The General Data Protection Regulation (GDPR) which is EU wide and far more extensive than its predecessor the Data Protection Act, along with the Privacy and Electronic Communications Regulations (PECR), seek to protect and enhance the rights of EU data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU and its storage within the EEA.

1 – Thrive Sevenoaks, based at Oldbury Lodge, Oldbury Lane, Ightham, Sevenoaks, TN15 9DE which hereafter for the purposes of this Privacy Notice will be referred to as Thrive, is pleased to provide the following information:

2 – Who I am
Thrive offer relaxing therapeutic foot reflexology treatments which are carried out in accordance with the Association of Reflexology patient charter. The practice also provides other treatments: facial and sports reflexology.

3 – Personal Data
a) For the purposes of providing treatment, Thrive may require detailed medical information. I will only collect what is relevant and necessary for your treatment. When you visit my practice, I  will make notes which may include details concerning your medication, treatment and other issues affecting your health. This data is always held securely and is not shared with anyone . To be able to process your personal data it is a condition of any treatment that you give your explicit consent to allow Thrive to document and process your personal medical 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. 

b) For marketing purposes, Thrive 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 Thrive maintaining a marketing dialogue with you until you either opt out (which you can do at any time) or until I decide to desist in promoting my services.  Thrive do not broker your data and you can ask to be removed from my marketing database by emailing or phoning the practice using the contact details provided at the end of this Privacy Notice.
d) Some basic personal data may be collected about you from the marketing forms and surveys you complete, from records of my correspondence and phone calls and details of your visits to my website, including but not limited to, personally identifying information like Internet Protocol (IP) addresses.
e) Thrive’s 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. WordPress.org uses cookies to help Thrive to identify and track visitors and their website access preferences. Thrive website visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using Thrive’s website.
f) Thrive will only collect the information needed so that I can provide you with the services you require, my business does not sell or broker your data.

4 – Legal basis for processing any personal data
To meet my contractual obligations obtained from explicit Patient Consent and legitimate interest to respond to enquiries concerning the services provided.

5 – Consent
Through agreeing to this privacy notice you are consenting to Thrive processing your personal data for the purposes outlined. You can withdraw consent at any time by using the postal, email address or telephone number provided at the end of this Privacy Notice.

7 – Disclosure
Thrive will keep your personal information safe and secure.  Thrive 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 my safety.

8 – Retention Policy
Thrive 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 obligations. After eight years all personal data will be deleted/shredded, unless basic information needs to be retained by me 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.

9 – Data storage
All Data is held in the United Kingdom. Thrive does not store personal data outside the EEA. Information is stored alphabetically as paper notes in a locked filing cabinet in the clinic treatment room. Archived notes are also stored in the same place for access.  In the event of clinic closure or death of the data processor/controller, the following arrangements are in place for patient’s to access their records: Upon patients written requests,  the ESO’s data controller’s husband: Greg Watson will have access to the filing cabinets and data.  In the event of ESO being sold the future owner will have the legal duty to comply with this data protection policy.  

10 – Your rights as a data subject
At any point whilst Thrive is 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 I hold about you.
• Right of rectification – you have a right to correct data that I hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data I 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 I hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• 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 Thrive refuses your request under rights of access, I will provide you with a reason as to why, which you have the right to legally challenge. At your request Thrive can confirm what information it holds about you and how it is processed.

11 – You can request the following information:

• Identity and the contact details of the person or organisation (Thrive) that has determined how and why to process your data.
• Contact details of the data protection officer (Natasha Watson), 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 Thrive 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.

12 – To access what personal data is held, identification will be required
Thrive 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 Thrive is dissatisfied with the quality, further information may be sought before personal data can be released. 

All requests should be made to: 

email natasha@thrivesevenoaks.co.uk 

phone:  +44 (0) 7776131028 

address: Oldbury Lodge, Oldbury Lane, Ightham, Sevenoaks, Kent, TN15 9DE