General Data Protection Regulation (GDPR)
Creating Balance Privacy and Consent Notice
GENERAL DATA PROTECTION REGULATION (GDPR) New legal protection (GDPR) for personal information is effective from May 2018.
This tells you what personal information I hold and why, and what your rights are.
Once you have read it I will ask you to complete and sign the statement of consent at the bottom.
Data Controller Jan Griffin
The Purpose of processing Client Data I hold and use client data in order to provide you with the best possible treatment options, support and advice.
Lawful Basis for holding and using Client Information
The lawful basis under which I hold and use for information is:
My requirement to hold your information for the following legal reasons
•Complementary and Natural Healthcare Council (CNHC) requirements to retain information for 8 years
•‘Claims occurring’ insurance: (records to be kept for 7 years after last treatment)
•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 Code of Practice and Ethics of my membership body.
What information I hold and what I do with it
In order to give professional holistic treatments, I will need to ask for and keep information about your health.
I will only use this for informing the holistic therapies treatments I provide 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
Treatment details and related notes
I will NOT share your information with anyone else (other than as required for legal process) without explaining why it is necessary, and getting your explicit consent.
Protecting Your Personal Data
I am committed to ensuring that your personal data is secure. In order to prevent and managerial procedures to safeguard and secure the information we collect from you.
I will contact you using the contact preference/s you have given me.
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 practitioner’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 practitioner to make changes to your personal information if it is incorrect or incomplete
•The right to erasure (also called “the right to be forgotten”)
•The right to restrict processing of personal data:
•You have the right to request limits on how your practitioner 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 practitioner 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/for-organisations/guide-to-thegeneral-data-protection-regulation-gdpr/individual-rights/.
If you wish to exercise any of these rights, please email me at the email address above. If you are dissatisfied with the response you can complain to the Information Commissioner’s Office; their contact details are at: www.ico.org.uk
Practitioner’s Rights Please note:
•If you don’t agree to Jan Griffin (practitioner) 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 practitioner may not be able to treat you.
•Your practitioner 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.
I consent to Jan Griffin – Creating balance holding and using my information as outlined above, and understand that I may withdraw that consent at any time by emailing my practitioner at the email address above.
I have received a copy of this document
Creating balance - Covid Secure service
The protocol detailed below has been drawn up following advice/guidelines from: -
The Association of Reflexologists (AOR), Reiki Federation, Reiki Association, CNHC
Government advice/guidelines - https://www.gov.uk/coronavirus
NHS website - https://www.nhs.uk/conditions/coronavirus-covid-19/
These are likely to change so this document is a “work in progress” and will be updated as and when any rules/guidelines are change. Updates will be made in red.
Please take note that I have followed advice & guidance and the measures I have taken are to reduce the risk of contracting corona virus but there is no 100% guarantee that this will fully protect all parties from contracting Covid 19
Risk assessment of client before treatment and further information about changes:
Client will be usually be contacted within 24-48 hours before appointment for a risk assessment to be completed to check * they don’t have any symptoms, *are not self-isolating, *are not in extremely high risk/vulnerable category, *have not been in contact with any one with coronavirus in last 14 days, *are not living with anyone who is self-isolating (I will regularly check the government and NHS guidelines for changes in symptoms). This record will be kept on file. It is important not to attend your appointment if you develop symptoms (check NHS guidelines).
2. If I, or any of my family (as I work from home) develop any symptoms I will contact the client to postpone any appointment that has been arranged.
3. Client’s will be checked again at their appointment and asked if they fall into the extremely high risk/vulnerable category etc. (as set out in 1 above).
4. Appointments will only be offered/proceed if the client is able to confirm they do not present a high risk / fall into extremely high risk/vulnerable category (so answered no to risks/questions in number 1 and 3).
5. I will amend my cancellation policy to ensure no one is penalised if an appointment is cancelled due to COAVID 19 risks.
6. Clients will be advised of the change in usual protocol via phone call, text or email prior to their appointment (as set out below).
7. No facial massage or aromatherapy facials can be offered until the government guidelines advise it is safe to do so.
8. All existing clients who had appointments cancelled will be rescheduled first before booking in other existing clients, or any new clients.
9. If possible, consultation forms/data protection forms will be emailed/posted/discussed over the phone or Zoom for new clients to complete/discuss and if completed and emailed back or brought with you the full details will be discussed at the first appointment (thus saving face to face time).
10. Time for any appointment is now restricted to 1.5 hours, which is usually combination treatments, others will be restricted to an hour (including dressing/undressing etc).
Changes to protocol for each appointment:
1. Client will be asked to confirm health has not changed since call/text/email prior to that day’s appointment, and will be required to answer Covid 19 specific questions and consent to the therapist being able to be provide their contact details to the NHS track and trace Dept. You will be required to have your temperature taken on entry.
2. It is recommended that the client wears a face mask/covering at all times throughout treatment from before they enter the premises until they leave the premises. This is for the protection of both parties. It is advisable not to touch mask, face, and eyes whilst mask is on.
3. The therapist will wear a face visor as set out in the government guidelines and a face mask/covering for treatments (in particular extended treatments).
4. Clients will be asked to wash hands/use hand sanitiser gel on entry and exit of the premises.
5. You will be asked to remove your shoes on entry and leave them in a lidded box by the front door for collection when you leave.
6. Client is respectfully requested not to touch anything on route to the treatment room and when in the treatment room to reduce to risk of transmission to surfaces (except for chair/massage bed/lafuma chair used for session).
7. Individual hand towels are in the toilet area for hand drying and a peddle bin for removal. These will be then be removed by the therapist in line with guidelines.
8. Packets of tissues will be provided for clients and packet wiped after every client.
9. Client to bring their own drink/water (a water bottle will be provided if you forget).
10. Payment should be either in advance (by bacs transfer), or paypal or if cash, this should be placed in a plastic bag.
11. All towels/linen/flannels/couch covers etc not in use in the room will be protected by plastic covering.
12. All oils/products not being used for treatment will be removed from treatment room/placed in a plastic container as appropriate.
13. Hand sanitiser gel will be available in the treatment room and a separate one for the therapist. Should anyone sneeze/cough into hands, it will be necessary to apply the sanitiser gel. The therapist will thoroughly wash hands before and after treatment.
14. A peddle bin will be available to dispose of any waste/tissues, which will then be disposed of in line with guidelines.
15. The room will be well ventilated in between each client.
16. A cleaning checklist is completed for each treatment session and available for inspection by clients. Treatment room, and route, will be thoroughly cleaned after every treatment, ready for the next client, in line with guidelines.
18. Maintaining social distancing as much as possible, for example, keeping distance on route to the treatment room, whilst in treatment room, no hugs, handshakes etc. Last updated 29/10/2020 by Jan Griffin.
This policy will also be placed on my website for reference:
Links to external sites
Links to external sites
www.creating-balance.co.uk carries links to external sites.
These links are provided for your convenience to provide further information. We are not responsible for the privacy policies or contents of these external sites nor guarantee, approve, or endorse the information or products available on these sites
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