privacy

Legal Notice/Privacy Policy  

Name of company:
Michelle Estruch Acupuncture

Registered office:
The Acupuncture Clinic, Guildford Surrey

Contact details:
07775 122 754
acupunctureme@btinternet.com

Regulatory authority:
The British Acupuncture Council

Introduction

The processing of personal data is governed by the General Data Protection Regulation 2016/679 (the GDPR). This legislation gives you the right to be informed about the data we hold on you, the way in which we use it, share and store it and the legal basis on which we collect it.
Who are we?
Michelle Estruch Acupuncture is the data controller (contact: acupunctureme@btinternet.com) which means that we decide how your personal data is processed and for what purposes.

Whose information does this privacy notice apply to?
This privacy notice applies to information we collect from patients (current, former and prospective patients) and visitors to our website.

What is personal data?
Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. Examples of personal data we may hold about you include your contact and appointment details.

Special category data is a sub-category of personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. Examples of special category data we may hold about you include your patient notes.

How do we process your personal data?
We take our responsibilities seriously. We comply with our obligations under the GDPR by keeping personal data up to date; by storing and destroying data securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data. We use your personal data for the purposes set out below.

The personal data held about you and how it is used
The data we collect about you is provided by you directly. We store your records on paper in secure locked cabinets, to which only we have access. Any phone numbers and email addresses stored electronically are stored securely and are password protected.
  1. We use your name, address, telephone number and email address to make and rearrange appointments.  Your name, email address and mobile number are used for the purposes of online booking.
  2. We may use your date of birth to ensure that you are uniquely identifiable, particularly if we are referring you to another health practitioner or writing to your medical practitioner.
  3. We keep a permanent patient attendance register for tax purposes and as evidence for other legitimate reasons.
  4.  We use your presenting complaint and symptoms reported by you, any relevant medical and family history you have told us about, our clinical findings about your health and wellbeing for the purposes of making a full traditional diagnosis, formulating treatment strategy and treatment planning.
  5. We keep a record of and refer to that record of any treatment given, details of progress of your case, including reviews of treatment planning, any information and advice that we have given and any decisions made in conjunction with you, to ensure that you receive the most appropriate treatment.
  6. Where relevant, we maintain records of your consent to treatment, or the consent of your next-of-kin in order to secure evidence that informed consent to treatment has been given.
  7. We use your GP’s name and address in the event that we need to contact your GP including in an emergency and because it is a mandatory requirement in the British Acupuncture Code of Professional Conduct.
  8. We will use your name, address, telephone number and email address to send you marketing materials only with your explicit consent.
  9. Some patients and prospective patients choose to tell us about their medical conditions and medication by email. Please note that we are unable to send or receive encrypted emails so you should be aware that any emails we send or receive may not be protected in transit. We will also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send us is within the bounds of the law.
  10. You are of course entitled to complain about the service we have provided to you. In such an event, we may need to provide personal information collected and processed in relation to complaint to the British Acupuncture Council or to our insurance company. The information relating to a complaint will be retained for two years from closure. It will be retained in a secure environment and access to it will be restricted according to a ‘need to know’ principle.
  11. In the unlikely event of an adverse incident occurring to any of our patients, we are obliged to report the matter to the British Acupuncture Council and to our insurance company.
  12. In accordance with UK Health and Safety legislation including the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations (RIDDOR) we record any accidents occurring at our clinic.
 Sharing your personal data
Your personal data will be treated as strictly confidential and will be shared only:
  • with named third parties with your explicit consent;
  • with a relevant medical or legal authority, if necessary, for compliance with a legal obligation to which we are subject;
  • to protect your or another person’s life;
  • for the purpose of safeguarding a child or a vulnerable adult;
  • with our regulatory body, the British Acupuncture Council, or our insurance company or legal advisors in the event of any investigation or legal proceedings.
For further details please see the Information Commissioner’s website at https://ico.org.uk/for-the-public/personal-information/

How long do we keep your personal data?
We keep patient records for a period of 7 years (or age 25, if this is longer) in accordance with the British Acupuncture Code of Professional Conduct 

In the event that something happens to me, Acupuncturist, Kerry Wratten (https://www.kerrywratten-acupuncture.com) may have access to our records.

Your rights and your personal data
Unless subject to an exemption under the GDPR, you have certain rights with respect to your personal data as set out below.
  • The right to request a copy of your personal data which we hold about you.
  • The right to request that we correct any personal data if it is found to be inaccurate or out of date.
  • The right to request your personal data is erased where it is no longer necessary for us to retain such data.
  • The right to withdraw your consent to the processing at any time. This right only applies where we are processing your information using the lawful purpose of consent. 
  • The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller [This right only applies where the processing is based on consent or is necessary for the performance of a contract with you and in either case where we are processing the data by automated means].
  • The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing.
  • The right to object to the processing of personal data [This right only applies where processing is based on legitimate interests, or the performance of a task in the public interest/exercise of official authority, direct marketing and processing for the purposes of scientific/historical research and statistics].
  • The right to be informed if your data is lost. We shall also inform the Information Commissioner’s Office in accordance with the time limits in the GDPR.
  • The right to lodge a complaint with the Information Commissioner’s Office.
For further details about these rights please see the Information Commissioner’s website 

Further processing
If we wish to use your personal data for a new purpose, not covered by this Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.

Contact Details
To exercise all relevant rights, queries or complaints please in the first instance contact Michelle Estruch Acupuncture (the “data controller”) at acupunctureme@btinternet.com or call 07775 122754.

You can contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.

Cookies

We and our trusted partners use cookies and other technologies in our related services, including when you visit our Site or access our services. 

A "cookie" is a small piece of information that a website assigns to your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enabling automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker and easier. Cookies are also used to help make sure that the advertisements you see are relevant to you and your interests and to compile statistical data on your use of our Services. 

The Site uses the following types of cookies:

a. 'session cookies' , which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed; 

b. 'persistent cookies ', which are read only by the Site, saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, for example to allow us to store your preferences for the next sign-in; 

c. 'third-party cookies' , which are set by other online services who run content on the page you are viewing, for example by third-party analytics companies who monitor and analyse our web access.

Cookies do not contain any information that personally identifies you, but Personal Information that we store about you may be linked, by us, to the information stored in and obtained from cookies. You may remove the cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of our Site may not operate properly and your online experience may be limited.

We use a tool which is based on the Snowplow Analytics  technology to collect information about your use of the Site. The tool collects information such as how often users access the Site, which pages they visit when they do so, etc. The tool does not collect any Personal Information and is only used by our Site hosting and operating service provider to improve the Site and services.

Use of script libraries (Google Web Fonts)

In order to present our contents correctly and make them graphically appealing across all browsers, we use script libraries and font libraries such as Google Web Fonts ( https://www.google.com/webfonts ) on this website. Google Web Fonts are transferred to your browser's cache to avoid multiple loading. If your browser does not support Google Web Fonts or does not allow access, content will be displayed in a default font. 
  • Calling script libraries or font libraries automatically triggers a connection to the library operator. In theory, it is possible – but currently also unclear whether and, if so, for what purposes – that operators of corresponding libraries collect data.

  • The privacy policy of the library operator Google can be found here: https://www.google.com/policies/privacy .

Third-party collection of information

Our policy only addresses the use and disclosure of information we collect from you. To the extent you disclose your information to other parties or sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them. Accordingly, we encourage you to read the terms and conditions and privacy policy of each third party that you choose to disclose information to. 

This Privacy Policy does not apply to the practices of companies that we do not own or control, nor to individuals whom we do not employ or manage, including any of the third parties which we may disclose information to as set out in this Privacy Policy. 

How do we safeguard your information?

We take great care in implementing and maintaining the security of the Site and your information. We employ industry standard procedures and policies to ensure the safety of the information we collect and retain, and prevent unauthorised use of any such information, and we require any third party to comply with similar security requirements, in accordance with this Privacy Policy. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorised access or abuse our Site, and we make no warranty, express, implied or otherwise, that we will prevent such access.

Transfer of data outside the EEA 

Please note that some data recipients may be located outside the EEA. In such cases we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection.

Updates or amendments to this Privacy Policy

We reserve the right to periodically amend or revise the Privacy Policy; material changes will be effective immediately upon the display of the revised Privacy policy. The last revision will be reflected in the "Last modified" section. Your continued use of the Platform, following the notification of such amendments on our website, constitutes your acknowledgment and consent of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments.
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