PRIVACY POLICY

This is the privacy policy for Anne-Marie Carter who is the data controller.
Trading as Business name Hypnotherapy Stone Staffordshire
And as the following website(s) and social media identities:
Facebook… Hypnotherapy Stone Staffs.
Contact details:
36 Heath Gardens, Walton, Stone, Staffs. ST150AW.
Email…. hypnotherapystonestaffs@hotmail.com

There are two sections to the following information:
1. About your personal data – the type of data that is collected or used, including when, how and why
2. Your rights – all the ways that you can control what happens with your data

About your personal data:
When you make an enquiry
The name and contact details you give and the content of your message(s) are retained for three reasons:
1. By your consent
2. As part of a ‘contract’ (only while we communicate)
3. For legitimate business interests – for good business practice I keep tabs on who has made contact before, the types of questions asked etc
When you make an online purchase as a single purchase, a membership or subscription
This is a contract for services. Your contact details are dealt with as above (consent, contract, legitimate reasons) – also these, your purchase history and the payment details (sent to me from Paypal) are retained for six years beyond the end of the contract for legal reasons – accounting law.
When you attend a workshop or training
All of the above applies. I also keep record of your attendance, your certificates earned etc on the legal bases of both contract and legitimate interest – so that I can confirm your certificate status / reissue certification if required, also so that I can send you updates or offers which may be of specific interest to you as an attendee/graduate.
When you work with me 1:1
Client work is different. Dependent on the work, you may wish, or need to provide personal details of a sensitive nature.
As an intake form these are retained in printed or handwritten format and include your contact details and where appropriate, signature. The sensitive nature of such documents will generally be in relation to health or medical history.
As session notes these are scant memos handwritten by me for the purpose of fulfilling our contract and keeping tabs on the work during the session and from one week to the next, filed separately in a locked cabinet.
I am a member of the Complementary & Natural Healthcare Council CNHC. As such I am bound by their regulations regarding the length of time I must hold onto your information. The CNHC insists that I must hold onto your data for 8 years after your final session. However, the rule for minors is different and the CNHC states that their data must be held until their 25th birthday. The exception to this rule applies to young adults whose treatment ends when they are 17 years old when I must keep their records until they reach their 26th birthday. Client records will be destroyed after the dates given above. This is in line with NHS regulations for holding data.
All electronic communication is securely held.
I will provide you with access to a platform for communication between sessions which is HIPPA compliant.
Other data sources:
Incoming data is also received from my website host Cloud Next, Paypal, Skype, Zoom.
I may receive information from another practitioner or therapist as part of a referral. In such a case you may be unaware that the consented data transfer has taken place, I will therefore inform you of receipt within 28 days
Sharing your data
Your privacy is important and I do not sell your data nor share it except by your consent or under the law.
When working together, I may give out elements of your personal information to another practitioner or therapist as part of a referral. This will always only be with your personal consent.
In continuation of current UK law on confidentiality I also retain the right and in some cases the legal requirement to breach confidentiality to inform an authority such as the police or your GP of impending harm or illegality.

Your Rights
The GDPR sets out clearly what your rights are. It also lays out deadlines for a reply and other rules which are reproduced for your information at the bottom of this section.
Right to be informed
You have the right to be informed about the collection and use of your personal data. This is a key transparency requirement under the GDPR.
I must provide you with information including: my purposes for processing your personal data, my retention periods for that personal data, and who it will be shared with. This ‘privacy information’ is provided above.
I must provide you with privacy information at the time I collect your personal data from you, in other words it has to be available to you before you fill in a form or hand over your data such as your email address.
If I obtain your personal data from other sources, e.g. by referral or from the payment service provider your selected, I must provide you with privacy information within a reasonable period of obtaining the data and no later than one month.
There are a few circumstances when I do not need to provide people with privacy information, such as if an individual already has the information or if it would involve a disproportionate effort to provide it.
The information I provide to people must be concise, transparent, intelligible, easily accessible, and it must use clear and plain language. Therefore if there is anything you do not understand, please get in touch.

Right of access
You have the right to access your personal data and supplementary information. This allows you to be aware of and verify the lawfulness of the processing.
You are entitled to confirmation that your data is being processed, access to your personal data, and
other supplementary information as provided in this privacy notice
Right to rectification
You have the right to have the data your personal data corrected if it is incorrect, or completed if it is incomplete.
Right to erasure
You may request, verbally or in writing, to have your data erased. This is also commonly known as ‘the right to be forgotten’. This right only takes effect when:
• Your personal data is no longer necessary for the purpose for which it was originally collected or processed,
• You withdraw your consent when the sole legal basis to hold this information is your consent,
• There is a legitimate interest in processing this data, which does not override your request
• processing/analysing of the personal data was for direct marketing purposes and this is the use you object to
• your personal data was processed unlawfully without a proper legal basis
• There is a legal obligation to comply with your request; or
• If the personal data was processed to offer information society services to a child.
Right to restrict processing
You have the right to request the restriction or suppression of your personal data. In other words you want to stop the data being used but keep it on file.
In this case your personal data cannot be used and can only be stored unless:
• you give your consent;
• it is for the establishment, exercise or defence of legal claims;
• it is for the protection of the rights of another person (natural or legal); or
• it is for reasons of important public interest.
Right to data portability
This allows you to obtain and reuse your personal data for your own purposes across different services.  It allows you to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without affecting its usability.  Doing this is meant to enable you to take advantage of applications and services that can use this data to find you a better deal or help you understand your spending habits. In general this rule exists for data held by big service providers, such as your call history or insurance or gas bill history. The right also only applies to information you have provided.
If, as a private client you wish to carry a copy of your case notes or other sensitive data to another practitioner or other mental, physical or spiritual health service, these may be provided to you or to the nominated service provider, on request, as an encrypted and password protected document.
Right to object
Individuals have the right to object to:
• processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling);
• direct marketing (including profiling); and
• processing for purposes of scientific/historical research and statistics.
Your objection must be made on grounds relating to your particular situation.
Once you object your data can no longer be processed, unless
• there are demonstrably compelling legitimate grounds for the processing, which override the interests, rights and freedoms of the individual; or
• the processing is for the establishment, exercise or defence of legal claims.
Timelines:
You can claim a right verbally or in writing.
A response should come without delay and at least within one month of receipt. The time limit is calculated from the day after you make the request (whether the day after is a working day or not) until the corresponding calendar date in the next month.
I aim to respond within 28 days.
Exceptions:
When you request access to your data, a copy must be provided free of charge. However, you can be charged a ‘reasonable fee’ when a request is:
• manifestly unfounded or excessive, particularly if it is repetitive, unless that’s because I failed to respond; or
• for further copies of the same information that’s previously been provided.

Cookies
A cookie, also known as an HTTP cookie, web cookie, or browser cookie, is a small piece of data sent from a website and stored in a user’s web browser while the user is browsing that website. Every time the user loads the website, the browser sends the cookie back to the server to notify the website of the user’s previous activity.
Our website may use cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.
We may use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

Complaints:
If you are unhappy with any aspect of the way in which we process your personal data, please contact us by e-mailing
hypnotherapystonestaffs@hotmail.com
You also have the right to complain to the UK’s data protection supervisory authority.
The Information Commissioner’s Office ICO. The ICO may be contacted via its website which is https://ico.org.uk/concerns/ or live chat or via their telephone helpline on 0303 123 1113.
You may of course exercise your right to legal action.

This policy was last updated 24th May 2018. It may be updated at any time, so please check back regularly to ensure that you are aware of the latest version.

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