Privacy Policy

What Happens to Your Data?

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​Email contact details: russellpwb@outlook.com

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I, Russell Bennett am the Data Controller and Processor of Russell Bennett Mind and Bodywork.

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The basis on which I keep client data is that of “Legitimate Interests”. This means that the data is necessary for me to fulfil the contract that we have together (i.e. to provide physical and talking therapies) and that it is data that you would reasonably expect me to hold and use.

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For those who enquire about my services, the data I hold includes any information you have sent me by email/text/WhatsApp message.

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For those who book and attend at least one session, the data I hold includes:

• Basic information such as name, email address, phone number

• Information that you give me as part of the work we do together

• Records of what interventions that I use (or potentially do not use) in our sessions

• Emails, texts and/or messages that are sent between

 

Data is not shared with anyone, except possibly for any reasons covered by the Requirements for Disclosure which are detailed and discussed when we first meet. My accountant will see bank and credit card records which will contain any information that you submit when making payment. If you would like me to redact your identifiable data before sending to the accountants then please let me know.

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Details of where data is held:

• Any emails sent between us are held either on my computer’s hard drive or exchange server. Any that may be held on my mobile phone are biometrically protected.

• Any texts/Whatsapp messages sent between us (See Social Media and Electronic Information section) are held on my mobile phone which is biometrically protected.

• Any notes taken down be me are handwritten and are kept in a locked filing cabinet. A coding system enables me to know whose notes are whose, but a stranger seeing the notes would not be able to identify who they referred to.

• Credit card information is shredded and/or deleted as soon as processed.

• If you use online banking then clearly these systems will hold your data. I will download from these systems for accounting purposes. When sent to my accountants, they will be password protected.

 

Your data is kept for 7 years. The length of time is based on the stipulation of my insurer. After this time any paper records are shredded and computer records permanently deleted.

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Russell Bennett Mind and Bodywork takes the security of data seriously and as such:

• All data is held securely (see details of where data is held above)

• Any data transmitted is sent encrypted where possible

• For accounting purposes Excel spreadsheets are used

However:

• I am not in control of data (including emails and texts) which you send me

• Social media apps, such as Facebook, routinely access any information held and this is beyond my control.

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If there is any breach of data security, Russell Bennett Mind and Bodywork will give full details to the Information Commissioner's Office and any person affected within 72 hours of the breach and do all possible to minimise any potential impact.

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Under UK GDPR legislation, you have rights with regards to the data held:

• The right of access. I will provide you with all data I hold on you as soon as I can following a request (and definitely within 30 days, unless this is impossible due to holidays or illness).

• The right to rectification. If any data I hold is incorrect, just let me know and I will correct it as soon as I can following a request (and definitely within 30 days, unless this is impossible due to holidays or illness).

• The right to erasure. If you wish me to erase your data just let me know and I will delete any computer records and shred any paper records as soon as I can following a request (and definitely within 30 days, unless this is impossible due to holidays or illness). NB: data may be retained for scientific research, historical research or statistical purposes where erasure is likely to render impossible or seriously impair the achievement of that processing but this would never include case notes or data such as address/email/phone

• The right to restrict processing. This would usually be a stop-gap measure before correction of any errors or before erasure

• The right to data portability. This might apply if you want your notes sent to another therapist for example, but it is likely that the easiest solution would come under the right to access, i.e. I would send the data to you.

• 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). Russell Bennett Mind and Bodywork does not engage in these things

  • Direct marketing.

  • Processing for purposes of scientific/historical research and statistics. For this, you must provide grounds for your objection.

  • Automated decision making and profiling. Russell Bennett Mind and Bodywork does not engage in automated decision making or profiling

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