Equality and Privacy
Equal Opportunity Policy
I fully recognise and accept my responsibility to treat all clients fairly and equally. I am committed to ensuring that I provide and promote an Indian head massage service that complies with all relevant legislation and is free from discrimination against any individual on the grounds of age, disability, race, sex, sexual orientation, gender reassignment, marriage or civil partnership, pregnancy and maternity, religion or belief. I will also ensure as far as reasonably practicable that individual clients with disabilities can access treatment.
My relationship with clients is based on trust and confidence. If you feel that I have treated you unfairly or that you have suffered harassment on any of the above grounds, you have the right to raise your concern with my professional body, the Federation of Holistic Therapists, who provide information and guidance on their website www.fht.org.uk/raise-a-concern
Mandala Head Massage
The processing of personal data is governed by the General Data Protection Regulation 2016/679 (the GDPR). This legislation came into effect on 25 May 2018 and replaces previous 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 I have to give you more information about the way in which I use, share and store your personal information.
Who I am and what this Privacy Notice covers
Christine MacFie (“I”, “me”) is the data controller for Mandala Head Massage. This means I decide how your personal data is processed and for what purposes.
It describes what personal data I collect about you when you use my website or access my service. Personal data is any information that could be used to identify you as an individual. This privacy notice describes how I process your personal data, the basis upon which I process it, with whom it is shared, how it is stored and certain other important information relating to the protection of your personal data.
This privacy notice applies to information I collect from:
· Clients· Prospective clients· Former clients· Visitors to my website
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 natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. Examples of special category data I may hold about you include your client record.
How do I process your personal data?
I comply with my 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 – 15 apply to my clients, prospective clients and former clients
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 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.
2. I store client records in a secure filing cabinet and transport them to the clinic when needed. They are not accessible to anyone other than you, me, or anyone you have expressly given permission to, unless subject to an exemption under the GDPR.
3. 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.
4. I keep a permanent attendance register that records all appointments for clients attending my clinic to keep a record of when you were treated 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 Federation of Holistic Therapists (FHT).
5. I may use your date of birth to help identify clients with the same name to avoid mistakes being made as to safe and appropriate treatment, for identification purposes if referring a client to another health practitioner, and for identification purposes if writing to a registered medical practitioner so that they correctly identify the client.
6. I use your presenting complaint and symptoms reported by you, also any relevant medical and family history you have told me for the purposes of treatment strategy and planning.
7. I use your GP’s name and address in the event that I need to contact your GP including in an emergency.
8. I use my clinical findings about your health and wellbeing for treatment strategy and planning.
9. 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 to enable me to review treatment strategy and planning and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint.
10. I record and use any information and advice that I have given, especially when referring clients 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.
11. 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.
12. Where relevant I maintain records of your consent to treatment, or the consent of your next-of-kin in order to be able to prove that you (and/or parent/guardian/next of kin) have given informed consent to treatment to secure evidence in the event of a civil claim, criminal prosecution, insurance claim or complaint.
13. You have certain rights in relation to your personal data (see “Your rights and your personal data” below). Those rights will not necessarily apply in all cases or to all personal data which are processed by me. For example, certain rights will not apply where I need to process personal data to comply with my legal duties.
15. In the event of an adverse incident occurring to any of my clients I report the matter to the Federation of Holistic Therapists (FHT) https://www.fht.org.uk/ and my insurance provider, to enable the insurance provider deal with any potential claims and to help the FHT develop its safe practice guidelines, as well as providing research data and information for the FHT’s insurers and other interested parties.
Section 16 applies to those who complain about my service
16. When 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. I usually have to disclose the complainant’s identity to the Federation of Holistic Therapists or my insurance company. If a complainant does not 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 Federation of Holistic Therapists or my insurance company.
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 – 19 apply to my website users
17. 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 my website. For more information about how Google Analytics processes data, please see https://policies.google.com/privacy
18. My website search is hosted by Fasthosts. No user-specific data is collected by me or any third party on my behalf.
19. I use a third party service (Fasthosts https://policies.google.com/privacy ) to help maintain the security and performance of my website. To deliver this service it processes the IP addresses of visitors to my website. For more information about how Fasthosts processes data, please see
Sharing your personal data
Your personal data will be treated as strictly confidential, and will be shared with:
· Named third parties with your explicit consent
· The relevant authority such as the police or a court, if necessary for compliance with a legal obligation to which I am subject e.g. a court order
· Your doctor or the police if necessary to protect yours or another person’s life
· The police or a local authority for the purpose of safeguarding a children or vulnerable adults
· My regulatory body, the Federation of Holistic Therapists and my insurance company in the event of a complaint or insurance claim being brought against me
· My solicitor in the event of any investigation or legal proceedings being brought against me
How long do I keep your personal data?
I keep adult (18 years and over) client records for a minimum period of 10 years as a mandatory requirement of my insurance provider. If the client is a child, I am required to keep their records for a minimum of 10 years after they reach adulthood.
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.
· The right to request a copy of your personal data which I hold about you
· The right to request that I correct 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 me to retain such data
· The right to withdraw your consent to the processing at any time. This right does not apply where I am processing information using a lawful purpose other than consent
· The right to request that I provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable) [This right only applies where the processing is based on consent or is necessary for the performance of a contract with you and in either case I am processing 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) [This right 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 be informed if your data is lost. I shall also inform the Information Commissioner’s Office in accordance with the time limits in the GDPR
· The right to lodge a complaint with the Information Commissioner’s Office
For further details about these rights please see the Information Commissioner’s website at https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/
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.
To exercise all relevant rights, queries or complaints please in the first instance contact me at email@example.com
1 may amend this privacy notice from time to time. The date of my most recent changes can be found at the bottom of this notice and will be updated as and when an amendment is made. The most recent and up to date notice will be available on my website at all times unless the site is undergoing scheduled maintenance.
This privacy notice was last reviewed and updated on 10 February 2019.