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GDPR Privacy Notice 2023


Scope
This document refers to personal data, which is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain.
The General Data Protection Regulation (GDPR) which is EU wide and far more extensive than its predecessor the Data Protection Act, along with the Privacy and Electronic Communications Regulations (PECR), seek to protect and enhance the rights of EU data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU and its storage within the EEA. 
1 – Sonya Hirst is pleased to provide the following information:
2 - Who I am:  Sonya provides CranioSacral Therapy as taught by the Upledger Institute UK - http://www.upledger.co.uk/
3 - Personal Data 
a) For the purposes of providing treatment, Sonya may require detailed medical information. She will only collect what is relevant and necessary for your treatment. When you visit she will make notes which may include details concerning your medication, treatment and other issues affecting your health. This data is always held securely, is not shared with anyone not involved in your treatment. To be able to process your personal data it is a condition of any treatment that you give your explicit consent to allow Sonya to document and process your personal medical data. Contact details provided by you such as telephone numbers, email addresses, postal addresses may be used to remind you of future appointments and provide reports or other information concerning your treatment. 
b) For marketing purposes, Sonya may also use the contact details provided by you to respond to your enquiries, including making telephone contact and emailing information to you which she believes may be of interest to you. 
c) Some basic personal data may be collected about you from the marketing forms and surveys you complete, from records of correspondence and phone calls and details of your visits to my website, including but not limited to, personally identifying information like Internet Protocol (IP) addresses. 
d) Sonya will only collect the information needed so that she can provide you with the services you require, she will not sell or broker your data. 
4 - Legal basis for processing any personal data
To meet her contractual obligations obtained from explicit Patient Consent and legitimate interest to respond to enquiries concerning the services provided.
5 - Legitimate interests pursued by Sonya
To promote treatments for patients with all types of health problems indicated for CranioSacral Therapy. 
6 – Consent
Through agreeing to this privacy notice you are consenting to Sonya processing your personal data for the purposes outlined. You can withdraw consent at any time by using the postal, email address or telephone number provided at the end of this Privacy Notice.
7 – Disclosure
Sonya will keep your personal information safe and secure. Sonya will not disclose your Personal Information unless compelled to, in order to meet legal obligations, regulations or valid governmental requests. Sonya may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to her rights, property or safety.
8 - Retention Policy
Sonya will process personal data during the duration of any treatment and will continue to store only the personal data needed for eight years after the contract has expired to meet any legal obligations. After eight years all personal data will be deleted, unless basic information needs to be retained by us to meet our future obligations to you, such as erasure details. Records concerning minors who have received treatment will be retained until the child has reached the age of 25.
9 - Data storage
All Data is held in the United Kingdom. Sonya does not store personal data outside the EEA.
10 - Your rights as a data subject
At any point whilst Sonya is in possession of, or processing your personal data, all data subjects have the following rights:
•    Right of access – you have the right to request a copy of the information held about you.
•    Right of rectification – you have a right to correct data held about you that is inaccurate or incomplete.
•    Right to be forgotten – in certain circumstances you can ask for the data held about you to be erased from records.
•    Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.
•    Right of portability – you have the right to have the data held about you transferred to another organisation.
•    Right to object – you have the right to object to certain types of processing such as direct marketing.
•    Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.

In the event that Sonya refuses your request under rights of access, she will provide you with a reason as to why, which you have the right to legally challenge. At your request Sonya can confirm what information she holds about you and how it is processed.
11 - You can request the following information:
•    Identity and the contact details of the person or organisation (Sonya) that has determined how and why to process your data.
•    Contact details of the data protection officer, where applicable.
•    The purpose of the processing as well as the legal basis for processing.
•    If the processing is based on the legitimate interests of Sonya and information about these interests.
•    The categories of personal data collected, stored and processed.
•    Recipient(s) or categories of recipients that the data is/will be disclosed to.
•    How long the data will be stored.
•    Details of your rights to correct, erasure, restrict or object to such processing.
•    Information about your right to withdraw consent at any time.
•    How to lodge a complaint with the supervisory authority (ICO).
•    Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
•    The source of personal data if it wasn’t collected directly from you.
•    Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

12 - To access what personal data is held, identification will be required
Sonya will accept the following forms of identification (ID) when information on your personal data is requested: a copy of your driving licence, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If Sonya is dissatisfied with the quality, further information may be sought before personal data can be released. All requests should be made to sonyacst@yahoo.com or by phoning 07848 966619.
13 Complaints
In the event that you wish to make a complaint about how your personal data is being processed by Sonya you have the right to complain to her. 
If you do not get a response within 30 days, you can complain to the ICO.

ICO Wycliffe House, Water Lane, Wilmslow, SK9 5AF Telephone +44 (0) 303 123 1113 or email: https://ico.org.uk/global/contact-us/email/
 

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