow, SK9 5AF
Tel +44 (0) 303 123 1113 or email: https://ico.org.uk/global/contact-us/email/
Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.
Please check back frequently to see any updates or changes and keep up-to-date.