PRIVACY POLICY
This is the privacy policy for Bridget Mary Clare, trading as Re-Creation Foundation and as the following website(s) and social media identities:
www.re-creationfoundation.com
https://www.facebook.com/Re-Creation-Foundation-312845482153389/?ref=br_rs
Contact details:
11 Dalvenie Road, Banchory, AB31 5UX
07867 801129
bridget@re-creationfoundation.com
Who are we?
Re-Creation Foundation is the brand name of Bridget Mary- Clare. I (and any representatives I use to help me with my administration) take your privacy very seriously. This privacy statement documents how Re-Creation Foundation complies with European Union data protection requirements. We may change this privacy statement from time to time, therefore, please continue to check this page to ensure you are happy with any changes.
There are two sections to the following information:
- About your personal data – the type of data that is collected or used, including when, how and why
- Your rights – all the ways that you can control what happens with your data
About your personal data:
When you make an enquiry
The name and contact details you give and the content of your message(s) are retained for three reasons:
- By your consent
- As part of a ‘contract’ (only while we communicate)
- For legitimate business interests
When you make an online purchase as a single purchase, a membership or subscription
This is a contract for services. Your contact details are dealt with as above (consent, contract, legitimate reasons) – also these, your purchase history and the payment details (sent to me from Paypal, bank transfer, and cheque) are retained for six years beyond the end of the contract for legal reasons – accounting law.
We may also communicate by email or phone about a specific booking or in response to an enquiry via our website.
Where permission is obtained or a legitimate interest is evident – we may also send promotional emails about new products, new treatments, special offers or other information that we think you may find interesting using a valid email address.
When you attend an event and provide your details to me
I attend and exhibit at various holistic shows. I carry a copy of this Privacy Policy at my stand, and you will be encouraged to view it. If you give me your email addresses and join my newsletter or the lists to find out more about my forthcoming events, you’re giving the first step of consent to receive marketing messages from me, and when I enter your details into Mailchimp you will be asked to confirm your opt in status. Please be aware that I am not in control of the other attendees who can see your email address on my open newsletter sign up form.
When you attend a workshop or training
All of the above applies. I also keep record of your attendance, your certificates earned etc on the legal bases of both contract and legitimate interest – so that I can confirm your certificate status / reissue certification if required, also so that I can send you updates or offers which may be of specific interest to you as an attendee/graduate.
When you work with me on a one to one basis
Typically I will need to gather the following information from you: Name, address, telephone number, date of birth as standard. Client work is different. Dependent on the work we do together, you may wish (or need) to provide personal details of a sensitive nature. In Consultations/Sessions: I may also ask you to provide me with information regarding your personal or professional interests, lifestyle, health conditions and wellbeing – this is to ensure I deliver the best service to you – this information will not be disclosed or used for any marketing purposes.
We require this information to fully understand your needs and provide you with a better service and in particular for the following reasons:
Internal client record management.
To improve our products and services.
As an intake form these details are retained in printed or handwritten format and include your contact details and where appropriate, signature. The sensitive nature of such documents will generally be in relation to health or medical history.
Session notes that I keep tend to be summaries and key points covered in our sessions and are usually handwritten or typed for me for the purpose of fulfilling our contract and keeping record of the work during between sessions. Each client’s notes are filed individually in a locked filing cabinet.
In both cases I am required by law to retain these records for six years after the completion of our contract – or in the case of a minor, from six years beyond the date of their eighteenth birthday.
Re-Creation staff or our carefully selected representatives may also follow up, either by email, phone or mail, to people who have received a treatment as part of our customer care procedure.
Mailing Lists
We only email people who have given their express permission to be emailed. We will advise on all newsletter sign up forms what information we’ll gather, why we need it and what we’ll do with it.
As part of the registration process for our ad hoc e-newsletter, we collect personal information. We use that information for a couple of reasons: to tell you about events, courses products and services that you’ve asked us to tell you about; to contact you if we need to obtain or provide additional information; to check our records are right and to check every now and then that you’re happy and satisfied. We don't rent or trade email lists with other organisations and businesses.
We use a third-party provider, MailChimp, to deliver our newsletter. We gather statistics around email opening and clicks using industry standard technologies to help us monitor and improve our e-newsletter. For more information, please see
MailChimp’s privacy notice. You can unsubscribe to general mailings at any time of the day or night by clicking the unsubscribe link at the bottom of any of our emails or by contacting me directly through this website.
Other data sources:
Incoming data is also received from my website host Wax Media through my contact form, Paypal, Skype, Zoom and through my professional and personal Facebook pages and Messenger if you choose to contact me through those mediums. Please be aware that as at Tuesday, 22 May 2018 we do not currently collect cookies on our website.
During our conversations with you we may collect the following information:
I may receive information from another practitioner or therapist or from a previous client if they’re recommending my services as part of a referral. In such a case you may be unaware that the consented data transfer has taken place, I will therefore inform you of receipt within 28 days.
Sharing your data
Your privacy is important and I do not sell your data nor share it except by your consent or under the law.
When working together, I may give out elements of your personal information to another practitioner or therapist as part of a referral. This will always only be with your personal consent.
In continuation of current UK law on confidentiality I also retain the right and in some cases the legal requirement to breach confidentiality to inform an authority such as the police or your GP of impending harm or illegality.
Your Rights
The GDPR sets out clearly what your rights are. It also lays out deadlines for a reply and other rules which are reproduced for your information at the bottom of this section.
Right to be informed
You have the right to be informed about the collection and use of your personal data. This is a key transparency requirement under the GDPR.
I must provide you with information including: my purposes for processing your personal data, my retention periods for that personal data, and who it will be shared with. This ‘privacy information’ is provided above.
I must provide you with privacy information at the time I collect your personal data from you, in other words it has to be available to you before you fill in a form or hand over your data such as your email address.
If I obtain your personal data from other sources, e.g. by referral or from the payment service provider your selected, I must provide you with privacy information within a reasonable period of obtaining the data and no later than one month.
There are a few circumstances when I do not need to provide people with privacy information, such as if an individual already has the information or if it would involve a disproportionate effort to provide it.
The information I provide to people must be concise, transparent, intelligible, easily accessible, and it must use clear and plain language. Therefore if there is anything you do not understand, please get in touch.
Right of access
You are entitled to view, amend, or delete the personal information that we hold. This allows you to be aware of and verify the lawfulness of the processing. Email bridget@re-creationfoundation.com in the first instance.
You are entitled to confirmation that your data is being processed, access to your personal data, and other supplementary information as provided in this privacy notice.
Right to rectification
You have the right to have your personal data corrected if it is incorrect, or completed if it is incomplete. If you believe that any information we are holding on you is incorrect or incomplete, please write or e-mail us as soon as possible to the above address. We will correct any information which was found to be incorrect promptly.
Right to erasure
You may request, verbally or in writing, to have your data erased. This is also commonly known as ‘the right to be forgotten’. This right only takes effect when:
- Your personal data is no longer necessary for the purpose for which it was originally collected or processed,
- you withdraw your consent when the sole legal basis to hold this information is your consent,
- There is a legitimate interest in processing this data, which does not override your request
- processing/analysing of the personal data was for direct marketing purposes and this is the use you object to
- your personal data was processed unlawfully without a proper legal basis
- There is a legal obligation to comply with your request; or
- If the personal data was processed to offer information society services to a child.
Right to restrict processing
You may change your mind about the permission you have given us to use your personal information at any time by emailing us bridget@re-creationfoundation.com
You have the right to request the restriction or suppression of your personal data. In other words you want to stop the data being used but keep it on file.
In this case your personal data cannot be used and can only be stored unless:
- you give your consent;
- it is for the establishment, exercise or defence of legal claims;
- it is for vital interests - I choose to deliver the best possible service, and in line with most therapy organisations I reserve the right to break your confidentiality agreement if I decide you or another person is at risk or secondly the content discloses criminal or illegal activity to me.
- it is for the protection of the rights of another person (natural or legal); or
- it is for reasons of important public interest.
Right to data portability
This allows you to obtain and reuse your personal data for your own purposes across different services. It allows you to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without affecting its usability. Doing this is meant to enable you to take advantage of applications and services that can use this data to find you a better deal or help you understand your spending habits. In general this rule exists for data held by big service providers, such as your call history or insurance or gas bill history. The right also only applies to information you have provided.
If, as a private client you wish to carry a copy of your case notes or other sensitive data to another practitioner or other mental, physical or spiritual health service, these may be provided to you or to the nominated service provider, on request, as an encrypted and password protected document.
Right to object
Individuals have the right to object to:
- processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling);
- direct marketing (including profiling); and
- processing for purposes of scientific/historical research and statistics.
Your objection must be made on grounds relating to your particular situation.
Once you object your data can no longer be processed, unless
- there are demonstrably compelling legitimate grounds for the processing, which override the interests, rights and freedoms of the individual; or
- the processing is for the establishment, exercise or defence of legal claims.
You may complain directly to me using the contact details above. If you find the outcome unsatisfactory you are then able to object or complain to the ICO, the CMA or my insurer Towergate Professional Risks.
You may of course also exercise your right to legal action.
Timelines:
You can claim a right verbally or in writing.
A response should come without delay and at least within one month of receipt. The time limit is calculated from the day after you make the request (whether the day after is a working day or not) until the corresponding calendar date in the next month.
I aim to respond within 28 days.
Exceptions:
When you request access to your data, a copy must be provided free of charge. However, you can be charged a ‘reasonable fee’ when a request is:
- manifestly unfounded or excessive, particularly if it is repetitive, unless that’s because I failed to respond; or
- for further copies of the same information (that’s previously been provided).
If you have any questions or concerns about this Privacy Statement, or would like to receive a printed version, please call us on the number at the top of this page.