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Privacy Policy

Somatic Tao’s core beliefs regarding user privacy and data protection

  • User privacy and data protection are human rights
  • Somatic Tao has a duty of care to the people within its data
  • Data is a liability, it should only be collected and processed when absolutely necessary
  • Somatic Tao loathes spam as much as you do!
  • Somatic Tao will never sell, rent or otherwise distribute or make public your personal information

Purpose of privacy notice

The processing of personal data is governed by the General Data Protection Regulation 2016/679 (the GDPR).  This legislation replaces current data privacy law, giving more rights to you as an individual and more obligations to organisations holding your personal data.

One of the rights is a right to be informed, which means we have to give you even more information than we do now about the way in which we use, share and store your personal information.

This means that we are publishing a new privacy notice so you can access this information, along with information about the increased rights you have in relation to the information we hold on you and the legal basis on which we are using it.

This new privacy notice comes into effect on 25 May 2018 and was published on our website at that time.

Who is Somatic Tao?

Somatic Tao is the data controller and processor.  This means we decide how your personal data is processed and for what purposes.  Our email contact is info@somatictao.co.uk .  You can also apply in writing: please email Somatic Tao for the correct postal address. 

Whose information does this privacy notice apply to?

This privacy notice applies to information we collect from:

  • patients;
  • prospective patients;
  • former patients;
  • people who subscribe to Somatic Tao’s newsletters;
  • visitors to Somatic Tao’s website

What is personal data?

Personal data relates to a living individual who can be identified from that data.  Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession.  Examples of personal data we may hold about you include your contact and appointment details.

Special category data is a sub-category of personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.  Examples of special category data we may hold about you include your patient notes.

How does Somatic Tao process your personal data?

We comply with our obligations under the GDPR by keeping personal data up to date; by storing, (if electronic then password protected; if hardcopy then held in a locked secure place)and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.  We use your personal data for the purposes set out below.

Sections 1 – 15 apply to our patients, prospective patients, former patients and visitors to our clinic

  1. We use your name, address, telephone number and email address to make and rearrange appointments. We are unable to send or receive encrypted emails or texts so you should be aware that any emails or texts we send or receive may not be protected in transit. We will also monitor any emails or texts sent to us, including file attachments, for viruses or malicious software.  Please be aware that you have a responsibility to ensure that any email you send us is within the bounds of the law.

 

  1. We use your name, address, telephone number and email address, only if we have your explicit consent, to send you marketing materials. We are unable to send or receive encrypted emails so you should be aware that any emails we send or receive may not be protected in transit.  We will also monitor any emails sent to us, including file attachments, for viruses or malicious software.  Please be aware that you have a responsibility to ensure that any email you send us is within the bounds of the law.

 

  1. Some patients and prospective patients return pre- 1stappointment questionnaires or tell us about their medical conditions and medication by email or mobile phone text. We are unable to send or receive encrypted emails or texts so you should be aware that any emails we send or receive may not be protected in transit.  We will also monitor any emails or texts sent to us, including file attachments, for viruses or malicious software.  Please be aware that you have a responsibility to ensure that any email you send us is within the bounds of the law.

 

  1. We keep a permanent attendance register which records all appointments for patients attending our clinic to keep a record of when you were treated for tax purposes and to secure potential evidence in the event of a criminal prosecution, civil litigation, insurance claim or complaint to my regulatory body, the Complementary Therapists Association, (CThA).

 

  1. We may use your date of birth to help identify patients with the same name to avoid mistakes being made as to safe and appropriate treatment, for identification purposes if referring a patient to another health practitioner, and for identification purposes if writing to a registered medical practitioner so that they correctly identify the patient.

 

  1. We use your presenting complaint and symptoms reported by you for the purposes of making a diagnosis, formulating treatment strategy and treatment planning.

 

  1. We use any relevant medical and family history you have told us for making a diagnosis, formulating treatment strategy and treatment planning.

 

  1. We use your GP’s name and address in the event that we need to contact your GP including in an emergency.

 

  1. We use our clinical findings about your health and wellbeing for making a diagnosis, and formulating treatment strategy and treatment planning.

 

  1. We keep a record of and refer to that record of any treatment given and details of progress of your case, including reviews of treatment planning to enable us to: review the diagnosis, treatment strategy and planning; and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint.

 

  1. We record and use any information and advice that we have given, especially when referring patients to any other health professional, to help you to receive the most appropriate treatment and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint.

 

  1. We record any decisions made in conjunction with you to help you to receive the most appropriate treatment and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint.

 

  1. We keep accident records for any patients, visitors or staff who are involved in accidents at our clinic in accordance with UK Health and Safety legislation including the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations (RIDDOR) to comply with the law and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint.

 

  1. In the event of an adverse incident occurring to any of our patients we report the matter to the Complementary Therapists Association, (CThA) and our insurance company to enable the insurance company to deal with any potential claims and to help the Complementary Therapists Association to develop its safe practice guidelines, as well as providing research data and information for the CThA’s insurers and other interested parties.

 

  1. Where relevant we maintain records of the patient’s consent to treatment, or the consent of their next-of-kin in order to be able to prove that the patient (and/or parent/guardian/next of kin) has given informed consent to treatment to secure evidence in the event of a civil claim, criminal prosecution, insurance claim or complaint.

Section 16 applies to those who complain about our services

  1. When we receive a complaint from a person we make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint.

We will only use the personal information we collect to process the complaint and to check on the level of service we provide.  We usually have to disclose the complainant’s identity to whoever the complaint is about.  If a complainant doesn’t want information identifying him or her to be disclosed, we will try to respect that.  However, it may not be possible to handle a complaint on an anonymous basis.  We may need to provide personal information collected and processed in relation to complaints to the Complementary Therapists Association, (CThA) or our insurance company.

We will keep personal information contained in complaint files in line with our retention policy.  This means that information relating to a complaint will be retained for two years from closure.  It will be retained in a secure environment, (if electronic then password protected; if hardcopy then held in a locked secure place) and access to it will be restricted according to the ‘need to know’ principle.

Similarly, where enquiries are submitted to us we will only use the information supplied to us to deal with the enquiry and any subsequent issues and to check on the level of service we provide.

Sections 17 – 22 apply to our website users

  1. When someone visits our website we use a third party service, Google Analytics, (GA), to collect standard internet log information and details of visitor behaviour patterns. Somatic Tao uses such information to improve our website user experience and better understand our website users.   This GA information is collected anonymously.  We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website.  If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.

Although GA records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to Somatic Tao.  GA also records your computer’s IP address which could be used to personally identify you but Google does not grant Somatic Tao access to this.  Somatic Tao considers Google to be a third party data processor.

In addition to Google Analytics, this website may collect* information (held in the public domain) attributed to the IP address of the computer or device that is being used to access it. The information is supplied to Somatic Tao from Whoisvisiting.com. Whoisvisiting.com is a service offered by Whoisdata Limited. The Whoisvisiting system does not use your IP address to identify you, the individual, in any way. No cookies are used by the Whoisvisiting system.

* The Whoisvisiting system will only lookup information when a static IP address is being used. Differences between a static and dynamic IP address.

More information about how Whoisvisiting uses IP addresses. 

  1. Our website includes an email hyperlink. When you click on the hyperlink to send an email to us, none of the data that you supply via the email hyperlink will be stored by this website or passed to / be processed by any of the third party data processors defined below in this document. Instead the data will be collated into an email and sent to us over the Simple Mail Transfer Protocol (SMTP).  Our SMTP servers are protected by TLS (sometimes known as SSL) meaning that the email content is encrypted using SHA-2, 256-bit cryptography before being sent across the internet. The email content is then decrypted by our local computers and devices.

 

  1. Our website contains links to enable you to visit other websites of interest easily. However, once you have used these links to leave our site, you should note that we do not have any control over that other website.  Therefore, we cannot be responsible for the protection and privacy of any information that you provide whilst visiting such sites and such sites are not governed by this privacy statement.  You should exercise caution and look at the privacy statement applicable to the website in question.

 

  1. We use a number of third parties to process personal data on our behalf. These third parties have been carefully chosen and all of them comply with the necessary legislation for privacy.

 

  1. To host our website we use a third party service, MCCIT, (a trading name of Florentino Limited within a UK data centre located Reynolds House, Manchester, M15 5RN, United Kingdom). MCCIT uses hardware firewalls to protect their servers which lock people out if they fail to enter the correct hosting credentials.  In the event that an account is compromised, each account is protected by a technology called “cloud lynux” which basically means that hackers will not be able to access other accounts from that one account.  In the event that another account is hacked on MCCIT’s shared hosting platform the Somatic Tao website should be safe.

Some of the data centre’s more notable security features as at 04 April 2018 are as follows:

  • Server cabinets have locked doors (no open racks)
  • Perimeter and internal IP CCTV system monitored 24×7
  • 24×7 on-site security guards with static and mobile patrols
  • All on-site personnel are security vetted to BS7858 standard
  • All traffic (transferral of files) between Somatic Tao’s website and your browser is encrypted and delivered over HTTPS

For more information about how MCCIT processes data, please see their Privacy Policy

 

  1. We use website cookies to improve user experience of our website by enabling our website to ‘remember’ users, either for the duration of their visit – using a ‘session cookie’ – or for repeat visits – using a ‘persistent cookie’.  For more detailed information regarding our cookie policy please check here.

Sharing your personal data

Your personal data will be treated as strictly confidential, and will be shared:

  • with named third parties with your explicit consent;
  • with the relevant authority such as the police or a court, if necessary for compliance with a legal obligation to which we are subject e.g. a court order;
  • with your doctor or the police if necessary to protect yours or another person’s life;
  • with the police or a local authority for the purpose of safeguarding a children or vulnerable adults; or
  • with my regulatory body, the Complementary Therapists Association, or my insurance company in the event of a complaint or insurance claim being brought against me; or
  • my solicitor in the event of any investigation or legal proceedings being brought against me.
  • the Therapeutic Executor of my Therapeutic Will should Somatic Tao be unable to continue practicing due to an emergency, serious illness or death

For further details about the situations when information about you might be shared please see the Information Commissioner’s website at https://ico.org.uk/for-the-public/personal-information/sharing-my-info/

How long does Somatic Tao keep your personal data?

We keep your personal data for no longer than reasonably necessary.

We keep patient records for a period of 7 years post conclusion of therapeutic relationship in accordance with the Complementary Therapists Association (CThA),Code of Professional Conduct http://www.ctha.com/CodeOfPractice/.   At the end of the 7 years all electronic records relating to the patient will be deleted and all paper hard copy material relating to the patient will be shredded in a cross-cutting shredder.

During the mandated retention period of 7 years patients will be required to notify in writing, changes to their personal data to enable their records to remain up to date. Such changes can be made at any time.

Should Somatic Tao be unable to continue practicing due to an emergency, serious illness or death, a “Therapeutic Will” will be invoked where the appointed Therapeutic Executor would have primary responsibility to ensure that patients are notified and referred, confidential records are protected and financial matters are dealt with.

Your rights and your personal data

Unless subject to an exemption under the GDPR, you have certain rights with respect to your personal data as set out below.

  • The right to request a copy of your personal data which we hold about you.
  • The right to request that we correct any personal data if it is found to be inaccurate or out of date.
  • The right to request your personal data is erased where it is no longer necessary for us to retain such data.
  • The right to withdraw your consent to the processing at any time. This right does not apply where we are processing information using a lawful purpose other than consent.
  • The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable) [This right only applies where the processing is based on consent or is necessary for the performance of a contract with you and in either case the we are processing the data by automated means].
  • The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing.
  • The right to object to the processing of personal data, (where applicable) [This right only applies where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics].
  • The right to be informed if your data is lost or exposed to an unlawful data breach. We shall also inform the Information Commissioner’s Office in accordance with the time limits in the GDPR.
  • The right to lodge a complaint with the Information Commissioner’s Office.

For further details about these rights please see the Information Commissioner’s website at https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/

Further processing

If we wish to use your personal data for a new purpose, not covered by this Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.

Contact Details

To exercise all relevant rights, queries of complaints please in the first instance contact our Data Controller and Processor by email: info@somatictao.co.uk

You can also contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.

Changes to Somatic Tao’s Privacy Policy

This privacy policy may change from time to time inline with legislation or industry developments.  We will not explicitly inform our clients or website users of these changes.  Instead, we recommend that you check this page occasionally for any policy changes. Specific policy changes and updates are mentioned in the change log below.

Change log 

  • 31/05/2017 Privacy policy amended to include requirements for Cookies
  • 23/05/2018 Privacy policy amended to included requirements for GDPR

 END OF PRIVACY NOTICE