Privacy Policy

Introduction:

Anna Grubb is committed to protecting and respecting your privacy. This is a statement is to inform you about all the information that I record about you.

This notice, along with the Client Registration and Consent Form, sets out the conditions under which I may process any information that I may collect from you, or that you provide to me. In the context of this statement, processing data, means collecting, storing, transferring, using or otherwise acting on information. This is in accordance with current General Data Protection Regulations and the UK Data Protection Act 2018. Any further changes to this notice will be posted on this page.

The types of personal data I collect and use:

I may collect personal data in the form of:

  • Personal details including; full name, address, telephone numbers, email address, date of birth, emergency contact details and other personal details,
  • Health history including; medical / chronic conditions, meditation and doses, mental health diagnosis, hospitalisation, current physical, mental and emotional situation and other health information,
  • Client notes, which may include; significant observations, relevant injuries, position preferences, and body maps where relevant,
  • Marketing preferences,
  • Record of payments.

This information:

  • Is given freely by yourself and is deemed true and correct at the time. This is collected by myself only. Updates to your data must be provided to me by yourself as soon as it is known,
  • I use a manual paper collection process for the primary source of data,
  • To perform my function, I use this information to encompass a complete picture of your situation. Information is only shared with my supervisory team or insurers where necessary,
  • Names and telephone numbers are used for effective direct communication

Cookies

  • A cookie is a small text file which is placed onto your computer (or other electronic device such as a mobile telephone or tablet) when you use my website.  I use cookies on my website.  I do this to find out things such as the number of visitors to the various parts of the site.  This information is only processed in a way which does not identify you individually. I use analysis software to look at IP addresses and cookies to improve your experience as a user of my website.  I do not use this information to develop a personal profile of you.  If I do collect personally identifiable information, I will be up front about this.  I will make it clear when I collect personal information and will explain what I intend to do with it.
  • You can set your browser not to accept cookies and you can remove cookies from your browser.  However, some of my website features may not function as a result.

Legal basis for processing personal data

I will process your personal data:

  • On the basis of our contractual agreement, for example:
  1. To be able to carry out Rosen Method Bodywork sessions with you,
  2. To ensure the safety of you as a client and me as a practitioner,
  3. For my accountancy purposes,
  4. To fulfil my insurance requirements,
  5. To update my records,
  6. To trace your whereabouts to contact you about your client file and any outstanding financial liability,
  7. For good governance, accounting, and managing of business operations,
  8. To monitor emails, calls, other communications, and activities related to your client file.
  • As necessary to comply with legal obligation, for example:
  1. When you exercise your rights under data protection law and make requests,
  2. For compliance with legal requirements and related disclosures,
  3. For establishment and defence of legal rights,
  4. For activities relating to the prevention, detection and investigation of crime.
  • Based on your consent, for example:
  1. When you request that I disclose your personal data to other people or organisations, or otherwise agree to disclosures,
  2. To send you marketing communications where I have asked your consent to do so.

Sharing your personal data:

Subject to applicable data protection law I may share your personal data with:

  • My supervisory team,
  • Companies and other persons providing services to me (such as emails being processed through my email provider or website provider),
  • My legal and professional advisers,
  • Courts, to comply with legal requirements, and for the administration of justice,
  • In an emergency or to otherwise protect your vital interests,
  • To protect the security and integrity of my business operations,
  • Anyone else where I have your consent, or it is required by law.

Information relating to your method of payment

You can pay by cash, cheque or bank transfer (using your name as a reference) and I will keep a record of payments made.

Please note that any cancellation of a session within 24 hours of the agreed session time will be charged at the full rate.

Information relating to becoming a Newsletter Subscriber

On my Client Registration and Consent Form, you can opt-in to the Rosen Method Training and Therapy Ltd newsletter to receive regular newsletters by their third-party provider. You can unsubscribe at any time. By signing up for their newsletters you also agree to the user and privacy notices of their third-party Mailchimp.

Alternatively, you can choose to sign up to this via their website directly: https://www.rosenmethod.co.uk/resources/#newsletter

Contacting you and your marketing preferences

I will use your email address, phone numbers and home address to contact you. You can change your preferences or unsubscribe to any marketing at any time by contacting me.

Retention periods

Your client record will be kept for 5 years after your last Rosen Method Bodywork session with me as a requirement of my insurance policy and for the following reasons:

  • I will retain your personal data for as long as you might legally bring claims against me,
  • I will retain your personal data for as long as required in accordance with legal and regulatory requirements.

Your rights under applicable data protection law

Your rights are as follows (noting that these rights don’t apply in all circumstances and that Data Portability is only relevant from May 2018).

  • The right to be informed about my processing of your personal data,
  • The right to object to processing of your personal data,
  • The right to have your personal data erased (the ‘right to be forgotten’),
  • The right to restrict processing of your personal data,
  • The right to have your personal data corrected if it’s inaccurate and to have incomplete personal data completed,
  • The right to move, copy or transfer your personal data (‘data portability’).

As the data subject, you have the right to request access to all data held on you. Should you wish to request this please email directly to [email protected] You shall receive your requested data within 1 calendar month of the initial request.

Complaints

When you send me a complaint, I record all the information that you have given me. I use that information to resolve your complaint. If your complaint reasonably requires me to contact some other person including my supervisory team and insurers, I may decide to give to that other person some of the information contained in the complaint.

If I think your complaint is vexatious and without any basis, I shall not correspond to you about it.

You have the right to complain to the Information Commissioner’s Office. It has enforcement powers and can investigate compliance with data protection law. You can do so via their website: www.ico.org.uk  

Security, data storage and data destruction

All measures are taken to prevent unauthorised or unlawful processing and against accidental loss, destruction or damage of your personal and sensitive data. No third party has access to your data except where relevant my supervisory team or insurers.

  • Paper files are stored and locked securely in a filing cabinet where only Anna Grubb has full access to. These files are only retrieved prior to appointment, or to check details. They are subsequently returned immediately after use,
  • You may share information via email communication or via my website contact from,
  • Where necessary, I may share information with my supervisory team or insurers over the telephone, by email, in writing or in person,
  • At the end of the retention period, paper files will be shredded and securely disposed of. All emails will be securely deleted.

Further information and queries

If you have any questions about this privacy statement, please contact:

[email protected]

Anna Grubb
Rosen Method Intern (Practitioner in Training under Supervision)

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