GDPR & PRIVACY NOTICE – LET THE RIVER FLOW
BACKGROUND:
Let the River Flow understands that your privacy is important to you and that you care about how your personal data is used. I respect and value the privacy of all of my clients and will only collect and use personal data in ways that are described here, and in a way that is consistent with my obligations and your rights under the law.
1. Information About Me:
Let the River Flow
sole trader registered in England
74 Spencer Lane, Lewes, BN7 2QX
Email address: lettheriverflow@hotmail.co.uk
Telephone number: 07905445585
I am a member of International Federation of Professional Aromatherapists (IFPA) and Insured with Balens Ltd, underwritten by Zurich plc.
2. What Does This Notice Cover?
This Privacy Information explains how I use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
3. What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that I use is set out in Part 5, below.
4. What Are My Rights?
Under the GDPR, you have the following rights, which I will always work to uphold:
a) The right to be informed about my collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact me to find out more or to ask any questions using the details in Part 11.
b) The right to access the personal data I hold about you. Part 10 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by me is inaccurate or incomplete. Please contact me using the details in Part 11 to find out more.
d) The right to be forgotten, i.e. the right to ask me to delete or otherwise dispose of any of your personal data that I have. Please contact me using the details in Part 11 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to me using your personal data for a particular purpose or purposes.
g) The right to data portability. This means that, if you have provided personal data to me directly, I am using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask me for a copy of that personal data to re-use with another service or business in many cases.
h) Rights relating to automated decision-making and profiling. I do not use your personal data in this way. For more information about my use of your personal data or exercising your rights as outlined above, please contact me using the details provided in Part 11.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about my use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
5. What Personal Data Do You Collect?
I may collect some or all of the following personal data (this may vary according to your relationship with me:
· Name;
· Date of birth;
· Address;
· Email address;
· Telephone number;
· Profession;
· Health information relating to the consultation so I can make an informed decision for the essential oils to use, the massage treatment or yoga class. This information is completely confidential and remains written in paper form and securely locked in a filing cabinet.
6. How Do You Use My Personal Data?
Under the GDPR, I must always have a lawful basis for using personal data. This may be because the data is necessary for my performance of a contract with you, because you have consented to my use of your personal data, or because it is in my legitimate business interests to use it. Your personal data may be used for one of the following purposes:
· Supplying my products and services to you. Your personal details are required in order for me to enter into a contract with you.
· Personalising and tailoring my products and services for you.
· Communicating with you. This may include responding to emails or calls from you.
· Supplying you with information by email and/or post that you have opted-in to and which you may unsubscribe at any time.
With your permission and/or where permitted by law, I may also use your personal data for marketing purposes, which may include contacting you by email, telephone text message or post with information, news, and offers on my products and services. You will not be sent any unlawful marketing or spam. I will always work to fully protect your rights and comply with my obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.]
7. How Long Will You Keep My Personal Data?
I will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
· As a holder of a Balen’s Health Professionals Policy, underwritten by Zurich Insurance plc, it is a condition of my Insurance Policy to take and retain client records. The policy wording notes:
The records shall be kept for at least 7 years following the last occasion on which treatment was given. In the case of treatment to minors, it is advisable that records should be kept or at least 7 years after they reach the age of majority (18).
8. How and Where Do You Store or Transfer My Personal Data?
I will only store or transfer your personal data in the UK. This means that it will be fully protected under the GDPR.
9. Do You Share My Personal Data?
I will not share any of your personal data with any third parties for any purposes, subject to one important exception.
In some limited circumstances, I may be legally required to share certain personal data, which might include yours, if I am involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
10. How Can I Access My Personal Data?
If you want to know what personal data I have about you, you can ask me for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11.
I will respond to your subject access request within 28 days and, in any case, not more one month of receiving it. Normally, I aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date I receive your request. You will be kept fully informed of my progress.
11. How Do I Contact You?
To contact me about anything to do with your personal data and data protection, including to make a subject access request, please use the following details [(for the attention of Wendy Spencer:
Email address: lettheriverflow@hotmail.co.uk.
Telephone number: 07905445585
Postal Address: 74 Spences Lane, Lewes, BN7 2QX
12. Changes to this Privacy Notice
I may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if I change my business in a way that affects personal data protection.
Any changes will be made available via the website.