I, Tracy Palazzo-Barnes, trading as Mind and Bodyworx understand 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.
- Information About Me
Tracy Palazzo-Barnes, Sole trader: trading as Mind and Bodyworx.
Main trading address: Mountain Ash, Drome Path, Winnersh, Wokingham, Berkshire RG41 5HB
Data Protection Officer: Under the rules of the GDPR (General Data Protection Regulation) I am not required to appoint a specified Data Protection Officer, I, Tracy Palazzo-Barnes act as Data Controller for this business and can be contacted on:
Email address: email@example.com.
Telephone number: 0118 324 6864
Postal Address: Mountain Ash, Drome Path, Winnersh, Wokingham, Berkshire RG41 5HB]
Complementary Therapists are not currently regulated by law, but are voluntarily registered and regulated by the CNHC, Complementary & Natural Healthcare Council, for Massage and Reiki, my Registration number is: 000102-I16
I am also a member of Complementary Health Professionals, CHP037 and the Reiki Association and I am a verified Reiki Practitioner with The Reiki Council.
- 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.
- 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.
- What Are My Rights?
Under the GDPR, you have the following rights, which I will always work to uphold:
- 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.
- The right to access the personal data I hold about you. Part 10 will tell you how to do this.
- 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.
- 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.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to me using your personal data for a particular purpose or purposes.
- 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.
- 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.
- 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):
- Date of birth;
- Email address;
- Telephone number;
- Information about your preferences and interests;
- Medical History and Treatment notes. (these details are confidential and are kept in paper format only in a locked cabinet.)
Some of your personal data is obtained from the following third parties:
- Contact details and appointment details via Acuity Scheduling (my online booking system);
- Contact details and purchasing data via WooCommerce, (my online store facility)
- 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 will be used for the following purposes:
- Supplying my products or services to you. Your personal details are required in order for me to enter into a contract with you.
- Personalising and tailoring my products or services for you, to ensure safe and appropriate treatment.
- 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 (you may unsubscribe or opt-out at any time by clicking the unscubscribe link at the foot of any newsletter or marketing email sent to you
- I am required for insurance purposes to retain your information for 8 years after your last treatment, or in the case of a minor for 8 years after age of maturity.
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, post, social media and/or other messaging services with information, news, and offers on my and/or 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.
I do not currently use automated system[s] for carrying decision-making and/or profiling. If this changes you will be informed via email.
- 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 8 years after your last treatment, or in the case of a minor for 8 years after age of maturity.
- How and Where Do You Store or Transfer My Personal Data?
I will only store or transfer your special category data in the UK. (your personal data relating to your medical history and treatment records.) This means that it will be fully protected under the GDPR.
Your contact details, online bookings and purchasing records are shared with external third parties, as detailed below in Part 9, that are based outside of the EEA. The following safeguards are applied to such transfers:
I transfer your data to a third party based in the US, this may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to similar levels of data protection to those in Europe. More information is available from the European Commission.]]
Please contact me using the details below in Part 11 for further information about the particular data protection mechanism used by me when transferring your personal data to a third country.]
The security of your personal data is essential to me, and to protect your data, I take a number of important measures, including the following:
- I have confirmed that the privacy policies and data processing practices are in accordance with the requirements of the GDPR.
- Do You Share My Personal Data?
I contract with the following third parties to supply products and/or services to you on my behalf. These may include payment processing, delivery, and marketing. In some cases, those third parties may require access to your personal data that I hold. (with the exception of special category data – i.e. sensitive personal data such as medical history and treatment information, which is never shared with anyone without your express permission.)
- MailChimp, firstname.lastname@example.org, 675 Ponce de Leon Ave NE, Suite 5000
If any of your personal data is required by a third party, as described above, I will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, my obligations, and the third party’s obligations under the law, as described above in Part 8.
If any personal data is transferred outside of the EEA, I will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 8.
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.]
- 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. There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover my administrative costs in responding.
I will respond to your subject access request within 28 days and, in any case, not more than 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.
- 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 Tracy Palazzo-Barnes):
Email address: email@example.com.
Telephone number: 01276 415750.
Postal Address: Basepoint Business Centre, 377 – 399 London Road, Camberley, Surrey GU15 3HL.
- 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 my website: www.mindandbodyworx.com