GDPR Privacy Policy Notice and Consent – Rachael Felton
(Reflexology with Rachael)

In line with the most recent General Data Protection Regulations (GDPR), this
notice informs you of which personal details I gather via my website, why I need
them and what your consumer rights are. Please take a moment to read the
information I have provided and click to confirm that you are happy for your details to be kept by Reflexology with Rachael.

Therapist name: Rachael Felton
Telephone number: 07795661510
Email address: contact@reflexologywithrachael.co.uk
Data controller contact details: As above

The Purpose of processing Client Data
In order to give professional reflexology treatments, I will need to gather and retain
potentially sensitive information about your health. I will only use this information
for informing Reflexology treatments and associated recommendations concerning
aspects of health and wellbeing which I will offer to you. I take basic contact details
and information via my website to allow me to contact you and handle bookings.
Please be aware that if you send me any sensitive medical/health information, I will
only hold and use this if we proceed to treatment, at which time I will require
explicit consent from you to hold this data. If we do not proceed to treatment I will
erase this information.

Lawful Basis for holding and using Client Information
I am a full member of the Association of Reflexologists (AOR) and the
Complementary Therapists Association (CThA), and insured by Holistic Insurance
Services (authorised and regulated by the FSA). I abide by their Code of Practice
and Ethics. The lawful basis under which I hold and use your information is my
legitimate interest i.e.my requirement to retain the information in order to provide
you with the best possible treatment options and advice.
As I hold special category data (i.e. health related information), the Additional
Condition under which I hold and use this information is: for me to fulfil my role as
a health care practitioner bound under the AoR and CThA Confidentiality, as defined in their Code of Practice and Ethics.

The information I hold and what I do with it
In order to give professional reflexology treatments, I will need to ask for and keep
information about your health. I will only use this for informing reflexology
treatments and any advice I give as a result of your treatment. The information to
be held is:
 Your contact details
 Medical history and other health-related information (which I will take from
you at first consultation)
 Treatment details and related notes (which I will take after each
consultation)
I will NOT share your information with anyone else (other than within my own
practice, or as required for legal process) without explaining why it is necessary,
and getting your explicit consent.

How Long I Retain Your Information for
I will keep your information for the following periods:
a. ‘claims occurring’ insurance: (records to be kept for 7 years after last
treatment)
b. law regarding children’s records (records to be kept until the child is
25 or if 17 when treated, then 26)
c. CNHC requirements to retain information for 8 years
d. therapist to specify any other constraint regarding retaining client
information)
Your data will not be transferred outside the EU without your consent.

Protecting Your Personal Data
I am committed to ensuring that your personal data is secure. In order to prevent
unauthorised access or disclosure, I have put in place appropriate technical,
physical and managerial procedures to safeguard and secure the information we
collect from you.
I will contact you using the contact preferences you give me in relation to:
 Appointment times.
 Reflexology information or information related to your health.
 Special offers and promotions (you may unsubscribe from this at any time).
Your Rights
GDPR gives you the following rights:
 The right to be informed:
To know how your information will be held and used (this notice).
 The right of access:
To see your therapist’s records of your personal information, so you know
what is held about you and can verify it.
 The right to rectification:
To tell your therapist to make changes to your personal information if it is
incorrect or incomplete.
 The right to erasure (also called “the right to be forgotten”):
For you to request your therapist to erase any information they hold about
you
 The right to restrict processing of personal data:.
You have the right to request limits on how your therapist uses your personal
information
 The right to data portability: under certain circumstances you can request a
copy of personal information held electronically so you can reuse it in other
systems.
 The right to object:.
To be able to tell your therapist you don’t want them to use certain parts of
your information, or only to use it for certain purposes.
 Rights in relation to automated decision-making and profiling.
 The right to lodge a complaint with the Information Commissioner’s Office:
To be able to complain to the ICO if you feel your details are not correct, if
they are not being used in a way that you have given permission for, or if
they are being stored when they don’t have to be.

Full details of your rights can be found at https://ico.org.uk/fororganisations/guide-to-the-general-data-protection-regulation-gdpr/individualrights/.

If you wish to exercise any of these rights, please use the contact details given
above.
If you are dissatisfied with the response you can complain to the Information
Commissioner’s Office; their contact details are at: http://www.ico.org.uk

THERAPIST’S RIGHTS
Please note:
 If you don’t agree to your therapist keeping records of information about you
and your treatments, or if you don’t allow them to use the information in the
way they need to for treatments, the therapist may not be able to treat you.
 Your therapist has to keep your records of treatment for a certain period as
described above, which may mean that even if you ask them to erase any
details about you, they might have to keep these details until after that
period has passed.
 Your therapist can move their records between their computers and IT
systems, as long as your details are protected from being seen by others
without your permission.