Privacy Notice

What is the purpose of this document?
I (Blossom Robin) am a data controller. This means that I am responsible for deciding how I hold and use personal information about you. I am required under data protection legislation to notify you of the information contained in this privacy notice.

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Data protection principles
I will comply with data protection law. This means that the personal information that I hold about you must be:
• Used lawfully, fairly and in a transparent way.
• Collected only for valid purposes that I have clearly explained to you and not used in any way that is in compatible with those purposes.
• Relevant to the purposes I have told you about and limited only to those purposes.
• Accurate and kept up to date.
• Kept only as long as necessary for the purposes I have told you about.
• Kept securely.

The information I hold about you
I will collect, store and use the following categories of personal information about you:
• Personal contact details such as name, title, addresses, telephone numbers and personal email addresses.
• Date of birth.
• Gender.
• Marital status and dependants.
I may also collect, store and use the following more sensitive types of personal information:
• Information about your health, including any medical condition, health and sickness records, as well as contact details of your GP.
• Information about your race, ethnicity, religious beliefs, sexual orientation and political opinions.

How is your personal information collected?
I collect personal information about you through the consultation process, either directly from you, or through any third party referring you to me.

How I will use information about you.
I will only use your personal information when the law allows me to. Most commonly I will use your personal information in the following circumstances:
• Where I need to perform the contract I have entered into with you.
• Where I need to comply with a legal obligation.
• Where it is necessary for legitimate interests pursued by me (or a third party) and your interests and fundamental rights do not override those interests.
I may also use your personal information in the following situations, which are likely to be rare:
• Where I need to protect your interests (or someone else’s interests).
• Where it is needed in the public interest, or for official purposes.
I need all the categories of information in the list above primarily to allow me to perform the contract with you and to enable me to comply with legal obligations. In some situations, I may use your personal information to pursue legitimate interests, provided your interests and fundamental rights do not override those interests.
The situations in which I will process your personal information are listed below.
• Assessing your suitability for the services I may provide to you.
• Carrying out background and reference checks, where applicable.
• Communicating with you about appointments to fulfil our contract.
• Keeping records relating to your appointments.
• Complying with legal or regulatory requirements.
It is in my legitimate interests to collect and use your personal data to be able to reach a decision as to your compatibility with my services since it would be beneficial to my business. I also need to process your personal information to decide whether to enter into a contract with you. If you fail to provide information when requested which is necessary for me to consider, I may not be able to perform the contract entered with you, or I may be prevented from complying with my legal obligations.

How I use particularly sensitive personal information
Special categories of particularly sensitive personal information require higher levels of protection. I may process special categories of personal information in the following circumstances:
• With your explicit written consent.
• Where I need to carry out my legal obligations.
• Where it is needed in the public interest.
The situations where I will process your particularly sensitive personal information are listed below:
• I will use information about your physical or mental health to assess, provide and record appropriate treatments. I need to process this information to perform the contract between us and comply with my legal obligations.
• I will use information about your race or ethnic origin, religious, philosophical or moral beliefs, or your sexual orientation, to assess, provide and record appropriate treatments. I need to process this information to perform the contract between us and comply with my legal obligations.

Automated decision-making
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. I do not envisage that any decisions will be taken about you using automated means, however I will notify you in writing if this position changes.

Data sharing
I will share your personal information with third parties where required by law, where it is necessary to administer the contract with you or where I have another legitimate interest in doing so. For example, in the appointment processes.

Data security
I have put in place measures to protect the security of your information. Details of these measures are available on request. In addition, I limit access to your personal information to agents and other third parties who have a business need-to-know. For example, in the appointment processes for the services provided under our contract. I 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 I am legally required to do so.

Data retention
I will retain your personal information for a minimum period of seven years from when the contract with you ends. I will only retain your personal information for as long as necessary to fulfil the purposes I collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. After this period, I will securely destroy your personal information.

Rights of access, correction, erasure and restriction
It is important that the personal information that I hold about you is accurate and current. Please keep me informed if your personal information changes. Under certain circumstances, by law you have the right to:
• Request access to your personal information.
• Request correction of the personal information that I hold about you.
• Request erasure of your personal information.
• Object to processing of your personal information where I am relying on a legitimate interest. You also have the right to object where I am processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information.
• Request the transfer of your personal information to another party.
You will not have to pay a fee to access your personal information or to exercise any other rights. However, I may charge a reasonable fee if your request for access is clearly unfounded or excessive or I may refuse to comply with the request in such circumstances.

Right to withdraw consent
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 me. Once I have received notification that you have withdrawn your consent, I will no longer process your information for the purpose(s) you originally agreed to, unless I have another legitimate basis for doing so in law.

Coronavirus and COVID-19

In light of the recent COVID-19 pandemic, I am obliged to share necessary contact data with Test and Trace agencies, if requested.  This would only be necessary if I am notified that either myself or a client or any other relevant person received a positive COVID-19 test result.

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

Acknowledgment of receipt
In order to acknowledge that you have been properly informed of my data collection and handling practices, you confirm that you have read and understood this data privacy notice by signing and dating the initial client consultation document. This acknowledgement will also confirm and demonstrate your explicit written consent for me to process your particularly sensitive personal information. I will provide a copy of this privacy notice to you on request.