Name: Elaine Murphy
Tel: 087 1717204
ARCHTI Membership Number: JUL1058 Date Created/Updated: 29/06/2020
WHY THE INFORMATION IS REQUIRED
The lawful basis by which I hold this information is held under Special Category Data: Health.
In order to provide an effective and safe massage therapy treatment, I require information about your current health and your medical history. This information is used only to provide you with the best possible course of treatment and advice. I also require your contact details to arrange appointment times with you.
As a registered massage therapist with ARCHTI (Association of Registered Complementary Holistic Therapists Ireland), I abide by this associations codes of conduct and confidentiality requirements.
FROM WHERE THE INFORMATION IS GATHERED
Downtime Massage may collect personal information from:
Email or Text messages sent from individuals to Downtime Massage.
Discussions with clients during the consultation process and during subsequent treatments and through all consultation forms and client record keeping forms.
WHAT INFORMATION IS HELD
Downtime Massage may collect the following personal information:
· Name, title and date of birth.
· Contact information including email address, telephone numbers and home address.
· Medical history and other health related information provided on the consultation form and discussed during the first and subsequent treatments.
· Treatment detail and assessment notes which will be recorded after each massage session.
· Follow up information which may be discussed with you by phone, email or text after your treatment.
· Diarised records of appointment times.
WHAT IS DONE WITH THE INFORMATION GATHERED
Downtime Massage requires this information to assess your massage treatment requirements and provide you with a safe and effective massage treatment. Additionally, the information is used to refer to at subsequent treatments in order to assess levels of improvement.
The information may be shared with another Massage Therapist or with another health practitioner should you be referred to one of these by Downtime Massage. This will only be done with your consent. Your information will not be shared with anyone else (other than required for legal process) without explaining the reason why this is necessary and obtaining your explicit consent.
The contact information you provide may be used by Downtime Massage to contact you in relation to appointment times or dialogue regarding your treatment plan.
HOW LONG THE INFORMATION IS HELD
Downtime Massage is required to keep your information for a period of 7 years after your last treatment for insurance purposes. Your data will not be transferred without your consent.
Disposal of Data: Once per year, Downtime Massage will review all client records and destroy any records that are no longer bound by the regulated legal timescale for such records to be held.
Downtime Massage is committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, suitable physical, electronic and managerial procedures have been put in place to safeguard and secure the information that is collected both online and on paper.
The health information gathered is held on paper consultation forms and treatment notes and is stored securely in a locked filing box. None of this information other than your name, phone number and/or email address is held electronically. Contact details including telephone numbers and email addresses are held on a password protected telephone and personal computer.
In the event of a data breach which consists of a breach of security leading to destruction, loss, alteration, unauthorised disclosure of or access to personal data, Downtime Massage understands ICO have to be notified where it is likely to result in a risk to the rights and freedoms of individuals. In the event of such a breach, Downtime Massage will notify those concerned directly and without delay. Records of personal data breaches will be maintained in any case.
The GDPR May 18 gives an individual: -
· The right to be informed as to how personal information will be both used and held. This is contained within this document.
· The right to access your personal information so individuals know what is held about them and they can confirm it.
· The right to rectification if there is something incorrect or incomplete.
· The right to have information deleted.
· The right to limit how the information is used or shared.
· The right to portability. Under certain circumstances a copy of electronically held information can be requested so it can be reused in other systems.
· The right to object if there are certain parts of an individual’s information that they do not want used or to be used only for certain purposes.
· Rights in relation to automated decision-making and profiling.
· The right to lodge a complaint with the Dublin Office
· You can contact the Office of the Data Protection Commission by emailing firstname.lastname@example.org or by telephone at 1890 252 231. Further information is also available on the dedicated website GDPR and You.
· Should an individual wish to exercise these rights, the contact details at the start of the document should be used. In the event that an individual is dissatisfied with the response, then a complaint can be made to the https://dbei.gov.ie/en/Data-Protection/
If an individual does not agree to Downtime Massage keeping records of information about an individual and treatment records then it may not be possible to provide the therapy.
Additionally, massage therapists have to keep records of treatment for a specific period of time as described above which may mean that even if you ask for information to be erased, they might be bound to keep these details until the period has elapsed.