Photo Courtesy of Chris Pullen
This policy relates to Trayah Remedial & Sports Massage (Trayah) which is located at:
13 St Catherine's Vale
WHY THE INFORMATION IS REQUIRED
The lawful basis by which Trayah holds this information is held under Special Category Data: Health. In order to provide an effective and safe massage therapy treatment, Trayah requires information about your current health and your medical history. This information is used only to provide you with the best possible course of treatment and advice. Trayah also requires your contact details to arrange appointment times with you. As a registered and accredited massage therapist with the FHT (Federation of Holistic Therapies), I abide by the associations’ Code of Conduct and confidentiality requirements.
WHAT INFORMATION DOES TRAYAH COLLECT ABOUT YOU
Trayah collects information about you when you first book in for a treatment (whether by telephone, email or through our website booking form at www.trayah.uk).
By your first appointment you will have provided your personal and contact details (name, address, DOB, email address) and a fully completed Client History Form (previous treatment history, injury history, current medication and other health-related information) and a Covid-19 Declaration Form. Treatment notes relating to the reason for treatment, the treatment provided, any assessments and future plans are also held and held electronically with Cliniko – a specific patient software package).
Cliniko treat security of information as a priority. Data is encrypted, backed up automatically and kept in ultra secure facilities. Please visit www.cliniko.com for more information.
Upon signing the client history form you are agreeing that Trayah will keep your details confidential and abide by current GDPR guidelines. You also agree that Trayah can contact you via telephone, text message and email regarding your appointments and treatments with me. This also includes the occasional marketing/promotional update of our products, services and availability. An option to unsubscribe is always included if you would no longer like me to contact you.
Personal data is collected such as:
Date of birth
Emergency contact or next of kin details
Health conditions including allergies, medication and doses, history of; injuries, operations, illnesses provided on the client intake form and discussed during the first and subsequent treatments
GP surgery details and other body treatments currently and previously received
Lifestyle covering an overview of: exercise, diet, sleep and stress levels
Information on current physical state (i.e. aches/pains/tension)
Treatment detail and assessment notes which will be recorded after each massage session
Diarised records of appointment times
If you object to the collection and use of your personal data I may be unable to provide you with my services.
HOW WILL WE USE THE INFORMATION GATHERED?
Trayah requires this information to assess your massage treatment requirements and provide you with a safe and effective massage therapy. Additionally, the information is used to refer to at subsequent treatments in order to assess levels of improvement. The information may be shared with another Massage Therapist or with another health practitioner should you be referred to one of these by Trayah. This will only be done with your consent.
Your information will not be shared with anyone else (other than required for legal process) without explaining the reason why this is necessary and obtaining your explicit consent. The contact information you provide may be used by Trayah to contact you in relation to appointment times or dialogue regarding your treatment plan.
HOW LONG IS THE INFORMATION HELD FOR?
Trayah is required to keep your information for a period of 7 years after your last treatment for insurance purposes. Your data will not be transferred without your consent. Once every two years, Trayah will review all client records and destroy any records that are no longer bound by the regulated legal timescale for such records to be held.
Trayah is committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, suitable physical, electronic and managerial procedures have been put in place to safeguard and secure the information that is collected both online and on paper. This includes the use of Cliniko, 2 factor authentication, password protections, retina passwords. Any health and personal information gathered on paper is stored securely in a locked filing cabinet in a locked clinic room.
In the event of a data breach which consists of a breach of security leading to destruction, loss, alteration, unauthorised disclosure of or access to personal data, Trayah understands ICO have to be notified where it is likely to result in a risk to the rights and freedoms of individuals. In the event of such a breach, Trayah will notify those concerned directly and without delay. Records of personal data breaches will be maintained in any case.
YOUR INDIVIDUAL RIGHTS
Individuals are provided with legal rights governing the use of their personal data. These grant individuals the right to understand what personal data relating to them is held, for what purpose, how it is collected and used, with whom it is shared, where it is located, to object to its processing, to have the data corrected if inaccurate, to take copies of the data and to place restrictions on its processing. Individuals can also request the deletion of their personal data.
These rights are known as Individual Rights under the Data Protection Act 2018. The following list details these rights:
The right to be informed about the personal data being processed;
The right of access to your personal data;
The right to rectification if there is something incorrect or incomplete;
The right to erasure of your personal data;
The right to limit how the information is used or shared;
The right to portability. Under certain circumstances a copy of electronically held information can be requested so it can be reused in other systems;
The right to object if there are certain parts of an individual’s information that they do not want used or to be used only for certain purposes
Rights in relation to automated decision-making and profiling;
The right to lodge a complaint with the Information Commissioner’s Office. An individual can complain to the ICO if the individual feels the information held is incorrect or not being used in the permission was granted or if information is being held unnecessarily. Full details of individual’s rights can be held at:
If you are dissatisfied with any aspect of the way in which we process your personal data please contact Trayah at the above address. You also have the right to complain to the UK’s data protection supervisory authority, the Information Commissioner’s Office (ICO). The ICO many be contacted via its website which is https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.
If an individual does not agree to Trayah keeping records of information about an individual and treatment records then it will not be possible to provide the therapy. Additionally, massage therapists have to keep records of treatment for a specific period of time as described above which may mean that even if you ask for information to be erased, they might be bound to keep these details until the period has elapsed.