Policy and Procedures - Privacy, Complaints, Cancellation, Ethical

Privacy Policy / Fair Processing Notice

What Information I Collect On You, Why I Collect it, What I Do With It

It is an essential part of my professional service to keep full and accurate records of all clients including contact details, medical history and current medical status, medication, supplementation and treatment details, and ongoing updates about each clients health and wellbeing and records of all treatment sessions. 
This is in order to provide the very best tailored, safe and effective treatments, and to evaluate the progress of a programme of treatments. I, Ceri Turner, collect and process personal data you give me for this purpose. 

The information asked for at your initial consultation, including your health and your medical history, are on the legal grounds of legitimate interestYou can, of course, refuse to provide the information, but if you were to do that I would not be able to provide treatment.

I require all clients to sign to say they agree to keep me updated as to any changes in their health and medical condition. This includes informing me of anything you believe to be affects of treatment. This is all necessary and legitimate interest. Beyond this, any personal information you choose to tell me is on the legal basis of consent, and further, you may ask me not to make a written note of it.  

All information you give me during your initial consultation and in subsequent sessions - whether or not it is recorded - is considered private and confidential and will not be shared without your express permission. 

The only exception is there there were a risk of death or serious harm to my client, myself or othersin which case relevant personal details would be disclosed only to the proper authorities, ie police, doctor, paramedics, court of law, or social services.

Security - 

     Paper - Full client notes are kept on paper only, kept securely, and only accessed by myself. 

     Digital - Brief details such as your name, email address, phone numbers (where provided), birth date, gender identity, which treatment type you had on your first appointment and the date of that appointment, whether you have come more than once, and whether or not you have given your consent to be on my mailing list are kept on the Gmail Contacts part of my email account, password secured on all platforms from which I access it (eg laptop, ipad, mobile phone). No medical or health information or other special or sensitive data (E.G. racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic and biometric data, sexual orientation, criminal convictions and offences) is kept digitally. 

You have a right to access personal information I hold about you within one month of your request, for information kept on paper I will provide photocopies. For information kept digitally I will provide screenshots or other appropriate digital version. 

You have the right to ask me to correct or remove information you think is inaccurate

Data Processing - I analyse data to help me understand my customer base. For example, I have analysed my customers by gender make-up, by the length of time people have been visiting me, by the total number of visits, and by the frequency of visits. This helps me understand, for example, how well I am attracting or retaining different kinds of clients, and to make decisions about e.g. marketing, pricing, customer service. Another example might be, I might analyse the number of people who come to me for different types of session, this would help me to make choices about training and professional development, and also to answer questionnaires from my professional body more accurately, for them to understand our Industry. 

Complaints. Please inform me if you think there is a problem with the way I am handling your data, and if you are not happy with the way I deal with the issue, you have the right to complain to the Information Commisioners Office. ICO

Communications. If you email or text me, or contact me by Facebook Messenger, I will assume you consent to me replying and having a conversation in that medium. 
If you give me your email address or phone number(s) at an initial visit, I will take this as consent to use them to communicate with you about appointments. However, you will have the choice whether or not to opt in to my mailing list for occasional newsletters, and my SMS text lists for notifications for available appointments are also on an opt in basis. You can opt out of these communications at any time, by telling me you wish to do so.

Children under the age of 16 are only treated with consent of a parent or legal guardian, and this consent will be considered to also cover consent to process personal data.

How Long Data is Kept - As per the
 stipulations of my professional association the FHT and my insurers, Hiscox, all client records are held for a minimum of 10 years after the date of your last appointment. In cases where there is any cause for concern - for instance, if the client had an adverse reaction during or after treatment - the records are kept indefinitely. If the client is a child, records will be kept for at least 10 years after they reach adulthood. After 10 years you may ask me to delete your records if you wish.

Data disposal - Any old client records that are disposed of will be disposed of securely and in a way that preserves confidentiality.

This policy was last edited on 22/5/2018

Complaints Procedure

As part of my membership of the FHT (Federation of Holistic Therapists) I am obliged to abide by a Code of Conduct (https://www.fht.org.uk/fs/s/v/code_of_conduct.pdf). Should you have any reason to raise a complaint in the first instance take this up with me, as your practitioner, and I will endeavour to resolve this to our mutual satisfaction.

If you are still not satisfied you can raise a complaint with the FHT by going to FHT Complaints Procedure and following the procedure outlined there.

Cancellation policy 

For non-attendance without 24 hours notice, I charge 50% of the fee for the appointment booked.

Ethical Policy

Professional Standards

High quality work, high quality customer care. 

Keeping the wellbeing and welfare of clients and prospective clients as a top priority at all times, in particular in regard to promoting health.

Openness and honesty in person and in my marketing.

Listening to my clients and adapting my service to their needs where appropriate.

Awareness of limits to my scope of practice - where appropriate recommending or referring to others.

Good practice in care and safeguarding of minors, elders and vulnerable people.

More details of the standards I adhere to at FHT Code of Conduct and Professional Practice.

Sustainable Economy

Shopping local where possible, both personally and for my business, particularly supporting other independently owned businesses (as opposed to chain stores and tax dodging corporations) to help develop a thriving ethical local economy.   

Recommending and otherwise supporting ethical local businesses.  

Participating in the  'Health and Wellbeing' sector group within ESTA, which I helped start, for mutual support and encouragement,  development of ethical practice, and initiatives to promote Complementary Health and Wellbeing locally.

Buying Fairtrade or from similar Ethical providers (eg Rainforest Alliance, etc) as much as possible when products are produced abroad. 

Environmental Care and Sustainability

Reducing energy usage, and reducing my carbon footprint. Eg by not using a car myself, and minimising transport miles on the products I buy.

Reducing, reusing, recycling, composting as much as possible, eg:

- I have made fleece sheets and wraps to use in place of paper where possible for hygiene
- my couch roll is recycled paper or sourced from managed forests with minimal bleaching;
- most of my furniture I bought or traded pre-owned.
The skin care products I use are non-toxic, not tested on animals, and as much as possible are pure, simple, and natural; free of human made chemicals; organic, naturally farmed or wild-crafted; and have not undergone processes with by products or effects that are harmful to the environment. They are also all Vegan with the exception of one non-vegan product, a balm containing beeswax, which I can not use if requested.

    Social Responsibility and Community

    Donating gift vouchers to raise money for good causes such as the Homeless Shelter at Christ Church.

    Volunteering my services occasionally for those in need who cannot afford them, eg sessions at the Tara Centre for Refugees and for those on little to no income.

    Using Facebook to promote local charities and other community organisations, initiatives and events.

    Inclusiveness, Accessibility and Non-Discrimination

    I do not discriminate on grounds of sex, gender identity or expression, or sexual orientation. Ie Holistyx is LGBTQIA+ friendly.  

    I do not discriminate on grounds of marital status, of ancestry, national or ethnic origin ('race'), or of religion, creed or belief - this is not effected by being in a Vicarage.

    Age - I am happy to work with older children, teenagers and older people. However, for babies, infants and very young children, and the very elderly, I may refer you to someone with more training and experience with those age groups.

    Disability - it depends on the issues - I will do my best to be accessible but I may recommend you go to someone with more training, experience or specialist equipment, resources or support where there is good reason to do so. If you have mobility issues, for example are a wheelchair user - be aware that there are steps at my door at the back of the property. However if this is the only obstacle to me providing you an accessible service I can arrange for use of the front door.

    Personal Wellbeing and Development

    Including myself in my holistic health and wellbeing care. It is good modelling for clients, and it is necessary to sustain working in this industry without harm*. 

    Striving to have a healthy lifestyle.

    Developing a treatment style with an awareness of posture, body mechanics, ergonomics and injury prevention*. 

    Looking after my body pre-and post treatment with joint mobilisations, stretches, Yoga and self-massage.

    Going to local practitioners for complementary health and wellbeing care myself, including massage and reflexology. This is not only good self care but keeps me in touch with differences and developments in practice. 

    Continuing Professional Development

    Engaging in ongoing learning and professional development to improve my knowledge and skills in service to others and for my own interest and satisfaction. This is also a requirement from my professional association. 

    Developing social, networking and educational opportunities and relationships, groups and communities that support them. 

    Eg, I co-founded and co-ordinated the FHT LLSG for 5 years, and still attend my local group. This is a local group in association with the Federation of Holistic Therapists. 

    It supports practitioners in the fields of complementary health care, holistic beauty and sports therapy and puts on talks, and demonstrations, on a broad range of related topics and practices. 

    This provides the opportunity practitioners in the area to do Continuing Professional Development and get 'CPD points' as required by the FHT and other professional associations.

    E.g The ESTA Health and Wellbeing group organises mini conferences for shared learning, development and networking.

    Seeking out professional supervision when issues arise in my practice which require professional support or scrutiny.

    * A survey on injury among American massage therapists found that an astounding 77% of practitioners complained of work-related pain and discomfort during the previous two years. From the same survey we learn that 64% of practitioners had symptoms that were serious enough to cause them to seek medical treatment, and 41% were diagnosed with a musculoskeletal disorder. The American Massage Therapy Association reveals that the average massage career does not last more than eight years. Save Your Hands! The Complete Guide to Injury Prevention and Ergonomics for Manual Therapists 2nd Edition Lauriann Greene CEAS and Richard W Goggins CPE LMP

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