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 interests. This is on two separate counts. For good business practice I keep tabs on who has made contact before, the types of questions asked etc.
When you make an online purchase as a single purchase, a membership or subscription
This is a contract for services. Your contact details are dealt with as above (consent, contract, legitimate reasons) – also these, your purchase history and the payment details (sent to me from Paypal or any other source) are retained for legal reasons – accounting law.
When you purchase a practice course
All of the above applies.
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.
An intake form will be retained in digital, 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.
Other data sources:
Incoming data may also be received from any other source related to you. If we communicate by email this also gives me access to your IP address which functions as an e-signature and which is retained for the life of the messages according to the situations above.
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 requirement.
The way I process your data (and the legal bases used) are constantly under review as my business grows and develops. Every effort will be made to inform you if there has been an update. Please always refer to the current privacy notice which can be found on my website
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
Under GDPR you have the right to be informed about the collection and use of your personal data. This is a key transparency requirement.
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, I must provide you with privacy information within a reasonable period of obtaining the data.
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 to them.
The information I provide to you must be concise, transparent, understandable, 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. 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, as provided in this privacy notice.
Right to rectification
You have the right to have your personal data corrected if it is incorrect, or completed if it is incomplete.
Right of removal
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.
Right to restrict processing
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 defense 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.
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 and it arrives to me (whether the day after is a working day or not) until the corresponding calendar date in the next month.
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, even when I have responded; or
for further copies of the same information (that has previously been provided).