GDPR and PRIVACY POLICY

S Bryce Therapies trading as Shelagh Bryce Massage Therapy

Name: Shelagh Bryce RMT DSM DOSM DIHM
Tel: 07581 372925
Email: info@massagetherapy.scot
ICO Reference Number: ZA363784
Date Created/Updated: 26.5.20

The GDPR (General Data Protection Regulation) May 2018 is the legal regulation that has been put in place to safeguard an individual’s personal information. The following privacy policy details the lawful basis for Shelagh Bryce Massage therapy to hold information, the type of information that Shelagh Bryce Massage Therapy holds about her clients, why that information is required, who it is shared with, how that information is used and protected and details the rights an individual has in terms of access to that information or, requests for information held to be amended or deleted.

Why the personal information is required

The lawful basis for Shelagh Bryce massage therapy processing client data is:-

  • consent or contract for personal data

and

  • the fact that the processing of the special category of personal data is necessary for the provision of healthcare
  • there is also a legitimate interest in retention of records as detailed in ‘ How long is the personal information held for’ below.

In order to provide an effective and safe massage therapy treatment, Shelagh Bryce massage therapy requires information about your current health and your medical history. This information is used only to provide you with the best possible course of therapy, inform you of updates and self-care advises.
Your contact details are also required in order to arrange appointment times with you.

As a registered massage therapist with the CNHC (Complementary and Natural Healthcare Council) and with the SMTO (Scottish Massage Therapists Organisation), Shelagh Bryce abides by these associations codes of conduct and confidentiality requirements.

Where the personal information is collected from

Shelagh Bryce Massage Therapy may collect personal information from:

  • Email or Text messages sent from individuals to Shelagh Bryce Massage Therapy
  • Acuity scheduling on-line booking system
  • Medical information submitted via electronic consultation form
  • Discussions with clients during the consultation process and during subsequent treatments

What personal information is collected

Shelagh Bryce Massage Therapy may collect the following personal information:

  • Name, title and date of birth
  • Contact information including email address, telephone numbers and home address
  • Emergency contact or next of kin details
  • Medical history and other health related information provided on the consultation form and discussed during the first and subsequent treatments
  • Treatment detail and assessment notes which will be recorded after each massage session
  • Follow up information which may be discussed with clients by phone email or text after their treatment
  • Diarised records of appointment times which may be electronic or hardcopy

How is the personal information used

Shelagh Bryce Massage Therapy requires this information to assess your massage treatment requirements and provide you with a safe and effective massage therapy. Additionally the information is used to refer to at subsequent therapy sessions in order to assess levels of improvement. It may be used to provide you with updates regarding price increases, offers, news  or new therapies available.

Who is your personal information shared with

The information may be shared with another Massage Therapist or with another health practitioner should you be referred to one of these by Shelagh Bryce Massage Therapy. This will only be done with your consent. Your information will not be shared with anyone else (other than required for legal process) without explaining the reason why this is necessary and obtaining your explicit consent.
The contact information you provide may be used by Shelagh Bryce Massage Therapy to contact you in relation to appointment times or dialogue regarding your treatment plan.

How long is the personal information retained for

Section B8 of the CNHC code requires registrants to keep client records safely and in good condition for eight years from the date of the clients last visit or, if the client is a child, until his or her 25th birthday if the client was 17 when the treatment ended.

This means there is a ‘legitimate interest’ in retaining records for this period

Records are required additionally for professional indemnity insurance purposes which also represents a legitimate interest.

Your data will not be transferred without your consent.

Disposal of Data: Once per year, Shelagh Bryce Massage Therapy will review all client records and destroy any records that are no longer bound by the regulated legal timescale for such records to be held.

Security Policy

Shelagh Bryce Massage Therapy is committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, suitable physical, electronic and managerial procedures have been put in place to safeguard and secure the information that is collected both online and on paper.
The health information gathered is held on paper consultation forms and treatment notes and is stored securely in a locked filing cabinet or within a secure electronic password protected scheduling system.
Contact details including telephone numbers and email addresses are held on a password protected telephone and personal computer.

Data Breach

A back up document is held of client names and contact details (name, email and telephone number).
In the event of a data breach which consists of a breach of security leading to destruction, loss, alteration, unauthorised disclosure of or access to personal data, Shelagh Bryce Massage Therapy understands ICO have to be notified where it is likely to result in a risk to the rights and freedoms of individuals. In the event of such a breach, Shelagh Bryce Massage Therapy will notify those concerned directly and without delay. Records of personal data breaches will be maintained in any case.

Your rights

  • The GDPR May 18 gives an individual:-
  • The right to be informed as to how personal information will be both used and held. This is contained within this document.
  • The right to access your personal information so individuals know what is held about them and they can confirm it
  • The right to rectification if there is something incorrect or incomplete.
  • The right to have information deleted
  • The right to limit how the information is used or shared
  • The right to portability. Under certain circumstances a copy of electronically held information can be requested so it can be reused in other systemsThe right to object if there are certain parts of an individual’s information that they do not want used or to be used only for certain purposes
  • Rights in relation to automated decision-making and profiling
  • The right to lodge a complaint with the Information Commissioner’s Office. An individual can complain to the ICO if the individual feels the information held is incorrect or not being used in the permission was granted or if information is being held unnecessarily.

Full details of individual’s rights can be held at:
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

Should an individual wish to exercise these rights, the contact details at the start of the document should be used. In the event that an individual is dissatisfied with the response, then a complaint can be made to the Information Commissioner’s Office at www.ico.org.uk

Notes:

If an individual does not agree to Shelagh Bryce Massage Therapy keeping records of information about an individual and treatment records then it may not be possible to provide the therapy.
Additionally, massage therapists have to keep records of treatment for a specific period of time as described above which may mean that even if you ask for information to be erased, they might be bound to keep these details until the period has elapsed.

Cookies Policy

Last updated: 20/5/18

Shelagh Bryce Massage Therapy (“us”, “we”, or “our”) uses cookies on www.massagetherapy.scot (the “Service”). By using the Service, you consent to the use of cookies.

Our Cookies Policy explains what cookies are, how we use cookies, how third-parties we may partner with may use cookies on the Service, your choices regarding cookies and further information about cookies.

What are cookies

Cookies are small pieces of text sent by your web browser by a website you visit. A cookie file is stored in your web browser and allows the Service or a third-party to recognise you and make your next visit easier and the Service more useful to you.

Cookies can be “persistent” or “session” cookies.

How Shelagh Bryce Massage Therapy uses cookies

When you use and access the Service, we may place a number of cookies files in your web browser.

We use cookies for the following purposes: to enable certain functions of the Service, to provide analytics, to store your preferences, to enable advertisements delivery, including behavioural advertising.

We use both session and persistent cookies on the Service and we use different types of cookies to run the Service:

– Essential cookies. We may use essential cookies to authenticate users and prevent fraudulent use of user accounts.

Third-party cookies

In addition to our own cookies, we may also use various third-parties cookies to report usage statistics of the Service, deliver advertisements on and through the Service, and so on.

What are your choices regarding cookies

If you’d like to delete cookies or instruct your web browser to delete or refuse cookies, please visit the help pages of your web browser.

Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.

Where can your find more information about cookies

You can learn more about cookies and the following third-party websites:

CONTROLLING YOUR PERSONAL INFORMATION

You may choose to restrict the collection or use of your personal information in the following ways:

  • whenever you are asked to fill in a form on the website, or via the online appointment scheduler, look for the box that you can click to indicate that you agreeing to the information to be used
  • If you have previously agreed to us using your personal information you can change your mind at any time by writing to or emailing us at
    Email:info@massagetherapy.scot

Shelagh Bryce Massage Therapy will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you information about third parties which we think you may find interesting if you tell us that you wish this to happen.