Jagir Reehal Hypnotherapy

 

PRIVACY POLICY

 

 

What is the purpose of this document?

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Jagir Reehal Hypnotherapy (hereafter referred to as ‘we’) is committed to protecting the privacy and security of your personal information.

This privacy notice and privacy policy describes how we collect and use personal information about you during and after your working relationship with us, in accordance with the General Data Protection Regulation (GDPR).

 

We are a "data controller". This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this policy.

This notice applies to current and former clients. This notice does not form part of any contract to provide services. We may update this notice at any time.

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It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

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Data protection principles

We will comply with data protection law. This says that the personal information we hold about you must be:

1. Used lawfully, fairly and in a transparent way.

2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.

3. Relevant to the purposes we have told you about and limited only to those purposes.

4. Accurate and kept up to date.

5. Kept only as long as necessary for the purposes we have told you about.

6. Kept securely.

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The kind of information we hold about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We will collect, store, and use the following categories of personal information about you including, but not limited to, the following:

• Personal contact details such as your name, title, addresses, telephone numbers, and personal email addresses.

• Date of birth.

• Gender.

• Next of kin and emergency contact information.

• Your gender.

• Copy of your driving licence.

• Copy of your passport.

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There are "special categories" of more sensitive personal data which require a higher level of protection, including information about your health.

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We envisage that we will hold or process special categories of sensitive personal data as highlighted above, in particular data concerning your health. We will obtain your explicit consent to obtain and process special categories of personal data.

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How is your personal information collected?

We collect most information from you. However, we may also collect information:

• from you directly in hardcopy or email format;

• from any forms completed and submitted by you to us;

• from a third party with your consent, eg:

  • doctors

  • consultants and other professionals we may engage;

• via our information technology systems, eg:

  • our website;

  • document management systems;

  • technical systems, such as our computer networks and connections, communications systems, email and instant messaging systems.

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How we will use information about you

Under data protection law, we can only use your personal data if we have a proper reason for doing so, eg:

• to comply with our legal and regulatory obligations;

• for the performance of our contract with you or to take steps at your request before entering into a contract;

• for our legitimate interests or those of a third party; or

• you have given consent.

 

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. For example, without obtaining your name, date of birth and medical conditions, we would not be able to undertake our services and it is therefore in our legitimate interest to obtain such information from you.

The table below explains the reasons what we use and process your personal data and our reasons for doing so:

 

What we use your personal data for

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Our reasons: 

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To provide the following services to you:

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• Hypnotherapy

 

For the performance of our contract with you or  for our legitimate interests

Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies

To comply with our legal and regulatory obligations

Ensuring safe working practices, staff administration and assessments

To comply with our legal and regulatory obligations

Ensuring the confidentiality of commercially sensitive information

For our legitimate interests or those of a third party

To comply with our legal and regulatory obligations

The above table also applies to special category personal data, which we will only process with your explicit consent.

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Retention Policy

This policy sets out how long information will normally be held by us and when that information will be confidentially destroyed.

How long your personal data will be kept

We will keep your personal data after we have finished working with you but we will not retain your data for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of data.

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our clients for legal, regulatory and tax purposes.

Information (hard copy and electronic) will be retained for at least the period specified in our Data Retention Period (see Appendix) and we will endeavour to delete hard copy and electronically held documents and information at the end of the retention period.

 

Data Retention Periods – Appendix

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Retention period

The Hypnotherapy service provided to you: 2 years from the conclusion of the service provided to you or we receive a written request to delete such data in accordance with this Privacy Policy, whatever comes earlier.

Tax: 6 years after the end of the period or assessment

Financial/Accounts records: 6 years

Complaints records: 1 year from the conclusion of the complaint

 

If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to provide you with a professional service.

How we use particularly sensitive personal information

Special categories" of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information.

As confirmed previously, we do envisage that we will obtain, handle or process your sensitive personal information. However, we may process special categories of personal information in the following circumstances:

1. In limited circumstances, with your explicit written consent.

2. Where we need to carry out our legal obligations.

3. Where it is needed in the public interest, such as for equal opportunities monitoring.

4. Where it is needed to assess your capacity on health grounds, subject to appropriate confidentiality safeguards.

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public. We may also process such information about members or former members in the course of legitimate business activities with the appropriate safeguards.

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Do we need your consent – sensitive personal data?

In accordance with this Privacy Policy, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.

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Why might you share my personal information with third parties?

We will share your personal information with third parties where required by law, where it is necessary to administer the relationship with you or where we have another legitimate interest in doing so.

"Third parties" includes your doctor, hospitals, private medical practices or organisations within the NHS.

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Data security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees and third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

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We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

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Your rights

You have the following rights, which you can exercise free of charge: 

 

Access

The right to be provided with a copy of your personal data (the right of access)

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Rectification

The right to require us to correct any mistakes in your personal data

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To be forgotten

The right to require us to delete your personal data—in certain situations

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Restriction of processing

The right to require us to restrict processing of your personal data—in certain circumstances, eg if you contest the accuracy of the data

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Data portability

The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations

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To object

The right to object:

—at any time to your personal data being processed for direct marketing (including profiling);

—in certain other situations to our continued processing of your personal data, eg processing carried out for the purpose of our legitimate interests.

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Not to be subject to automated individual decision-making

The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

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To withdraw

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact Jagir Reehal. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

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If you would like to exercise any of those rights, please:

• email or call —see below: ‘How to contact us’; and

• let us have enough information to identify you (eg your full name, address and client or matter reference number);

• let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and

• let us know what right you want to exercise and the information to which your request relates.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

 

Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

If you have any questions about this privacy notice, please contact Jagir Reehal at info@jagirreehal.com or by telephone +442036336307

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How to complain

We hope that we can resolve any query or concern you may raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner (ICO) who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.

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How to contact us

Please contact us by email or telephone if you have any questions about this privacy policy or the information we hold about you.

 

Our contact details are:

Email: info@jagirreehal.com

Tel: +442036336307