trading as A Healing Space
And as the following website
and social media identities:
A Healing Space facebook page
The short version
I don't hold anything you haven't given me, and I will never sell your information or indeed pass it anyone without your express permission
unless required to do so by law.
I will look after everything I have from you as I would want somenone else to do for me and then more so.
If you are unhappy about what you think I am holding then ask me about it
The formal version
There are two sections to the following information:
- About your personal data – the type of data that is collected or used, including when, how and why
- Your rights – all the ways that you can control what happens with your data
About your personal data:
When you make an enquiry
The name and contact details you give and the content of your message(s) are retained for three reasons:
- By your consent
- As part of a ‘contract’ (only while we communicate)
- For legitimate business reasons: To keep track of the kind of enquiries I get and because I may email you later on if I have new practices
or offerings that I think may interest you or to check in with you. This is not the same as subscribing to a newsletter
- Vital Interests: When I ask you for the contact details of a person I can contact on your behalf in an emergency - it is up to you
to check with them that is ok before telling me.
When you work with me 1:1
Client work is different. Dependent on the work, you may wish (or need) to provide personal details of a sensitive nature.
As an intake form these are retained on my laptop, printed or handwritten format and include your contact details and where appropriate, signature.
The sensitive nature of such documents will generally be in relation to health or medical history. If these are emailed to me
they will also be saved encrypted and password protected . You too can password protect your word files before you send
them to me but of course we would have to arrange for you to give me the password... Any of this material I print will be kept in a locked filing cabinet.
As session notes these are memos handwritten by me for the purpose of fulfilling our contract and keeping tabs on the work during the session
and from one session to the next, filed separately with only first name a number I assign as identifiers so that no other person may connect these details alone
to your personal identity. These are stored in a locked filing cabinet.
In both cases I am required by law to retain these records for six years after the completion of our
contract – or in the case of a minor, for six years after their 18th birthday.
Other data sources:
Incoming data is also received from Paypal, Skype, Zoom, Google Hangouts, Facetime, Facebook and I may receive information from
another practitioner or therapist as part of a referral.
If you email me I will also have all the information in the header which will include you IP address which can count as an e-signature.
I use google analytics - but NOT on the contact page where you give your email adress. We have been assured that google analytics will be GDPR compliant
by May 25 2018.
Sharing your data
Your privacy is important and I do not sell your data nor share it except by your consent or under the law.
When working together, I may give out elements of your personal information to another practitioner or therapist as part of a referral.
This will always only be with your personal consent.
In continuation of current UK law on confidentiality I also retain the right and in some cases the legal requirement to breach
confidentiality to inform an authority such as the police or your GP of impending harm or illegality.
The GDPR sets out clearly what your rights are. It also lays out deadlines for a reply and other rules which are reproduced for your information at the bottom of this section.
Right to be informed
You have the right to be informed about the collection and use of your personal data. This is a key transparency requirement under the GDPR.
I must provide you with information including: my purposes for processing your personal data, my retention periods for that personal data, and who it will be shared with. This ‘privacy information’ is provided above.
I must provide you with privacy information at the time I collect your personal data from you, in other words it has to be available to you before you fill in a form or hand over your data such as your email address.
If I obtain your personal data from other sources, e.g. by referral or from the payment service provider your selected, I must provide you with privacy information within a reasonable period of obtaining the data and no later than one month.
There are a few circumstances when I do not need to provide people with privacy information, such as if an individual already has the information or if it would involve a disproportionate effort to provide it.
The information I provide to people must be concise, transparent, intelligible, easily accessible, and it must use clear and plain language. Therefore if there is anything you do not understand, please get in touch.
Right of access
You have the right to access your personal data and supplementary information. This allows you to be aware of and verify the lawfulness of the processing.
You are entitled to confirmation that your data is being processed, access to your personal data, and
other supplementary information as provided in this privacy notice
Right to rectification
You have the right to have the data your personal data corrected if it is incorrect, or completed if it is incomplete.
Right to erasure
You may request, verbally or in writing, to have your data erased. This is also commonly known as ‘the right to be forgotten’.
This right only takes effect when:
- Your personal data is no longer necessary for the purpose for which it was originally collected or processed
- you withdraw your consent when the sole legal basis to hold this information is your consent
- There is a legitimate interest in processing this data, which does not override your request
- processing/analysing of the personal data was for direct marketing purposes and this is the use you object to
- your personal data was processed unlawfully without a proper legal basis
Right to restrict processing
- There is a legal obligation to comply with your request; or
- If the personal data was processed to offer information society services to a child.
You have the right to request the restriction or suppression of your personal data. In other words you want to stop the data being used but keep it on file.
In this case your personal data cannot be used and can only be stored unless:
- you give your consent
- it is for the establishment, exercise or defence of legal claims
- it is for the protection of the rights of another person (natural or legal); or
- it is for reasons of important public interest
Right to data portability
This allows you to obtain and reuse your personal data for your own purposes across different services. It allows you to move, copy or
transfer personal data easily from one IT environment to another in a safe and secure way, without affecting its usability.
Doing this is meant to enable you to take advantage of applications and services that can use this data to find you a better deal
or help you understand your spending habits. In general this rule exists for data held by big service providers, such as your call history or insurance or gas bill history. The right also only applies to information you have provided.
If, as a private client you wish to carry a copy of your case notes or other sensitive data to another practitioner or other mental,
physical or spiritual health service, these may be provided to you or to the nominated service provider, on request, in an agreed secure way.
Right to object
Individuals have the right to object to:
Your objection must be made on grounds relating to your particular situation.
Once you object your data can no longer be processed, unless
- processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling)
- direct marketing (including profiling); and
- processing for purposes of scientific/historical research and statistics
- there are demonstrably compelling legitimate grounds for the processing, which override the interests, rights and freedoms of the individual; or
- the processing is for the establishment, exercise or defence of legal claims
You can claim a right verbally or in writing.
A response should come without delay and at least within one month of receipt. The time limit is calculated from the day after you make the request (whether the day after is a working day or not) until the corresponding calendar date in the next month.
I aim to respond within 28 days.
When you request access to your data, a copy must be provided free of charge. However, you can be charged a ‘reasonable fee’ when a request is:
- manifestly unfounded or excessive, particularly if it is repetitive, unless that’s because I failed to respond; or
- for further copies of the same information (that has been previously provided).