Privacy Policy -

Your personal information

The General Data Protection Regulation (GDPR, implemented by DPA 2018 in the UK) brought in new legal protection for personal information from May 2018. Please read the details below which tells you what personal information I need to hold and why, and what your rights are. Once you have read it please complete and sign the declaration/statement of consent at the bottom.

Name of Reflexologist / Data controller: Ildiko Horvath MAR

Therapist’s Contact Details:

• Telephone: 07480 174754
• Email: hello@solefulreflexology.com
• Address: 43 Beggars Lane, Leek, ST13 8DB
• ICO reference: ZB647742

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.

Lawful basis for holding and using client information:

As a full member of the Association of Reflexologists, I abide by the AoR Code of Practice and Ethics and will hold you information for the following reasons:

• To provide you with the best possible treatment options and advice (i.e. my legitimate interests).
• Fulfilment of legal requirements set out by my insurance providers.

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 Confidentiality as defined in the AoR Code of Practice and Ethics.

What 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 your information will be retained for:

I will keep your information for the following periods:

• Insurance and Association of Reflexologists requirements: 7 years from last treatment
• Legal requirements for children: until the child is 25 years old or, if 17 when treated, until they are 26 years old

I will not transfer your data outside the EU without your consent, though I would like to make you aware of the third party services I use as part of my business.

Website/Email: My website and email are provided by Webhealer which is based in the UK. However Webhealer is also committed to complying with GDPR privacy laws and you can read their privacy policy here.

Client consultation form: My client consultation form is based on the platform by Jotform, which is based outside of the UK. However, Jotform is also committed to complying with applicable privacy laws, including the GDPR. You can read Jotform’s privacy policy here.

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
• Newsletters and special offers (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/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.

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: 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.