The Complementary Therapy Schools Data Privacy Policy
YOUR PERSONAL INFORMATION DATA PROTECTION REGULATION (GDPR)
GDPR is bringing in new legal protection for personal information from May 2018.
This tells you what personal information I gather via my website, and why, and what your rights are.
The Complementary Therapy School
Address: Barry Business Centre, Main Street, Barry, Scotland, DD7 7RP.
Telephone No: 07961118183
Email address: melanie@thects.co.uk
Data Controller Contact Details: Melanie Bell – melanie@thects.co.uk
Purpose of processing Client Data
We hold and use client data in order to provide you with the best possible learning experience, support and advice.
We take information via our application form to allow us to make a decision on your suitability for the course. We also ask limited health information to ensure we can offer you the best learning experience.
Lawful Basis for holding and using case study Information
As a full member of the Association of Reflexologists, I abide by the AoR Code of Practice and Ethics. The lawful basis under which I hold and use your information is my legitimate interests i.e.my requirement to retain the information in order to provide you with the most appropriate training, follow up support, and advice
When you submit case studies as part of our therapy training course, the client cannot be identified. i.e. you cannot put on the consultation form the client’s name and contact details.
You are required to get signed privacy statements from any person you keep records on, including case studies. You will be required to submit a copy of this privacy statement along with any case study submitted to your tutor. A copy of this must be produced to the tutor during one of the teaching days.
As we may hold special category data (i.e. health related information) about you, the Additional Condition under which I hold and use this information is for us to fulfil our role as a Complementary Therapy trainer.
What information I hold and what I do with it
In order to give professional learning opportunities and follow up support to students the following information will be held:
• Your contact details
• Application forms
• Case studies submitted
• Course assignments
• Copies of certificates issued and records of students’ progress. I will NOT share your information with anyone else (other than with:
• An internal verifier
• An external verifier
• The Awarding body
• Students Awards Agency for Scotland
• The Association of Reflexologists (if required for quality verification purposes), or as required for legal process, or on your request to confirm that you have completed my course satisfactorily) without explaining why it is necessary, and getting your explicit consent.
Occasionally, we take pictures of our students in class and share these pictures on social media and other forms of advertising. If you do not want to take part in these pictures, you can opt out of these pictures at any time. It is not compulsory to take part in the pictures.
ID will be requested from you in person as a means of identification only. It will not be stored and the tutor will view your ID in class.
I may contact you using the contact preferences you give me in relation to
• Providing you with additional supporting material for the course
• Other information relevant to the course
• Reflexology information or information related to health
• Future training events, special offers and promotions (you may unsubscribe from this at any time)
Your data will not be transferred outside the EU without your consent.
Your personal contact details may be shared with the Association of Reflexologists (AoR) on completion of your course. The AoR may contact you to ask you to provide them with feedback on the course. This is part of the criteria for AoR CPD approval.
The AoR will only keep your information for 6 months and will only contact you in regards to feedback.
How Long I Retain Your Information for
I will keep your personal information for 3 Years.
Protecting Your Personal Data
I am committed to ensuring that your personal data is secure. In order to prevent unauthorised access or disclosure, I have put in place appropriate technical, physical and managerial procedures to safeguard and secure the information we collect from you.
Your Rights
GDPR gives you the following rights:
• The right to be informed: To know how your information will be held and used (this notice).
• The right of access: To see your tutor’s records of your personal information, so you know what is held about you and can verify it.
• The right to rectification: To tell your tutor to make changes to your personal information if it is incorrect or incomplete.
• The right to erasure (also called “the right to be forgotten”): For you to request your tutor to erase any information they hold about you
• The right to restrict processing of personal data: You have the right to request limits on how your tutor uses your personal information
• The right to data portability: under certain circumstances you can request a copy of personal information held electronically so you can reuse it in other systems.
• The right to object: To be able to tell your tutor you don’t want them to use certain parts of your information, or only to use it for certain purposes.
• Rights in relation to automated decision-making and profiling.
• The right to lodge a complaint with the Information Commissioner’s Office: To be able to complain to the ICO if you feel your details are not correct, if they are not being used in a way that you have given permission for, or if they are being stored when they don’t have to be.
Full details of your rights can be found at https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
If you wish to exercise any of these rights, please use the contact details given above.
If you are dissatisfied with the response you can complain to the Information Commissioner’s Office; their contact details are at: www.ico.org.uk