Balanced Approach Acupuncture
The processing of personal data is governed by the
General Data Protection Regulation 2016/679 (the GDPR). This legislation will replace 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 I have to give you even more information than I do now about the way in which I use, share and store your personal information.
means that I will be 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 I hold on you and the legal basis on which I am using it.
This new privacy notice comes
into effect and will be published on my website on 25 May 2018.
Balanced Approach Acupuncture, the data controller
is Christine Poolton.
This means I decide how your personal data is processed and for what purposes.
This privacy notice applies to information I collect from:
∑ Prospective patients
∑ People who subscribe to my newsletters
∑ Visitors to my website
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 controllerís possession or likely to come
into such possession. Examples of personal data I may hold about you include your contact and appointment details.
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 personís sex life or sexual orientation. Examples of special category data I may
hold about you include your patient notes.
I comply with my obligations under the GDPR
by keeping personal data up to date; by storing 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. I use your personal data for the purposes set out below.
∑ I use your name, address, telephone number and email address to make and rearrange appointments. I am unable to send or receive encrypted
emails so you should be aware that any emails I send or receive may not be protected in transit. I will also monitor any emails sent
to me, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that
any email you send me is within the bounds of the law.
∑ Some patients and prospective
patients tell me about their medical conditions and medication by email I am unable to send or receive encrypted emails so you
should be aware that any emails I send or receive may not be protected in transit. I will also monitor any emails sent to me, including
file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send
me is within the bounds of the law.
∑ I keep a permanent attendance register
which records all appointments for patients attending my 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 British Acupuncture Council.
∑ I 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.
∑ I use your presenting complaint
and symptoms reported by you for the purposes of making a full traditional diagnosis, formulating treatment strategy and treatment
∑ I use any relevant medical and family history you have told me for
making a full traditional diagnosis, formulating treatment strategy and treatment planning.
∑ I use your GPís name and address in the event that I need to contact your GP including in an emergency and because it is a mandatory
requirement in the British Acupuncture Code of Professional Conduct.
∑ I use
my clinical findings about your health and wellbeing for making a full traditional diagnosis, and formulating treatment strategy and
∑ I 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 me to: review the full traditional diagnosis,
treatment strategy and planning; and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim
∑ I record and use any information and advice that I 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.
∑ I 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.
∑ I keep accident records for any patients, who are involved in accidents at the clinic in which I work 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.
∑ In the event of an adverse incident occurring to any of my patients I report the matter to the British Acupuncture Council and my
insurance company to enable the insurance company to deal with any potential claims and to help the British Acupuncture Council to
develop its safe practice guidelines, as well as providing research data and information for the BAcCís insurers and other interested
∑ Where relevant we maintain records of the patientís 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
∑ When I receive a complaint from a person I 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.
I will only use the personal information I collect to process the complaint and to check on the level of service I provide. I usually
have to disclose the complainantís identity to whoever the complaint is about. If a complainant doesnít want information identifying
him or her to be disclosed, I will try to respect that, however, it may not be possible to handle a complaint on an anonymous basis.
I may need to provide personal information collected and processed in relation to complaints to the British Acupuncture Council or
my insurance company. I will keep personal information contained in complaint files in line with my 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 and access
to it will be restricted according to the Ďneed to knowí principle. Similarly, where enquiries are submitted to me, I will only use
the information supplied to me to deal with the enquiry and any subsequent issues and to check on the level of service I provide.
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 personís life
∑ with the police or a local authority for the purpose of safeguarding a children or vulnerable adults; or
∑ with my regulatory body, the British Acupuncture Council, 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.
For further details about the situations when information about you might be shared please see the
Information Commissionerís website at https://ico.org.uk/for-the-public/personal-information/sharing-my-info/
I keep your personal data for no longer than reasonably necessary.
I keep patient records for a period of 7 years in accordance with the British Acupuncture Code of Professional Conduct https://www.acupuncture.org.uk/public-content/effective-practice/bacc-professional-codes.html
personal data is kept in lockable filing cabinets and after a period of 7 years is destroyed by shredding if the patient is no longer
an active patient.
At any time you may request that changes are made to your contact details.
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 I hold about you
∑ The right
to request that I 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 forI me to retain such data.
∑ The right to withdraw your consent to the processing at any time. This right does not apply where I am processing information using
a lawful purpose other than consent.
∑ The right to request that I 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 I 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. I shall also inform the Information Commissionerís Office in accordance with the time
limits in the GDPR.
∑ The right to lodge a complaint with the Information Commissionerís
For further details about these rights please see the Information Commissionerís website at https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/
If I wish to use your personal data for a new purpose, not covered by this Privacy Notice, then I 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, I will seek your prior consent to the new processing.
To exercise all relevant
rights, queries of complaints please in the first instance contact me at Christine.firstname.lastname@example.org.
You can 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.