Privacy notice

Privacy notice


Purpose of privacy notice
The processing of personal data is governed by the General Data Protection Regulation 2016/679 (the GDPR). This legislation will replace current data privacy law, giving more rights to you as an individual and more obligations to organisations holding your personal data.
This new privacy notice comes into effect and will be published on our Website on 25 May 2018.

Who I am
Sandra Arbelaez as I work as an independent practitioner, I am the “data controller” in this case and can be contacted at chinesemedicinebristol@gmail.com. This means it is me who decides how your personal data is processed and for what purposes.
Whose information does this privacy notice apply to?
This privacy notice applies to information I collect from:
· patients;
· prospective patients;
· former patients;
· visitors to my Website;

What is personal data?
Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. Examples of personal data I may hold about you include your contact and appointment details.

Special category data is a sub-category of personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. Examples of special category data I may hold about you include your patient notes, which are completely confidential.

Why do I need to collect your personal data?

I take your privacy very seriously and because of this I will only use any personal information you give me to provide you with the treatments and health advice you have requested of me.  There are four main reasons for you to supply personal details to me, and for me to store and process these details:

1. Your requesting treatment and my agreement to provide it constitutes a contract between us. To honour this contract, I need to collect personal information about you and your health in order to provide you with the best possible treatment. You can, of course, refuse to provide the information, but if you Ire to do that I would not be able to provide treatment.                                                             2. I have a “Legitimate Interest” in collecting that information, because without it I couldn’t do my job effectively and safely.                                                                                                                                     3. I may use your phone number and email address to contact you in order to confirm your appointments with me or to update you on matters related to your health needs. This again constitutes “Legitimate Interest”, but this time it is your legitimate interest.                                                4. I am constantly updating my knowledge and, every year or two, I sing up to sponsored charitable acts such as the Bristol 10K, to raise funds for organisations that help people with health issues access relevant treatments. Provided I have your consent, I may occasionally send you information regarding any new qualifications, new treatments, and fundraising activities. You may withdraw this consent at any time – just let me know by any convenient method.

How do I process your personal data?
I comply with the obligations under the GDPR by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data. I use your personal data for the purposes set out below.

1. I use your name, address, telephone number and email address to make and rearrange appointments. I am unable to send or receive encrypted emails so you should be aware that any emails I send or receive may not be protected in transit. I will also monitor any emails sent to me, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send me is within the bounds of the law.
2. I may use your name, telephone number, or email address, only if I have your explicit consent, to send you marketing materials. These marketing materials will only consist of updates on my new qualifications and therapies I offer, and about fundraising events that I perform from time to time to help organisations that enable access to health to those who cannot normally access them. I am unable to send or receive encrypted emails so you should be aware that any emails I send or receive may not be protected in transit. I will also monitor any emails sent to me, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send me is within the bounds of the law.
3. Some patients and prospective patients return pre- 1st appointment questionnaires or tell me about their medical conditions and medication by email or online enquiry forms. I am unable to send or receive encrypted emails so you should be aware that any emails I send or receive may not be protected in transit. I will also monitor any emails sent to me, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send me is within the bounds of the law.
4. I use your presenting complaint and symptoms reported by you, your medical and family history, and my clinical findings about your health and Illbeing for the purposes of making a full traditional diagnosis, formulating treatment strategy and treatment planning.
5. I keep a record of and refer to that record of any treatment given and details of progress of your case, including reviews of treatment planning to enable me to: review the full traditional diagnosis, treatment strategy and planning; and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint.
6.I record and use any information and advice that I have given, especially when referring patients to any other health professional, to help you to receive the most appropriate treatment and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint.
12. I record any decisions made in conjunction with you to help you to receive the most appropriate treatment and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint.
7. When someone visits my Website I use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. 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 anyone. I do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our Website. If I do want to collect personally identifiable information through our Website, 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.                                                               8. My Website uses cookies to improve user experience of our Website by enabling the Website to ‘remember’ users, either for the duration of their visit – using a ‘session cookie’

Sharing your personal data
Your personal data will be treated as strictly confidential, and will be shared:

. with suppliers of herbal prescriptions how will only require your name and, if sending the prescription             directly to you, also your address but no other personal data
· with named third parties with your explicit consent;
· with the relevant authority such as the police or a court, if necessary for compliance with a legal obligation to which I are subject e.g. a court order;
· with your doctor or the police if necessary to protect yours or another person’s life;
· with the police or a local authority for the purpose of safeguarding a children or vulnerable adults; or
· with my regulatory bodies, the Association of Traditional Chinese Medicine and Acupuncture and the Register of Chinese Herbal Medicine, or my insurance company in the event of a complaint or insurance claim being brought against me; or
· my solicitor in the event of any investigation or legal proceedings being brought against me.

How long do I keep your personal data?
I keep your personal data for no longer than reasonably necessary.
I keep patient records for a period of 7 years in accordance with the British Acupuncture Code of Professional Conduct https://www.acupuncture.org.uk/public-content/effective-practice/bacc-professional-codes.html

Your rights and your personal data
Your personal data is kept on paper files in a locked filing cabinet and are burned when no longer required. Some contact details are kept on my mobile devices which password protected.
Provision is made to what will happen to your records in the event of my retirement or death.
Unless subject to an exemption under the GDPR, you have certain rights with respect to your personal data as set out below. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, I may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.
· The right to request a copy of your personal data which I hold about you.
· The right to request that I correct any personal data if it is found to be inaccurate or out of date.
· The right to request your personal data is erased where it is no longer necessary for me to retain such data.
· The right to withdraw your consent to the processing at any time. This right does not apply where I are processing information using a lawful purpose other than consent.
· The right to request that I provide you with your personal data and where possible, to transmit that data directly to another data controller (eg. another practitioner)
· The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing.
· The right to object to the processing of personal data, (where applicable) [This right only applies where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics].
· The right to be informed if your data is lost. I shall also inform the Information Commissioner’s Office in accordance with the time limits in the GDPR.
· The right to lodge a complaint with the Information Commissioner’s Office.
For further details about these rights please see the Information Commissioner’s Website at https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/
Further processing
If I wish to use your personal data for a new purpose, not covered by this Privacy Notice, then I will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, I will seek your prior consent to the new processing.

Contact Details
To exercise all relevant rights, queries of complaints please in the first instance contact me at
chinesemedicinebristol@gmail.com

If you are not satisfied with the response, then you have the right to raise the matter with the Information Commissioner’s Office.


END OF PRIVACY NOTICE