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 interest. You 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 if there were a risk of death or serious harm to my client, myself or others, in 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., including medical history and notes from Consultations and treatment sessions are kept on paper only, kept securely, and only accessed by myself.
Digital - Google: You may give me medical and health information by email. If you would rather not do so, please request to do so by another medium, eg by phonecall. 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 on Google Contacts. You can find more information about Google's Privacy policy at https://policies.google.com/privacy?hl=en-US
Digital - Acuity: The intake forms you fill in as part of the booking process are stored on Acuity. You can see information about their security, and compliance with privacy laws including GDPR at https://help.acuityscheduling.com/hc/en-us/articles/219149587 and the pages it links to. I have disabled the option on Acuity which would send me a copy of your intake forms by email, as I believe Acuity to have a higher standard of security to email.
Digital - Stripe: Payments on Acuity are made through Stripe. If you choose to use this service, you are covered by the privacy terms detailed at: https://stripe.com/gb/privacy - in particular those in relation to 'Customer of a Stripe User'. I am the Stripe user, you are my customer if you use their service to pay me. If you do not wish to use Stripe, it is not required to pay at booking, and there are other ways to pay available, including cash. Please enquire.
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.
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.
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.
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.
Your Data Protection Rights
Under data protection law, you have rights including:
Your right of access - You have the right to ask us for copies of your personal information. For information kept on paper I will provide photocopies. For information kept digitally I may provide screenshots, or other appropriate digital version such as an uploaded file, or I may provide print outs.
Your right to rectification - You have the right to ask us to correct or remove personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.
Your right to object to processing - You have the the right to object to the processing of your personal information in certain circumstances.
Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
Complaints. Please inform me if you have any concerns about my use of your personal information (my contact details are listed below) 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).
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk
Contact Details:
Name: Ms Ceri Turner
Address: 604 Alston House, White Cross Business Park, Lancaster, Lancashire, LA1 4XQ
Phone Number: 07888 692803
Email: Holistyx@gmail.com
This policy was last edited on 29/09/2020
Should you have any reason to raise a complaint please raise it with me and I will do my best to resolve it to our mutual satisfaction.
For non-attendance without 24 hours notice, I charge 50% of the fee for the appointment booked.
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.
From 2013 - 2023, participating in ESTA - The Ethical Small Traders Association - and the 'Health and Wellbeing' sector group within, 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.
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.
Address: 604 Alston House, White Cross Business Park, Lancaster, Lancashire, LA1 4XQ
Phone Number: 07888 692803
Email: Holistyx@gmail.com
This policy was last edited on 29/09/2020
Complaints Policy
Should you have any reason to raise a complaint please raise it with me and I will do my best to resolve it to our mutual satisfaction.
Cancellation Policy
For non-attendance without 24 hours notice, I charge 50% of the fee for the appointment booked.
As of August 2020, an exception will be made if cancellation is due to symptoms emerging which the person cancelling reasonably believed could be caused by a cold, flu or Covid-19; because another member of the client's household or someone they have been in close contact with has tested positive for Covid-19 or has Covid-19 symptoms and they have decided they must self-isolate; because they been told to isolate by the NHS Test and Trace service, a Health Professional, local Public Health Officer or Border Control, or because their medical practitioner has advised against it, or for other legal, infection control or health protection measure that arose at short notice where the client was not able to inform me of this prior to the 24 hour cancellation period.
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 protecting and 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.
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.
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. From 2013 - 2023, participating in ESTA - The Ethical Small Traders Association - and the 'Health and Wellbeing' sector group within, 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.
Donating gift vouchers to raise money for good causes.
Using Facebook to promote local charities and other community organisations, initiatives and events.
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.
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. My premises is accessible for wheelchair users, and there is Blue Badge holder parking nearby (see location page for details).
Social Responsibility and Community
Donating gift vouchers to raise money for good causes.
Volunteering my services occasionally for those in need who cannot afford them.
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.
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. My premises is accessible for wheelchair users, and there is Blue Badge holder parking nearby (see location page for details).
The high standard of Covid safety measures increases accessibility, especially for clinically vulnerable people.
Engaging in ongoing learning and professional development to improve my knowledge and skills in service to others and for my own interest and satisfaction.
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. This was a local group in association with the Federation of Holistic Therapists, supporting practitioners in the fields of complementary health care, holistic beauty and sports therapy and putting on talks, and demonstrations, on a broad range of related topics and practices. This provided 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. 2013 - 2023, participating in ESTA - The Ethical Small Traders Association - and participating in the ESTA Health and Wellbeing group which I co-founded soon after joining in 2013 - including mini conferences for shared learning, development and networking.
Seeking out professional supervision when issues arise in my practice which require professional support or scrutiny.
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.
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.
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. This was a local group in association with the Federation of Holistic Therapists, supporting practitioners in the fields of complementary health care, holistic beauty and sports therapy and putting on talks, and demonstrations, on a broad range of related topics and practices. This provided 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. 2013 - 2023, participating in ESTA - The Ethical Small Traders Association - and participating in the ESTA Health and Wellbeing group which I co-founded soon after joining in 2013 - including mini conferences for shared learning, development and networking.
Seeking out professional supervision when issues arise in my practice which require professional support or scrutiny.
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