Privacy Policy – May 2018 – the General Data Protection Regulation (GDPR)

We are required by law to ask each client to consent to us storing information that you have provided via a health questionnaire, by phone, text, email and post. By giving us this information you are consenting to us being able to contact you. If you no longer would like this information stored then you can request that it is deleted however if you wanted to come back for another colonic (or other another related service) then another questionnaire would have to be filled out.

We undertake at all times to protect your personal data, including any health and contact details, in a manner which is consistent with our duty of professional confidence and the requirements of the General Data Protection Regulation (GDPR) concerning data protection.  We will also take reasonable security measures to protect your personal data storage.

This document outlines how that information is used, who we may share that information with and how we keep it secure. This notice does not provide exhaustive detail. However, we are happy to provide any additional information or explanation needed. Any requests for this, or for data removal, should be sent to info@colonicsmarketharborough.co.uk. We keep our Privacy Notice under regular review.

What We Do

The Colonic Clinic focuses on preventative healthcare, the optimisation of physical and general health through colonics, dietary and lifestyle changes and with the use of digestive supplements/herbs.

Storing data securely

Paper files will be stored in a locked cupboard where unauthorised personnel cannot access it. Paper files include such information as the client’s name, address, email address, contact details and their health information.

Printed data will be shredded when it is no longer needed.

Details such as the Client’s name, email address and contact number is stored securely on an encrypted database which is then backed up securely on Google Drive and only accessed by authorised persons.

  • Data stored on a computer will be protected by strong passwords.
  • Data stored on CDs or memory sticks will be encrypted or password protected and locked away securely when they are not being used
  • Cloud services used to store personal data will be assessed for compliance with GDPR principles.

Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

The Colonic Clinic may share your sensitive information with third parties to support your ongoing healthcare i.e. if referring to a nutritional therapist for your ongoing health support.  We will not do this unless we have your permission to do so

We will not sell, distribute or lease your personal information to third parties

You can withdraw your consent at anytime by emailing info@colonicsmarketharborough.co.uk

How We Obtain Your Personal Data

Information provided by you

You provide us with personal data in the following ways:

  • By completing and signing a health questionnaire
  • By signing terms of engagement form
  • Information you provide during your appointment
  • Through email, over the telephone, by text or post
  • Information provided by third parties that you have consented to being passed to the Colonic Clinic
  • By taking online payment via bank transfer

This may include (but not limited to) the following information:

  • basic details such as name, address, contact details
  • details of contact we have had with you such as referrals and appointment requests
  • health information including your previous medical history, dietary, lifestyle, supplement and medicine details, biochemical test results obtained elsewhere or GP results that have been provided to us
  • GP contact information
  • Bank details (these are stored on HSBC servers)

We use this information in order to provide you with direct healthcare.  This means that the legal basis of our holding your personal data is for legitimate interest.

How we use your personal data

Karen Dilley acts as the data controller for the use of your personal data to provide direct healthcare.  Karen Dilley also acts as a controller and processor in regard to the processing of your data from third parties such as healthcare providers. Karen Dilley acts as a data controller and processor in regard to the processing of online payments.

Do you share my information with other organisations?

We will keep information about you confidential.  We will only disclose your information with other third parties with your express consent with the exception of the following categories of third parties:

  • Our registrant body, Association of Registered Colonic Hydrotherapists (ARCH), for the processing of a complaint made by you
  • Any legal or crime prevention agencies and/or to satisfy any regulatory request (e.g. ARCH if we have a duty to do so or if the law dictates us to do so

We may share your information with supplement companies if you wish us to order on your behalf.  We will not include any sensitive information and this will only be done at the client’s request and consent.

We will seek your express consent before sharing your information with other healthcare providers. However if we believe that your life is in danger then we may pass your information onto an appropriate authority (such as the police, social services in the case of a child or vulnerable adult, or GP in case of self-harm) using the legal basis of vital interests.

What are your rights?

Every individual has the right to see, amend, delete or have a copy, of data held that can identify you, with some exceptions. You do not need to give a reason to see your data.

If you want to access your data you must make a subject access request in writing to info@colonicsmarketharborough.co.uk. Under special circumstances, some information may be withheld. We shall respond within 20 working days from the point of receiving the request and all necessary information from you.  Our response will include the details of the personal data we hold on you including:

  • Sources from which we acquired the information
  • The purposes of processing the information
  • Persons or entities with whom we are sharing the information

You have the right, subject to exemptions, to ask to:

  • Have your information deleted
  • Have your information corrected or updated where it is no longer accurate
  • Ask us to stop processing information about you where we are not required to do so by law or in accordance with the ARCH and CNHC guidelines.
  • Receive a copy of your personal data, which you have provided to us, in a structured, commonly used and machine readable format and have the right to transmit that data to another controller, without hindrance from us.
  • Object at any time to the processing of personal data concerning you

We do not carry out any automated processing, which may lead to automated decision based on your personal data.

If you would like to invoke any of the above rights then please write to us at info@colonicsmarketharborough.co.uk

What safeguards are in place to ensure data that identifies me is secure?

We only use information that may identify you in accordance with GDPR. This requires us to process personal data only if there is a legitimate basis for doing so and that any processing must be fair and lawful.

Within the health sector, we also have to follow the common law duty of confidence, which means that where identifiable information about you has been given in confidence, it should be treated as confidential and only shared for the purpose of providing direct healthcare. We will protect your information, inform you of how your information will be used, and allow you to decide if and how your information can be shared.

We also ensure the information we hold is kept in secure locations, restrict access to information to authorised personnel only, protect personal and confidential information held on equipment such as laptops with encryption (which masks data so that unauthorised users cannot see or make sense of it).

The Colonic Clinic, Market Harborough is registered with the Information Commissioner’s Office (ICO) as a data controller and collects data for a variety of purposes. A copy of the registration is available through the ICO website.

How long do you hold confidential information for?

All records held by The Colonic Clinic, Market Harborough will be kept for the duration specified in Section B8 of the CNHC Code which requires registrants to keep client’s records safely and in good condition for eight years from the date of the client’s last visit or, if the client is 17 years old when the treatment ended, until his or her 26th birthday. This means that registrants have a ‘legitimate interest’ in retaining records for this period.

Website technical details

We do use electronic forms on our website making use of an available ‘forms module’ which has a number of built-in features to help ensure privacy. We also aim to use secure forms where appropriate.

Cookies collect information and help the site function more efficiently and all information collected is done anonymously.

Cookies are small. We do not make use of cookies to collect any private or personally identifiable information. The technical platform of this website uses cookies solely to aid the proper technical functioning of the website. The cookies used contain random strings of characters alongside minimal information about the state and session of the website – which in no way collects or discloses any personal information about you as a visitor.

Advanced areas of this site may use cookies to store your presentation preferences in a purely technical fashion with no individually identifiable information. Note also our statement on analytics software below – as analytics software also uses cookies to function.

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org

To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout

Analytics

Like most websites, we make use of analytics software in order to help us understand the trends in popularity of our website and of different sections. We make no use of personally identifiable information in any of the statistical reports we use from this package. We use an analytics package called Google Analytics who provide details of their privacy policy on the Google website.

Complaints

If you have a complaint regarding the use of your personal data then please contact us by writing to The Colonic Clinic at Suite 4, 10 The Square, Market Harborough, LE16 7PA or email info@colonicsmarketharborough.co.uk and we will do our best to help you.

If your complaint is not resolved to your satisfaction and you wish to make a formal complaint to the Information Commissioner’s Office (ICO), you can contact them on 01625 545745 or 0303 1231113.