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PRIVACY NOTICE (Data Processing)

 

Who we are and how we process your personal data

 

Sophie Pelham Burn is a nutritionist providing a range of services to individuals, groups and workplaces to enhance wellbeing and improve health, happiness and habits.

 

Sophie Pelham Burn complies with their obligations under the General Data Protection Regulation (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.

 

We use your personal data for the following purposes:

 

To deliver the services that clients have requested;

To contact those clients as necessary in accordance with the services they have requested;

To contact clients via surveys to ascertain their opinions on the service they received from us;

To maintain our own accounts and records.

 

N.B. In the event that our recorded data is utilised for research purposes, our own supervision or for the instruction or tuition of trainees, all such data will be sufficiently anonymised to the extent that individual clients cannot be identified. Should a client indicate that their data should not be used for these purposes, we would refrain from using that data.

 

Individual client data will never be passed to a third party without the express consent of the respective client, always provided that such confidentiality is neither inconsistent with the therapist’s own safety or that of the client, the client’s family members or other members of the public, nor in contravention of any legal action or legal requirement.

 

In accordance with my need to maintain the possibility of access to client data as a result of returning clients or those who may wish to lodge a complaint in respect of our professional services to either our professional body or our insurers (i.e. in all cases perhaps after a long period of time has elapsed), we retain client data for a minimum period of 7 years. For clients under the age of 18, data will be retained until their 25th birthday.

 

Our Lawful Basis for processing client personal data

 

The client has given clear consent for me to process their personal data for a specific purpose. Further, the processing is necessary for both my client’s and my own legitimate interests.

 

Information I collect:

I may collect and process the following types of personal data about clients for legitimate interest. That is data which is necessary for me to provide you with the services requested and is data you would reasonably expect me to hold and use:

 

  • Identity data: Include name, family information, likes and dislikes.

  • Contact data: Includes billing address, contact details such as email and telephone numbers.

  • Initial contact data: Form your first message to us via WhatsApp, web-based form, Facebook messenger, Instagram messenger or text.

  • Third Party data: information from your GP, insurance company or any related third party which you a have agreed to share with us.

  • Transaction data: Details about payments (but not card or bank information) to and from you and other details of services or products you have purchased from us.

  • Technical data: Includes internet protocol (IP) address; and other relevant details of how you have accessed our website and online communications

 

How your data is stored and kept securely:

 

I have put in place the following measures to keep your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. If there is a data breach, I will give full details to the Information Commissioner’s Office (ICO) within 72 hours and do all that is possible to minimize any potential impact.

 

Paper copies of consultation notes are kept in locked storage.

 

Any electronic notes or client lists are kept on a secure computer, which is password protected. Client lists are never passed to any third party.

 

Messages between us on Facebook messenger, Instagram, text message, WhatsApp, emails are held in the relevant apps on my mobile phone and laptop, all of which are password protected.

 

Your rights and your personal data

 

Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:

The right to request a copy of your personal data which Sophie Pelham Burn holds about you;

The right to request that the Sophie Pelham Burn corrects any personal data if it is found to be inaccurate or out of date;

The right to request your personal data is erased where it is no longer necessary for Sophie Pelham Burn to retain such data;

The right to withdraw your consent to the processing at any time;

The right to request that the data controller provide the data subject with his/her personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable) [N.B. This only applies where the processing is based on consent or is necessary for the performance of a contract with the data subject and in either case the data controller processes the data by automated means].

The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;

The right to object to the processing of personal data, (where applicable) [N.B. This only applies where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics]

The right to lodge a complaint with the Information Commissioners Office. (See below).

 

Complaints Notice

 

The client has the right to complain to the Independent Commissioner’s Office (ICO) if they think there is a problem with the way we are handling their data

(see https://ico.org.uk/concerns/handling/).

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