In accordance with the General Data Protection Regulation (GDPR) I have implemented this privacy notice to provide you, my clients, with details of how I collect and process your personal data. I also include within this policy the reasons for processing your data, the lawful basis that permits me to process it, how long I keep your data for and your rights regarding your data.
JM Physiotherapy Services is the data controller and I am responsible for your/your child’s personal data (referred to as “I”, “me” or “my” in this privacy notice).
I am also the Data Protection Officer who is in charge of privacy related matters. If you have any questions about this privacy notice, please let me know.
My full details are:
Data Protection Officer: Joanna McMeechan
Full name of legal entity: JM Physiotherapy Services
Email Address: firstname.lastname@example.org
If you are not happy with any aspect of how I collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). I should be grateful if you would contact me first if you do have a complaint, so that I can try to resolve it for you.
It is very important that the information I hold about my clients is accurate and up to date. Please let me know if at any time yours/your child’s personal information changes by emailing me at email@example.com
WHAT DATA DO I COLLECT ABOUT YOU?
Personal data means any information capable of identifying an individual. It does not include anonymised data.
I may process certain types of personal data about you/your child as follows:
Identity Data may include your first name, maiden name, last name, marital status, title, date of birth, NHS/hospital number and gender.
Contact Data may include your address, email address and telephone numbers.
Financial Data may include your bank account and payment card details.
Transaction Data may include details about invoices.
Marketing and Communications Data may include your preferences in receiving marketing communications from me and your communication preferences.
External medical records may include records I collect from you, external records from GPs/consultants/procedures. These will always be collected with your consent.
Treatment notes may include notes written during and following your/your child’s consultations and assessments.
I may also process Aggregated Data from your/your child’s personal data but this data does not reveal your/your child’s identity and as such in itself is not personal data. An example of this is where I review your/your child’s Profile Data to give me statistics on feedback received from clients. If I link the Aggregated Data with your/your child’s personal data so that you can be identified from it, then it is treated as personal data.
I collect sensitive data about your/your child’s health to help me assess and treat you/your child appropriately. I do not collect any other Sensitive Data about you/your child. Sensitive data refers to data that includes details about your/your child’s race or ethnicity, religion or philosophical beliefs, political opinions, trade union membership, information about your health and genetic and biometric data. I do not collect any information about criminal convictions and offences.
HOW I COLLECT YOUR PERSONAL DATA
I collect data about you/your child through a variety of different methods including:
- Direct interactions: You may provide data by filling in forms either in person or by communicating with me by post, phone, email or otherwise, including when you:
book an appointment with me; buy products from me;
give me feedback; or
- during your/your child’s consultation
Personal data is kept within the online medical portal WriteUpp. This is the administrative client record model that I use to store my Client Data.
HOW I USE YOUR PERSONAL DATA
The law on data protection allows me to process your/your child’s data for certain reasons only. In the main, I process your/your child’s data to comply with a legal requirement or in order to manage your/your child’s treatment.
Generally, I do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing me at firstname.lastname@example.org
Purposes for processing your personal data
Set out below is a description of the ways I intend to use your/your child’s personal data and the legal grounds on which I will process such data. I have also explained what my legitimate interests are where relevant.
I may process your/your child’s personal data for more than one lawful ground, depending on the specific purpose for which I are using your/your child’s data. Please email me at email@example.com if you need details about the specific legal ground I am relying on to process your/your child’s personal data.
|Purpose/Activity||Type of data||Lawful basis for processing|
|To register you/your child as a new client||Identity Contact||Legal obligation|
|To provide effective physiotherapy treatment using external medical notes and treatment notes.||Identity Contact
Treatment notes External medical notes
|To manage my relationship with you/your child which will include:
Asking you to leave a review or take a survey.
Marketing and Communications
|To ensure I receive payment for treatments and products.||Identity Contact
|To administer and protect my business and my site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).||Identity Contact
|Necessary for my legitimate interests for running my business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise Legal obligation|
|To use data analytics to improve my website, products/services, marketing, customer relationships and experiences.||Technical Usage||My legitimate interests.
To develop my business and inform my marketing strategy
You will receive marketing communications from me if you have requested information from me or purchased goods or services from me and you have not opted out of receiving that marketing.
You can ask me to stop sending you marketing messages at any time by emailing me at firstname.lastname@example.org
Where you opt out of receiving my marketing communications, this will not apply to personal data provided to me as a result of a service or product purchase, or other transactions.
Change of purpose
I will only use your/your child’s personal data for the purposes for which I have collected it, unless I reasonably consider that I need to use it for another reason and that reason is compatible with the original purpose. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email me at email@example.com
If I need to use your/your child’s personal data for a purpose unrelated to the purpose for which I collected the data, I will notify you and I will explain the legal ground of processing.
I may process your/your child’s personal data without your knowledge or consent where this is required or permitted by law.
DISCLOSURES OF YOUR PERSONAL DATA
I may have to share your personal data with the parties set out below for the purposes set out in the table above:
- Service providers who provide IT and system administration services (WriteUpp).
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
- My Accountancy supplier and my online Accountancy package supplier.
I require all third parties to whom I transfer your/your child’s data to respect the security of your/your child’s personal data and to treat it in accordance with the law. I only allow such third parties to process your/your child’s personal data for specified purposes and in accordance with my instructions.
I have put in place appropriate security measures to prevent your/your child’s personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, I limit access to your/your child’s personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your/your child’s personal data on my instructions and they are subject to a duty of confidentiality.
I have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where I am legally required to do so.
I will only retain your/your child’s personal data 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.
To determine the appropriate retention period for personal data, I consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your/your child’s personal data, the purposes for which I process your/your child’s personal data and whether I can achieve those purposes through other means, and the applicable legal requirements.
By law I have to keep basic information about my clients (including Contact, Identity, Treatment notes, External medical notes and Transaction Data) for seven years after they cease being clients for tax purposes. For children, I keep data for seven years after their 18th birthday or until they are 25 years old. For children with a lifelong condition, records are kept for 30 years or for 8 years after the Client’s death, as per current government recommendations.
In some circumstances you can ask me to delete your/your child’s data: see below for further information.
In some circumstances I may anonymise your/your child’s personal data (so that it can no longer be associated with you) for research or statistical purposes in which case I may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your/your child’s personal data. These include the right to:
- Request access to your/your child’s personal data.
- Request correction of your/your child’s personal data.
- Request erasure of your/your child’s personal data.
- Object to processing of your/your child’s personal data.
- Request restriction of processing your/your child’s personal data.
- Request transfer of your/your child’s personal data.
- Right to withdraw consent.
You can see more about these rights at:
If you wish to exercise any of the rights set out above, please email me at firstname.lastname@example.org
You will not have to pay a fee to access your/your child’s 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. Alternatively, I may refuse to comply with your request in these circumstances.
I may need to request specific information from you to help me confirm your identity and ensure your right to access your/your child’s personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. I may also contact you to ask you for further information in relation to your request to speed up my response.
I try to respond to all legitimate requests within one month. Occasionally it may take me longer than a month if your request is particularly complex or you have made a number of requests. In this case, I will notify you and keep you updated.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you/your child. I do not control these third-party websites and are not responsible for their privacy statements. When you leave my website, I encourage you to read the privacy notice of every website you visit.