Complementary Therapies, Intuitive Guidance & Coaching
Crystal Holistics Limited
The Full Spectrum Centre
The Old Court House
Contact: Anita Maddock MIPHM
Under the General Data Protection Regulation (GDPR), you have the right to be informed about:
• the collection and use of your personal data
• our purposes for processing that data
• the retention periods for storing your data (or a guarantee that it will be kept only for as long as necessary)
• who it will be shared with (both in this country and, if applicable, in others: in this case, we will inform you of the safeguards which are applied in that country)
• the legal basis under which we process your data
• the right to withdraw your consent (if consent is the legal basis for processing)
• our “legitimate interest” in processing your data (if that interest is the legal basis for processing)
• details of any data we collect about you from a third party (such as publicly-available information)
• the right to lodge a complaint with the ICO
You also have the right to information that is concise, transparent, intelligible, easily accessible and presented to you in clear and plain language rather than in “legalese”. We would encourage you to get in touch with the contact given above if you have any questions about this policy statement or our procedures with regard to data processing. This will not in any way affect your right (mentioned above) to complain to the ICO.
Finally, we commit to informing you if, at any time, we update our privacy information and always to seek permission if we plan to use your personal data for a new purpose.
The information we collect
We process and store details of your
• chosen mode of address (Mrs, Ms, etc)
• job title
• date of birth
• email address
• medical history and other health related information
These details will typically be provided before you have your first treatment as part of the consultation process. We only keep them for as long as necessary and you may, at any time, contact us to ask for them to be removed (see “the right to be forgotten” below).
Why do we need this information?
We use the information that we collect and store about you to:
• provide our products/services
• manage invoices and accounts
• deliver marketing and events information
The legal basis under which we collect and store data
Legal basis — legitimate interests
“This organisation has carried out a legitimate interests assessment (LIA) which can be seen on request. In doing so, we have checked that the processing is necessary and that there is no less intrusive way to achieve the same result. We will only use your data in ways that you would reasonably expect, unless we have a very good reason. We will not use your data in ways that you would find intrusive or which could cause you harm and we have considered and introduced safeguards to reduce the impact where possible.
If we process children’s data, we take extra care to make sure we protect their interests. In using this basis for processing data, we will make sure that your interests, as protected by the GDPR, are not undermined by our legitimate interests.”
Access to your data
On receipt of a request for access to the data which we hold about you, we will respond without delay and at the latest within one month of receipt. Information will be provided free of charge although a reasonable fee may be applied when a request requires excessive work, particularly if it is repetitive. This fee will reflect the amount of administrative work involved.
The right to be forgotten
Also known as data erasure, the “right to be forgotten” set out in the GDPR entitles you to ask any data controllers (including this organisation) to erase your personal data and to cease further dissemination. You can make such a request either verbally or in writing and we will respond as quickly as possible, and at the latest within one month. We understand that there is a particular emphasis on the right to erasure if the request relates to data collected from children and such requests will always be given the highest priority.
Please note, however, that there are certain circumstances in which the right to erasure may not apply. These include where processing is necessary for one of the following reasons:
• to comply with a legal obligation
• to exercise the right of freedom of expression and information
• for the performance of a task carried out in the public interest or in the exercise of official authority
• for the establishment, exercise or defence of legal claims.
In addition, any organisation is allowed to refuse to comply with a request for erasure if it is manifestly unfounded or excessive, taking into account whether the request is repetitive in nature. We will, however, explain and justify any such refusal.
Right to be informed
Within one month of collecting your personal data, we will inform you of the purposes for processing that data, the retention periods and with whom it will be shared. Any information which is provided to you will be concise, transparent, intelligible, easily accessible and presented in clear and plain language.
Right to rectification
Either verbally or in writing, you may ask for inaccurate personal data to be rectified, or to be completed if it is partial. We will respond as quickly as possible and certainly within the one month time period allowed under the GDPR. In the unlikely event that there is disagreement over the accuracy of the data, we will do our best to resolve this and you will, of course, have right to take the matter to the ICO if we cannot reach agreement. If that situation arises, we are prepared to consider restricting processing of the contested data during the time it takes to resolve the issue with the ICO.
Under the GDPR, only children aged 13 or over are able provide their own consent. Due to the form of services we provide as good practice, anyone under the age of 16 will require consent from whoever holds parental responsibility or, if we are using a different legal basis, will inform that person accordingly. We are fully aware that children have the same rights as adults over their personal data and are committed to ensuring full protection for them at all times.
Right to data portability
This organisation recognises that, under the GDPR, you must be able to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without hindrance to usability. The requested information will be provided free of charge in a structured, commonly used and machine-readable form. However, it should be noted that the right to data portability only applies:
• to personal data an individual has provided to a controller
• where the processing is based on the individual’s consent or for the performance of a contract
• when processing is carried out by automated means.
Right to object
You 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
• direct marketing
We will stop processing personal data for direct marketing purposes as soon as an objection is received.
Automated decision-making and profiling
Profiling refers to the automated processing of personal data to evaluate certain things about an individual. Together with making a decision solely by automated means, it is covered by the GDPR and will require the individual’s explicit consent. We will only collect the minimum amount of data needed and will retain it only for as long as is necessary. Anyone affected by an automatic decision has the right to ask for it to be reconsidered and we have additional checks in place for profiling/automated decision-making systems to protect vulnerable groups such as children.
While we will take all appropriate measures to prevent illegal access to your data, we have to prepare for that possibility. Should there be a significant data breach affecting your data and rights, we will notify you (and the ICO) as soon as possible. To minimise any possible danger, we will use encryption where it is appropriate to do so. We will also have backup systems in place in the event that an outside organisation attempts to disrupt access to our data,
A cookie is a small text file placed on your computer or device by our site when you visit certain parts of it and/or use certain of its features. For example, we may monitor how many times you visit, which pages you go to, traffic data, location data, weblogs and other communication data whether required for billing purposes or otherwise. We may also look at the originating domain name of a user’s internet service provider, IP address, operating system and browser type. This information helps us to build a profile of our users. Where appropriate, this data will be aggregated or statistical, which means that we will not be able to identify you individually.
Cookies are also used to remember your settings (language preference, for example) and for authentication (so that you do not have to repeatedly sign in). You can set your browser not to accept cookies and there are a number of websites which explain how to remove cookies from your browser. However, it is possible that some of our website features may not function as a result.
Third party websites
Please note that there are some links on our website to other sites where you may find useful information. This does not indicate a general endorsement of those sites and, as we have no control over how data is collected, stored, or used by other websites, we would advise you to check their privacy policies before providing any data to them.
Last updated on 19 May 2021