GENERAL DATA PROTECTION REGULATION (GDPR) PRIVACY NOTICE
Michelle Mulliss Health Care and London Kent Acupuncture understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our clients and will only use personal data in ways that are described here and in a way that is consistent with our obligations and your rights under the law.
1. Information About Us
Michelle Mulliss Health Care, including London Kent Acupuncture Natural Fertility UK and Fertile Foods.
Main trading addresses
10 Harley Street, London, W1G 9PF
Godinton Clinic, Kent, TN23 3PQ
Abbey Place Clinic, Kent, ME13 7BG
Data Protection Officer: Michelle Mulliss CEO Owner
Email address: Info@michellemulliss.com
Telephone number: 020 8 242 6508
Postal Address: 10 Harley Street, London, W1G 9PF
We are on the Data Protection Register held by the ICO
2. What Does This Notice Cover?
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
3. What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out below.
4. What Are My Rights?
Under the GDPR, you have the following rights, which we will work to uphold:
1. The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions.
2. The right to access the personal data we hold about you.
3. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us to find out more.
4. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us to find out more.
5. The right to restrict (i.e. prevent) the processing of your personal data.
6. The right to object to us using your personal data for a particular purpose or purposes.
7. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
8. Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
5. What Personal Data Do You Collect?
We may collect some or all of the following personal data :
Name; Date of birth; Gender; Address; Email address; Telephone number; Business name; Job title; Profession; Payment information; Insurance details and Accredited Body Registration details.
6. How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary as a medical professional and hold a contract with you for consent of treatment to be carried out, or because you have consented to our use of your personal data to advise you of any health matters and events held by us that may be of interest to you. Your personal data will be used for the following purposes:
1. Providing and managing your case history.
2. Supplying appointment confirmation to you.
3. Making payment using PAYPAL services.
4. Communicating with you. This may include responding to emails or calls from you.
5. Supplying you with information by email or text.
6. With your permission and/or where permitted by law, we may also use your personal data for purposes relating only to our business, which may include contacting you by email, telephone or post with information, news and events held by Michelle Mulliss and her companies.
7. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to optout.
7. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for a fixed period of 8 years following the regulations by medical law and that of the professional membership of The British Acupuncture Council.
8. How and Where Do You Store or Transfer My Personal Data?
We will only store or transfer your personal data in the UK, held by an online computer software. This information is only accessible to those employed by the company and practitioners treating you. This is not shared with any other company.
This means that it will be fully protected under the GDPR.
9. Do You Share My Personal Data?
We will not share any of your personal data with any third parties for any purposes except under the following limited circumstances.
1. We may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority such as the NHS or other private health care and insurance companies with regards to your health care.
2. We may contract with third parties to supply services on our behalf. These may include PAYPAL payment processing, delivery for any products you may purchase from us, and marketing platforms from our websites.
3. If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely and in accordance with your rights, our obligations, and the third party’s obligations under the law.
10. How Can I Access My Personal Data?
1. If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
2. All subject access requests should be made in writing and sent to the email or postal addresses shown. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
3. There is a nominal administrative charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) further fees may be charged to cover our administrative costs in responding.
4. We will respond to your subject access request within 14 working days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of progress.
11. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Tracey Ongley PA to Michelle Mulliss):
Email address: firstname.lastname@example.org
Telephone number: 020 8 242 6508
Postal Address: 10 Harley Street London WG1 9FP
12. Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Information relating to any changes will be made available via email.