Privacy notice

Sally Blades: Coaching, Supervision & Acupuncture

Purpose of privacy notice

The processing of personal data is governed by the General Data Protection Regulation 2016/679 (the GDPR). This legislation will replace current data privacy law, giving more rights to you as an individual and more obligations to organisations holding your personal data.

One of the rights is a right to be informed, which means we have to give you even more information than we do now about the way in which we use, share and store your personal information.

This means that I will be publishing a new privacy notice so you can access this information, along with information about the increased rights you have in relation to the information we hold on you and the legal basis on which we are using it.

This new privacy notice comes into effect and will be published on my website on 25 May 2018.

Who am I?

I am Sally Blades, a practicing Acupuncturist, Coach and Supervisor. I am the ‘data controller’ of my business, which means that I decide how your personal data is processed and for what purposes.

Whose information does this privacy notice apply to?

This privacy notice applies to information I collect from:

What is personal data?

Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. Examples of personal data I may hold about you include your contact and appointment details.

Special category data is a sub-category of personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a person, data concerning health or data concerning a person’s sex life or sexual orientation. Examples of special category data I may hold about you include your patient notes.

How do I process your personal data?

I comply with our obligations under the 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. I use your personal data for the purposes set out below.

Sections 1 – 3 apply to my clients and patients, prospective clients and patients, former clients and patients and visitors to my clinic.

  1. I use your name, address, telephone number and email address to make and rearrange appointments. I am unable to send or receive encrypted emails so you should be aware that any emails we send or receive may not be protected in transit. I will also monitor any emails sent to me, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send me are within the bounds of the law.
  2. I use your name, address, telephone number and email address, only if I have your explicit consent, to send you marketing materials. Some coaching clients return a pre-first session questionnaire by email. Potential attendees of trainings may use an online application form to express interest or to book a place on a course. I am unable to send or receive encrypted emails so you should be aware that any emails I send or receive may not be protected in transit. I will also monitor any emails sent to me, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send me is within the bounds of the law.
  3. I keep a permanent attendance register which records all appointments for patients attending my clinic and coaching clients to keep a record of when you were seen for tax purposes and to secure potential evidence in the event of a criminal prosecution, civil litigation, insurance claim or complaint to my regulatory body, the British Acupuncture Council and/or the Association for Coaching.

Sections 4 - 14 apply specifically to current, former and prospective acupuncture patients and visitors to my clinic.

  1. In my acupuncture practice I may use your date of birth to help identify patients with the same name to avoid mistakes being made as to safe and appropriate treatment, for identification purposes if referring a patient to another health practitioner, and for identification purposes if writing to a registered medical practitioner so that they correctly identify the patient.
  2. I use your presenting complaint and symptoms reported by you for the purposes of making a full traditional diagnosis, formulating treatment strategy and treatment planning.
  3. I use any relevant medical and family history you have told us for making a full traditional diagnosis, formulating treatment strategy and treatment planning.
  4. I use your GP’s name and address in the event that we need to contact your GP including in an emergency and because it is a mandatory requirement in the British Acupuncture Code of Professional Conduct.
  5. I use my clinical findings about your health and wellbeing for making a full traditional diagnosis, and formulating treatment strategy and treatment planning.
  6. I keep a record of and refer to that record of any treatment given and details of progress of your case, including reviews of treatment planning to enable us to: review the full traditional diagnosis, treatment strategy and planning; and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint.
  7. I record and use any information and advice that we have given, especially when referring patients to any other health professional, to help you to receive the most appropriate treatment and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint.
  8. I record any decisions made in conjunction with you to help you to receive the most appropriate treatment and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint.
  9. I keep accident records for any patients, visitors or staff who are involved in accidents at my clinic in accordance with UK Health and Safety legislation including the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations (RIDDOR) to comply with the law and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint.
  10. In the event of an adverse incident occurring to any of my acupuncture patients I report the matter to the British Acupuncture Council and the our insurance company to enable the insurance company to deal with any potential claims and to help the British Acupuncture Council to develop its safe practice guidelines, as well as providing research data and information for the BAC’s insurers and other interested parties.
  11. Where relevant I maintain records of the acupuncture patient’s consent to treatment, or the consent of their next-of-kin in order to be able to prove that the patient (and/or parent/guardian/next of kin) has given informed consent to treatment to secure evidence in the event of a civil claim, criminal prosecution, insurance claim or complaint.

Sections 15 - 16 applies to those who complain about my services

  1. If I receive a complaint from a person I make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint. I will only use the personal information I collect to process the complaint and to check on the level of service I provide. If a complainant doesn’t want information identifying him or her to be disclosed, I will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis. I may need to provide personal information collected and processed in relation to complaints to the British Acupuncture Council or my insurance company.
  2. I will keep personal information contained in complaint files in line with my retention policy. This means that information relating to a complaint will be retained for two years from closure. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle. Similarly, where enquiries are submitted to me, I will only use the information supplied to me to deal with the enquiry and any subsequent issues and to check on the level of service I provide.

Sections 17 – 20 apply to my website users

  1. When someone visits my website I use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. I do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. I do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. If I do want to collect personally identifiable information through my website, I will be up front about this. I will make it clear when I collect personal information and will explain what I intend to do with it.
  2. I use website cookies to improve user experience of my website by enabling my website to 'remember' users, either for the duration of their visit - using a 'session cookie' - or for repeat visits - using a 'persistent cookie'.
  3. I use a third party service, 123-Reg, to host my website.

Sharing your personal data

Your personal data will be treated as strictly confidential, and will be shared with:

How long do I keep your personal data?

I keep your personal data for no longer than reasonably necessary.

I keep acupuncture patient records for a period of 7 years in accordance with the British Acupuncture Code of Professional Conduct - see https://www.acupuncture.org.uk/public-content/effective-practice/bacc-professional-codes.html

I keep coaching and supervision client records for a period of 7 years, and these records are kept in accordance with ‘The Global Code of Ethics for Coaches, Mentors and Supervisors’ - see https://www.associationforcoaching.com/page/AboutCodeEthics

All client and patient records are kept as paper files in a locked filing cabinet. Records are updated by hand following meetings, consultations and treatments. Emails with client data are printed off and added to the paper file, the email containing client data is then promptly deleted. As outlined above, emails sent to and from my work email account are not encrypted, but the account is password protected.

At any time you may request that changes are made to your contact details.

Your rights and your personal data

Unless subject to an exemption under the GDPR, you have certain rights with respect to your personal data as set out below.

For further details about these rights please see the Information Commissioner’s website at https://ico.org.uk/your-data-matters/

Further processing

If I wish to use your personal data for a new purpose, not covered by this Privacy Notice, then I will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, I will seek your prior consent to the new processing.

Contact Details

To exercise all relevant rights, including making queries or complaints, in the first instance please contact me at sally@sallyblades.co.uk 01364 73440 / 0789 636 9885.

You can contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.


END OF PRIVACY NOTICE