Active Health Solutions Ltd (“We”) are committed to protecting and respecting your privacy.
The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).
Data controller – A controller determines the purposes and means of processing personal data.
Data processor – A processor is responsible for processing personal data on behalf of a controller.
Data subject – Natural person
Categories of data: Personal data and special categories of personal data
Personal data – The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.
Special categories personal data – The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.
Processing – means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Third party – means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
2. Who are we?
Active Health Solutions Ltd is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are: 10-12 Hibernia Street, Holywood, Co Down, BT18 9JE. 028 9042 1188 firstname.lastname@example.org For all data matters contact Rachel Saligari on 028 9042 1188 or email email@example.com
3. The purpose(s) of processing your personal data
We use your personal data for the following purposes:
To manage our employees;
· To maintain our own accounts and records;
· To inform individuals of news, events or activities;
· You may give us information about you by filling in forms on our site www.activehealthsolutions.co.uk (our site) or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our site, subscribe to our service, search for a product, place an order on our site, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, use Mindbody Active Health Solutions App for Pilates, leave a review, and when you report a problem with our site
4. The categories of personal data concerned
With reference to the categories of personal data described in the definitions section, we process the following categories of your data:
- Personal data: Name, Address, Telephone Number, Email Address, Date of Birth, Referral Source, Insurance policy Number and Authorisation Code, G.P Contact details, Consultant Contact Details, Next of Kin
- Special categories of data: Medical History
5. What is our legal basis for processing your personal data?
a. Personal data (article 6 of GDPR)
Our lawful basis for processing your general personal data:
|X Consent of the data subject;||GDPR Consent Form|
|x Processing necessary for the performance of a contract with the data subject or to take steps to enter into a contract||Insurance Claims, AccessNI|
|x Processing necessary for compliance with a legal obligation||Health Records and Personal Details|
|x Processing necessary to protect the vital interests of a data subject or another person||Health Records|
|X Processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller||Health records|
|x Processing necessary for the purposes of the legitimate interests of the data controller or a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of the data subject||The use and supply of personnel details, health record, bank details|
- Special categories of personal data (article 9 of GDPR)
Our lawful basis for processing your special categories of data:
|X Explicit consent of the data subject||GDPR Consent form, personnel information|
|x Processing necessary for carrying out obligations under employment, social security or social protection law, or a collective agreement|
|x Processing necessary to protect the vital interests of a data subject or another individual where the data subject is physically or legally incapable of giving consent||For services we provide|
|☐ Processing carried out by a not-for-profit body with a political, philosophical, religious or trade union aim provided that the processing relates only to members or former members (or those who have regular contact with it in connection with those purposes); and there is no disclosure to a third party without consent|
|X Processing relates to personal data manifestly made public by the data subject||For clinic use only|
|x Processing necessary for the establishment, exercise or defence of legal claims or where courts are acting in their judicial capacity||For clinic use only|
|☐ Processing necessary for reasons of substantial public interest on the basis of EU or Member State law|
|x Processing necessary for reasons of preventative or occupational medicine, for assessing the working capacity of an employee, medical diagnosis, the provision of health or social care or treatment or management of health or social care systems and services on the basis of EU or Member State law or a contract with a health professional||For medical requests and health records|
|x Processing necessary for the reasons of public interest in the area of public health||For clinic use|
|x Processing necessary for archiving purposes in the public interest, or scientific and historical research purposes or statistical purposes||For clinic use|
More information on lawful processing can be found on the ICO website.
6. Sharing your personal data
Your personal data will be treated as strictly confidential, and will be shared only with Directors, Practice Manager, accountant, pension providers, insurance companies for qualifications
7. How long do we keep your personal data?
We keep your personal data for no longer than reasonably necessary and we only retain your data for the following purposes and use the following criteria to determine how long to retain your personal data. This includes medical files, personnel records, qualifications, appraisals and payroll details
8. Providing us with your personal data
You are under an obligation to provide your personal data to us as we are unable to treat you without your consent, for identification purposes when dealing with Health professionals involved in your care. Legal employment law.
If you fail to adhere the consequences will be the clinic not able to treat you, unable to employ you.
9. Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
- The right to request a copy of the personal data which we hold about you;
- The right to request that we 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 to retain such data;
- The right to withdraw your consent to the processing at any time, WHERE CONSENT WAS YOUR LAWFUL BASIS FOR PROCESSING THE DATA;
- The right to request that we 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 i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes 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 i.e. 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).
10. Transfer of Data Abroad
we do not transfer personal data outside the eea.
11. Automated Decision Making
WE DO NOT USE ANY FORM OF AUTOMATED DECISION MAKING IN OUR BUSINESS.
12. Further processing
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we 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.
14. How to make a complaint
To exercise all relevant rights, queries or complaints please in the first instance contact Rachel Saligari at 10-12 Hibernia Street, Holywood, Co Down, Bt18 9JE. Rachel@activehealthsolutions.co.uk 028 9042 1188
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 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, England.