- 1:1 consultation
- From my website
- From social media
- Any other online communication
- By telephone
What Personal Information do I collect?
Patients: If you are coming to me as a patient/client, in order to treat you, I will ask you to provide me with certain information examples of which include:
- Date of birth
- Home address
- Email address
- Telephone number
- Medical history
- Skype address
Over time I will add to this information details of conditions for which you have consulted me and the remedies that I have prescribed to you. I will also add referrals that I have made or suggested to you.
Newsletters/Sign Up Forms: If you are signing up to my newsletter or a Sign Up Form I will ask you to provide information including:
- Email address
My newsletter is currently hosted by MailChimp and to the best of my knowledge they are GDPR compliant and you may unsubscribe at anytime by clicking on the unsubscribe button at the bottom of the newsletter.
How do I collect this Personal Information?
All information collected is obtained directly from you.
In the case of patients/clients this is usually at the point of your initial consultation and any subsequent consultations. I will request that you provide consent for me to store and use your data. Your consent is required in order to ensure my compliance with data protection legislation.
In the case of newsletter subscribers and sign up forms this is at the point of sign up.
How do I use this Personal Information?
In the case of a patient/client I use your Personal Information to analyse the conditions for which you have consulted me and to prescribe remedies or make referrals or recommendations. I will communicate with you in person, by email, other digital methods, telephone and post.
In the case of my Newsletter/Sign Up Forms I will update you periodically on information that you may find interesting in regards to health matters.
With whom do I share your Personal Information?
I do not share the Personal Information of my patients/clients or my mailing lists created when you sign up to my newsletter or sign up forms.
How long do I keep your Personal Information?
I will keep your Personal Information for as long as you are consulting with me and then I am required by law to keep your information for seven years after your last consultation. In the case of a child I am required to keep the information for seven years after they reach the age of 18 years. At this point that file will be securely destroyed and any digital information will be erased from my computer systems.
How your Personal Information can be updated and corrected?
To ensure that I have the most accurate and up to date information on you, I require that you inform me of any changes that you believe I need to make to the Personal Information that I hold on you. You can do this by contacting me by any of the means previously described. Under data protection legislation, you have the right to inspect the Personal Information that I hold on you. You can make a request to do so by contacting me and, once I have verified that you are who you say you are, I will endeavour to respond within 14 working days.
How do I store your Personal Information?
My patient files are paper based and are held securely within my office. I take steps to protect your Personal Information against loss or theft, as well as unauthorised access, disclosure, copying, use, or modification. Your email address, if you have provided me with one, is held securely on the servers of my email provider, currently Google Mail.
Changes to this policy.
This policy may change from time to time.
If you have any queries about this policy or wish to contact me with any questions, please contact me at:
Kelly CS Johnson, “The Burrow”, Ballyvaughan, Co. Clare, H91 XHN8, Ireland
+353 (0)86 811 7676 or firstname.lastname@example.org
Policy review date; Every 2 years.
Data Protection Policy
Kelly CS Johnson
Registered Homeopath, Author & Inspirational Speaker
Scope of policy
Why this policy exists.
This data protection policy ensures that Kelly CS Johnson
- Complies with data protection law and follows good practice
- Protects the rights of patients/clients
- Is open about how patients/clients Personal Information is stored and processed
- Protects Kelly CS Johnson from the risk of a data breach
Data protection principles.
The General Data Protection Regulation identifies eight data protection principles.
Principle 1 – Personal data shall be processed lawfully, fairly and in a transparent manner.
Principle 2 – Personal data can only be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
Principle 3 – The collection of personal data must be adequate, relevant and limited to what is necessary compared to the purpose(s) data is collected for.
Principle 4 – Personal data held should be accurate and, where necessary, kept up to date. Every reasonable step must be taken to ensure that personal data that are inaccurate are erased or rectified without delay.
Principle 5 – Personal data which is kept in a form which permits identification of individuals shall not be kept for longer than is necessary.
Principle 6 – Personal data must be processed in accordance with the individuals’ rights.
Principle 7 – Personal data must be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
Principle 8 – Personal data cannot be transferred to a country or territory outside the European Union unless that country or territory ensures an adequate level of protection for the rights and freedoms of individuals in relation to the processing of personal data.
Certain of these principles are expanded upon in the sections that follow.
Lawful, fair and transparent data processing
Kelly CS Johnson requests personal information from patients and potential patients for the purpose of consulting with them and providing them with advice and guidance on homeopathic treatments. The forms used to request personal information may contain a privacy statement informing patients and potential patients why the information is being requested and what the information will be used for. Patients will be asked to provide consent for their data to be held and a record of this consent along with patient information will be securely held. Patients will be informed that they can, at any time, remove their consent and will be informed as to what to do should they wish to do so.
Processed for Specified, Explicit and Legitimate Purposes
Patients will be informed how their information will be used and Kelly CS Johnson will seek to ensure that patients’ information is not used inappropriately. Appropriate use of information provided by patients includes:
- Communicating with patients in order to make, change or cancel consultations
- Assessing the conditions and issues reported by patients and devising and prescribing relevant remedies and therapies.
Those subscribing through newsletters and sign up forms will receive information on health matters.
Kelly CS Johnson will ensure that patients’ information is managed in such a way so as to not infringe an individual members rights which include:
- The right to be informed
- The right of access
- The right to rectification
- The right to erasure
- The right to restrict processing
- The right to data portability
- The right to object.
Adequate, Relevant and Limited Data Processing
Kelly CS Johnson’s patients will only be asked to provide information that is relevant to support consultations and prescription. This includes:
- Date of birth
- Postal address
- Email address
- Telephone number
- Medical history.
Where additional information may be required, this will be obtained with the specific consent of the patient who will be informed as to why this information is required and the purpose for which it will be used.
There may be occasional instances where a patient’s information needs to be shared with a third party due to an accident or incident involving statutory authorities. Where it is in the best interests of the patient or of Kelly CS Johnson, in these instances where Kelly CS Johnson has a substantiated concern then consent does not have to be sought from the member.
Accuracy of Data and Keeping Data up to Date
Kelly CS Johnson has a responsibility to ensure that patients’ information is kept up to date. Patients will be required to let Kelly CS Johnson know if any of their personal information changes.
Accountability and Governance
Kelly CS Johnson is responsible for ensuring that her practice remains compliant with data protection requirements and can provide evidence that it has. For this purpose, those from whom data is required will be asked to provide written consent. The evidence of this consent will then be securely held as evidence of compliance.
Kelly CS Johnson has a responsibility to ensure that data is both securely held and processed. This includes:
- Using strong passwords for information held within computer systems
- Restricting access to computer and paper-based files
- Using password protection on laptops and PCs that contain or access personal information
- Using password protection or secure cloud systems
- Providing adequate virus-protection and firewall software to secure computer-based systems.
Subject Access Request
Kelly CS Johnson’s patients are entitled to request access to the information that is held by her. The request needs to be received in the form of a written request to Kelly CS Johnson.
On receipt of the request, the request will be formally acknowledged and dealt with within 14 working days unless there are exceptional circumstances as to why the request cannot be granted. Kelly CS Johnson will provide a written response detailing all information held on the member. A record shall be kept of the date of the request and the date of the response.
Data Breach Notification
Were a data breach to occur, action shall be taken to minimise the harm. Kelly CS Johnson will inform any patients where she believes their personal information has been compromised. Where necessary, the Data Protection Commissioner will be notified.
If a patient contacts Kelly CS Johnson to say that they feel that there has been a breach by her she will ask the patient to provide an outline of their concerns. If the initial contact is by telephone, Kelly CS Johnson will ask the patient to follow this up with an email or a letter detailing their concern. The concern will then be investigated fully, and a response made to the patient. Breach matters will be subject to a full investigation, records will be kept and all those involved notified of the outcome.
Policy review date: Every 2 years.