Last updated: April 16, 2024
Control and Change (“us”, “we”, or “our”, “Control and Change Hypnotherapy”) operates the Control and Change website, also known as Control and Change Hypnotherapy website, (the “Service”).
CONTROL AND CHANGE
UK GDPR 2021 and PRIVACY POLICY V2 2024
At Control and Change we understand that your privacy is important to you and that you care about how your personal data is used. We are committed to protecting and respecting your privacy.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting our website you are accepting and consenting to the practices described in this policy. We use your Personal Information for providing and improving the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. If you do not accept and agree with this privacy policy, you must stop using our site immediately.
Scope
This privacy notice (sometimes referred to as a privacy policy or privacy statement) concerns personal data, which is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain.
The UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations (PECR), seek to protect and enhance the rights of UK data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and its storage within the UK.
This Privacy Policy applies only to your use of our site. Our site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them. We have no control over, and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
For the purpose of the General Data Protection Regulation, the data controller Control and Change, based at Lordswood Osteopathic Clinic, Lordswood Leisure Centre, North Dane Way, Chatham, Kent, ME5 8YE, which hereafter for the purposes of this Privacy Notice will be referred to as the “we”, “us” or “our”, are pleased to provide the following information:
What is Personal Data
Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioners Office (ICO).
Personal Data
a) For the purposes of providing treatment, we may require detailed medical, mental health or personal information. We will only collect what is relevant and necessary for your treatment. When you visit our practice, we will make notes which may include details concerning your medication, treatment and other issues affecting your health. This data is always held securely, is not shared with anyone not involved in your treatment, although for data storage purposes it may be handled by pre-vetted staff who have all signed an integrity and confidentiality agreement. To be able to process your personal data it is a condition of any treatment that you give your explicit consent to allow us to document and process your personal data. Contact details provided by you such as telephone numbers, email addresses, postal addresses may be used to remind you of future appointments and provide reports or other information concerning your treatment. As part of our obligations as primary healthcare practitioners there may be circumstances related to your treatment, on-going care or medical diagnosis that will require the sharing of your medical records with other healthcare practitioners e.g GPs, consultants, surgeons and/or medical insurance companies. Where this is required we will always inform you first unless we are under a legal obligation to comply.
b) For marketing purposes, we may also use the contact details provided by you to respond to your enquiries, including making telephone contact and emailing information to you which the practice believes may be of interest to you.
c) In making initial contact with the practice you consent to us maintaining a marketing dialogue with you until you either opt out (which you can do at any time) or we decide to desist in promoting our services. We may occasionally also act on behalf of our patients in the capacity of data processor, when we may promote other practitioners based at our premises, who may not be employed by us. We do not broker your data and you can ask to be removed from our marketing database by emailing or phoning the practice using the contact details provided at the end of this Privacy Notice.
d) Personal data may be collected about you from the marketing forms and surveys you complete, health and/or nutritional therapy questionnaires or forms, from records of our correspondence and phone calls and details of your visits to our website, including but not limited to, personally identifying information like Internet Protocol (IP) addresses or by making payments online or by credit/debit cards.
e) Our website uses cookies, which is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Wix.com uses cookies to help us to identify and track visitors and their website access preferences. Our website visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using our website. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
f) We will only collect the information needed so that we can provide you with the services you require, the business does not sell or broker your data.
g) If you send us an email, we may collect your name, your email address, and any other information which you choose to give us, and we may use them to respond to your email. We will not share any of your data with any third parties for any purposes [other than storage on an email server].
h) We will use this information: to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
Legal basis for processing any personal data
To meet our contractual obligations obtained from explicit Patient Consent and legitimate interest to respond to enquiries concerning the services provided.
Legitimate interests pursued by us
To promote treatments for patients with different types of mental health or dietary problems indicated for hypnotherapy and nutritional therapy care.
Consent
Through agreeing to this privacy notice you are consenting to us processing your personal data for the purposes outlined. You can withdraw consent at any time by using the postal, email address or tele- phone number provided at the end of this Privacy Notice.
Children’s Privacy
Our Service does not address anyone under the age of 18 without parental consent (“Children”). A parent must always be present during all appointments.
We do not knowingly collect personally identifiable information from children under 18 without parental consent. If you are a parent or guardian and you are aware that your child has provided us with Personal Information, without your consent, please contact us. If we discover that a child under 18 has provided us with Personal Information without consent, we will delete such information immediately.
Disclosure
We will keep your personal information safe and secure, only staff engaged in providing your treatment will have access to your patient records, although our administration team will have access to your contact details so that they can make appointments and manage your account. We will not disclose your Personal Information unless compelled to, in order to meet legal obligations, regulations or valid governmental requests. The practice may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of its staff.
External Third Parties Service
• Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in the UK who provide CONSULTANCY, BANKING, LEGAL, INSURANCE AND ACCOUNTING SERVICES.
• HM Revenue & Customs, regulators and other authorities ACTING AS PROCESSORS based IN THE UNITED KINGDOM WHO REQUIRE REPORTING OF PROCESSING ACTIVITIES IN CERTAIN CIRCUMSTANCES.
Data Retention Policy
We will process personal data during the duration of any treatment and will continue to store only the personal data needed for eight years after the contract has expired to meet any legal, accounting or reporting obligations and requirements. After eight years all personal data will be deleted, unless basic information needs to be retained by us to meet our future obligations to you, such as erasure details. Records concerning minors who have received treatment will be retained until the child has reached the age of 25.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Data storage
All Data is held in the United Kingdom.
Information Collection And Use
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information (“Personal Information”) may include, but is not limited to:
Log Data
We collect information that your browser sends whenever you visit our Service (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages and other statistics.
Cookies
Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer’s hard drive.
We use “cookies” to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Some third party companies may also deploy cookies when using their services through this website. Please see their separate policies for details.
However, in the interests of a smoother customer journey and process, calendly.com provides booking services on this site, with cookie messages hidden, therefore if you do not accept, please discontinue use of the booking service and contact us using the details at the end of this policy.
Service Providers
We may employ third party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform Service-related services or to assist us in analysing how our Service is used.
These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Security
The security of your Personal Information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.
Your rights as a data subject
At any point whilst we are in possession of, or processing your personal data, all data subjects have the following rights:
• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or
incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be
erased from our records.
• Right to restriction of processing – where certain conditions apply you have a right to restrict the
processing.
• Right of portability – you have the right to have the data we hold about you transferred to another
organisation.
• Right to object – you have the right to object to certain types of processing such as direct market-
ing.
• Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.
In the event that we refuse your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge. At your request we can confirm what information it holds about you and how it is processed.
You can request the following information:
• Identity and the contact details of the person or organisation (us) that has determined how and why to process your data.
• Contact details of the data protection officer, where applicable.
• The purpose of the processing as well as the legal basis for processing.
• If the processing is based on the legitimate interests of us and information about these interests.
• The categories of personal data collected, stored and processed.
• Recipient(s) or categories of recipients that the data is/will be disclosed to.
• How long the data will be stored.
• Details of your rights to correct, erasure, restrict or object to such processing.
• Information about your right to withdraw consent at any time.
• How to lodge a complaint with the supervisory authority (ICO).
• Whether the provision of personal data is a statutory or contractual requirement, or a requirement
necessary to enter into a contract, as well as whether you are obliged to provide the personal data
and the possible consequences of failing to provide such data.
• The source of personal data if it wasn’t collected directly from you.
• Any details and information of automated decision making, such as profiling, and any meaningful
information about the logic involved, as well as the significance and expected consequences of such processing.
To access what personal data is held, identification will be required. We will accept the following forms of identification (ID) when information on your personal data is requested: a copy of your driving licence, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If we are dissatisfied with the quality, further information may be sought before personal data can be released. All requests should be made to paul@controlandchange.co.uk or by phoning +44 07902 633694 or writing to us at the address further below.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
CCTV
Control and Change and the osteopathic clinic do not have CCTV inside the clinic, however, the Lordswood Leisure Centre does have CCTV covering the car park and all the internal corridors including the one leading to the main door of the Lordswood Osteopathic Clinic. The recordings from these CCTV cameras are kept onsite and the controller of these is the Lordswood Leisure Centre’s General Manager – Mr Spencer Grimwade. The recordings are not stored by any other outside company and are kept onsite for two weeks, after which time they are then deleted. Should you wish to have access to these recordings please contact Mr Spencer Grimwade on 01634 682862.
Complaints
In the event that you wish to make a complaint about how your personal data is being processed by us, you have the right to complain to us. If you do not get a response within 30 days, you can complain to the ICO.
The details for each of these contacts are:
Paul Wren, Control and Change, Lordswood Osteopathic Clinic, Lordswood Leisure Centre, North Dane Way, Chatham, Kent, ME5 8YE. Tel: 07902 633694 or email: paul@controlandchange.co.uk
ICO
Wycliffe House, Water Lane, Wilmslow, SK9 5AF
Tel +44 (0) 303 123 1113 or email: https://ico.org.uk/global/contact-us/email/
Changes to our privacy policy
Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.
We may change or update this privacy policy in the future. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection. Any changes will be posted on this page and you will be deemed to have accepted the terms of the policy on your first use of our site following the changes.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
Please check back frequently to see any updates or changes and keep up-to-date.
Contact Us
If you have any questions about this Privacy Policy, please contact us.