This document refers to personal data, which is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain.
The General Data Protection Regulation (GDPR) which is EU wide and far more extensive than its predecessor the Data Protection Act, along with the Privacy and Electronic Communications Regulations (PECR), seek to protect and enhance the rights of EU data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU and its storage within the EEA.
1 – MY BUSINESS
Jo Hamilton Yoga, which hereafter for the purposes of this Privacy Notice will be referred to as Jo Hamilton, is pleased to provide the following information:
2 – WHO I AM
I am a Yoga Teacher, Certified Neurogenic Yoga Teacher and Advanced TRE Trauma Release Practitioner and Mentor. Relax and Renew Trainer in Restorative Yoga, Total Yoga Nidra Teacher and Accredited certified Advanced EFT Practitioner.
I support clients to release physical and emotional trauma and to release stress. Based in Devon UK I run weekly classes, 1:1 therapy sessions, Workshops and host Residential Retreats.
3 – PERSONAL DATA
- a) For the purposes of providing support, Jo Hamilton may require detailed medical information. Jo will only collect what is relevant and necessary for your support. When you attend a session, Jo will make notes which may include details concerning your medication, treatment and other issues affecting your health. This data is always held securely, is not shared with anyone not involved in your treatment. To be able to process your personal data it is a condition of any treatment that you give your explicit consent to allow Jo Hamilton to document and process your personal data. Contact details provided by you such as telephone numbers, email addresses, postal addresses may be used to remind you of future appointments and provide reports or other information concerning your treatment. As part of my obligation as a practitioner there may be circumstances related to your treatment, on-going care or medical diagnosis that will require the sharing of your medical records with other healthcare practitioners e.g GPs, consultants, surgeons and/or medical insurance companies. Where this is required Jo will always inform you first unless we are under a legal obligation to comply.
- b) For appointments made with Jo via the Estuary Clinic, The Estuary Clinic requires personal details; including contact details such as telephone numbers, email addresses, postal addresses. This information is used to arrange and manage bookings within the Clinic. Personal details may be used to remind you of future appointments, clinical auditing and for accountancy purposes.
- c) For marketing purposes, Jo Hamilton may also use the contact details provided by you to respond to your enquiries, including making telephone contact and emailing information to you which she believes may be of interest to you.
- d) In making initial contact with Jo Hamilton you consent to Jo maintaining a marketing dialogue with you until you either opt out (which you can do at any time) or we decide to desist in promoting our services. You can ask to be removed from her marketing database by emailing or phoning her using the contact details provided at the end of this Privacy Notice.
- e) Some basic personal data may be collected about you from the marketing forms and surveys you complete, from records of our correspondence and phone calls and details of your visits to Jo’s website wwwjohamiltonyoga.co.uk, including but not limited to, personally identifying information like Internet Protocol (IP) addresses.
- g) Jo Hamilton will only collect the information needed so that she can provide you with the services you require, the business does not sell or broker your data.
4 – CONSENT
Through agreeing to this privacy notice you are consenting to Jo Hamilton processing your personal data for the purposes outlined. You can withdraw consent at any time by using the postal, email address or telephone number provided at the end of this Privacy Notice.
5 – DISCLOSURE
Jo Hamilton will keep your personal information safe and secure. Jo Hamilton will not disclose your Personal Information unless compelled to, in order to meet legal obligations, regulations or valid governmental requests.
6 – RETENTION POLICY
Jo hamilton will process personal data during the duration of any client support and will continue to store only the personal data needed for eight years after the contract has expired to meet any legal obligations. After eight years all personal data will be deleted, unless basic information needs to be retained by us to meet our future obligations to you, such as erasure details. Records concerning minors who have received support will be retained until the child has reached the age of 25.
7 – THIRD PARTY DATA PROCESSORS & DATA STORAGE
Jo Hamilton uses a number of third parties to process personal data on her behalf. These third parties have been carefully chosen and, to the best of her belief and understanding, all of them comply with current GDPR legislation. The following third parties are based in the USA where we have signed Standard EU contractual clauses for data transfers between EU and non-EU countries in place or the services are privacy shield protected.
8 – YOUR RIGHTS AS A DATA SUBJECT
At any point whilst Jo Hamilton is in possession of, or processing your personal data, all data subjects have the following rights:
- Right of access – you have the right to request a copy of the information that Jo holds about you.
- Right of rectification – you have a right to correct data that Jo holds about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data Jo holds about you to be erased from our records.
- Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.
- Right of portability – you have the right to have the data Jo holds about you transferred to another organisation.
- Right to object – you have the right to object to certain types of processing such as direct marketing.
- Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.
In the event that Jo Hamilton refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge. At your request Jo Hamilton can confirm what information it holds about you and how it is processed.
9 – YOU CAN REQUEST THE FOLLOWING INFORMATION:
- The purpose of the processing as well as the legal basis for processing.
- If the processing is based on the legitimate interests of Jo Hamilton and information about these interests.
- The categories of personal data collected, stored and processed.
- Recipient(s) or categories of recipients that the data is/will be disclosed to.
- How long the data will be stored.
- Details of your rights to correct, erasure, restrict or object to such processing.
- Information about your right to withdraw consent at any time.
- How to lodge a complaint with the supervisory authority (ICO).
- Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
- The source of personal data if it wasn’t collected directly from you.
- Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
10 – TO ACCESS WHAT PERSONAL DATA IS HELD, IDENTIFICATION WILL BE REQUIRED
Jo Hamilton will accept the following forms of identification (ID) when information on your personal data is requested: a copy of your driving licence, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If Jo is dissatisfied with the quality, further information may be sought before personal data can be released. All requests should be made to firstname.lastname@example.org 07714253992
12 – COMPLAINTS
In the event that you wish to make a complaint about how your personal data is being processed by Jo Hamilton you have the right to complain to Jo. If you do not get a response within 30 days, you can complain to the ICO.
The details for each of these contacts are:
Telephone 0771 4253992 or email: email@example.com
Wycliffe House, Water Lane, Wilmslow, SK9 5AF Telephone +44 (0) 303 123 1113 or email: https://ico.org.uk/global/contact-us/email/