Charlotte Green Fertility
5 Stoneygate Lane
Purpose of privacy notice
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 we have to give you even more information than we do now about the way in which we use, share and store your personal information.
This means that we 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 we hold on you and the legal basis on which we are using it.
This new privacy notice comes into effect at the commencement of trading of Charlotte Green Fertility Coaching and will be published on our website from 1st September 2020.
Who are we?
Charlotte Green is the data controller. This means we decide how your personal data is processed and for what purposes.
Whose information does this privacy notice apply to?
This privacy notice applies to information we collect from:
- prospective clients;
- former clients;
- people who subscribe to our newsletter;
- visitors to our website.
What is personal data?
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 controller’s possession or likely to come into such possession. Examples of personal data we may hold about you include your contact and appointment details.
Special category 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 person’s sex life or sexual orientation. Examples of special category data we may hold about you include your client notes.
How do we process your personal data?
We comply with our 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. We use your personal data for the purposes set out below.
Sections 1 – 15 apply to our clients, prospective clients, former clients and visitors to our consultation room.
- We use your name, address, telephone number and email address to make and rearrange appointments. We are unable to send or receive encrypted emails so you should be aware that any emails we send or receive may not be protected in transit. We will also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send us is within the bounds of the law. Any emails sent to us will be received via a password protected device.
- We use your name, address, telephone number and email address, only if we have your explicit consent, to send you marketing materials. We are unable to send or receive encrypted emails so you should be aware that any emails we send or receive may not be protected in transit. We will also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send us is within the bounds of the law.
- Clients and prospective clients tell us about their general health, fertility health, mental health, medical conditions and medication by telephone, Whatsapp, email, online enquiry forms and Zoom calls. Clients complete pre-first appointment questionnaires by email, telephone call or Zoom call. Clients complete their Client Agreement by email or Whatsapp. We are unable to send or receive encrypted telephone calls, online enquiry forms and emails so you should be aware that any information we exchange by telephone, online enquiry form and email may not be protected in transit. We are unable to guarantee the security of information transferred via Whataspp so you should be aware that any Whatsapp messages we send or receive may not be protected in transit. We are unable to guarantee that information transmitted over the internet via Zoom, is secure – see Section 4 below. We will also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send us is within the bounds of the law.
- We keep a permanent attendance register for all appointments held with clients in person and online. We keep this record for tax purposes and to secure potential evidence in the event of a criminal prosecution, civil litigation, insurance claim or complaint.
- We may use your date of birth to help identify clients with the same name for identification purposes if referring a client to a health practitioner, and for identification purposes if writing to a registered medical practitioner so that they correctly identify the client.
- We use the information you share with us for the purposes of assessing suitability for fertility coaching, providing fertility coaching, planning the sessions and monitoring progress.
- We use any relevant medical and family history you have told us about for the purposes of providing fertility coaching.
- We use your GP’s name and address in the event that we need to contact your GP including in an emergency.
- We use our observations at each session to tailor the fertility coaching to your needs, monitor progress and plan the coaching sessions.
- We keep a record of and refer to that record of the fertility coaching sessions, to review and reflect on the sessions, plan future sessions; and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint.
- We record and use any information and advice that we have given, including when referring clients to any other health professional, to help you to receive the most appropriate support and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint.
- We record any decisions made in conjunction with you to help you to receive the most appropriate support and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint.
- Your intake form and session notes are stored on paper in a secure, lockable cabinet. A photograph of your signed Client Agreement is stored electronically on a password protected device. We will never share your data with anyone who does not have access to it, without your consent.
- We keep accident records for any clients or visitors who are involved in accidents at our consulting room in 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 our clients we report the matter to our insurance company to enable them to deal with any potential claims.
- We maintain records of the client’s consent to participate in the fertility coaching sessions using the Client Agreement form, in order to be able to prove that the client has given informed consent to participate, and to secure evidence in the event of a civil claim, criminal prosecution, insurance claim or complaint.
Section 18 applies to those who complain about our services:
18.When we receive a complaint from a person we 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.
We will only use the personal information we collect to process the complaint and to check on the level of service we provide. We usually have to disclose the complainant’s identity to whoever the complaint is about. If a complainant doesn’t want information identifying him or her to be disclosed, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis. We may need to provide personal information collected and processed in relation to complaints to our insurance company.
We will keep personal information contained in complaint files in line with our 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 ‘need to know’ principle.
Similarly, where enquiries are submitted to us we will only use the information supplied to us to deal with the enquiry and any subsequent issues and to check on the level of service we provide.
Sections 19 applies to subscribers to our newsletters
19. We maintain and use records of subscribers to our newsletters, only with their consent, for marketing purposes.
Sections 20 – 24 apply to our website users
20. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.
21. We use website cookies to improve user experience of our website by enabling our website to ‘remember’ users, either for the duration of their visit – using a ‘session cookie’ – or for repeat visits – using a ‘persistent cookie’.
22. Our website search is powered by WordPress.com. Search queries and results are logged anonymously to help us improve our website and search functionality. No user-specific data is collected by us or any third party.
23. We use a third party service, WordPress.com, to host our website including publishing our blog. This site is hosted at WordPress.com, which is run by Automattic Inc. We use a standard WordPress.com service to collect anonymous information about users’ activity on the site, for example the number of users viewing pages on the site, to monitor and report on the effectiveness of the site and help us improve it. WordPress.com requires visitors that want to post a comment to enter a name and email address. For more information about how WordPress.com processes data, please see https://automattic.com/privacy/.
24. We sometimes use the online advertising platform Google Ads to promote our website. This organisation is owned by Alphabet Incs. Google Ads may collect information about users’ including their activity on the website. For more information on how Google Ads processes data please see https://policies.google.com/privacy.
Sharing 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 person’s life;
- with the police or a local authority for the purpose of safeguarding a children or vulnerable adults; or
- with 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 Commissioner’s website at https://ico.org.uk/
How long do we keep your personal data?
We keep your personal data for no longer than reasonably necessary.
We keep client records for a period of 7 years in accordance with best practice guidelines.
If your contact details change please notify your coach so your records can be kept up to date. Your contact details will also be checked with you, during the routine review of your session notes. Your personal records will be destroyed by shredding or burning after the 7 year period. If your coach dies or stops working, your records will be destroyed after the 7 year period.
At any time you may request that changes are made to your contact details.
Your rights and your personal data
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 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 for us to retain such data.
- The right to withdraw your consent to the processing at any time. This right does not apply where we are processing information using a lawful purpose other than consent.
- 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)
- 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. We shall also inform the Information Commissioner’s Office in accordance with the time limits in the GDPR.
- The right to lodge a complaint with the Information Commissioner’s Office.
For further details about these rights please see the Information Commissioner’s website at https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/
If we wish to use your personal data for a new purpose, not covered by this 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. Where and whenever necessary, we will seek your prior consent to the new processing.
To exercise all relevant rights, queries of complaints please in the first instance contact us at:
5 Stoneygate Lane
Or by email to: 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.