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Privacy Policy

This privacy notice provides you with details of how and why we collect and process your personal data through your use of our website https://www.newdawnhealth.co.uk and in the provision of osteopathic, nutritional therapy and educational course services. Dawn Rowland is the data controller and is responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice). Personal data means any information capable of identifying an individual. It does not include anonymised data. By providing us with your data, you warrant to us that you are over 13 years of age.

1. CONTACT DETAILS

  • Full name of legal entity: Dawn Rowland
  • Email address: dawn@newdawnhealth.co.uk
  • Postal address: 15A Paul Street, Corsham, SN13 9DG.
  • It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at dawn@newdawnhealth.co.uk.

2. WHAT DATA DO WE COLLECT ABOUT YOU?

We may collect the following data about you:

  • Your name
  • Your email address
  • Your address
  • Your phone number
  • Your date of birth
  • Your bank details
  • Your sensitive medical data (see below)
  • Any personal data you post on our website
  • Data about how you use our website
  • Technical data such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website
  • Your marketing and communication preferences
  • Any other information that you directly provide to us whether through our contact form, over the phone, by email or otherwise, such as when entering a competition or completing a survey
  • Photographs of you at events

Sensitive Data

We need to collect sensitive health data, including physical and mental health data and history, in order to deliver the treatment, services or products.

We require your explicit consent for processing sensitive data. When you submit your details, you will be asked to provide explicit consent.

For the purposes of providing services, Osteopaths and Nutritional Therapists require detailed medical information. We will only collect what is relevant and necessary for your treatment and care. We will make notes which may include details concerning your medication, treatment and other issues affecting your health. This data is always held securely and is not shared with anyone not involved in your treatment, although for data storage purposes it may be handled by pre-vetted staff who have all signed an integrity and confidentiality agreement. Contact details provided by you such as telephone numbers, email addresses, postal addresses may be used to remind you of future appointments and provide reports or other information concerning your treatment.

We may obtain sensitive medical information in the form of test results from biochemical testing companies. We use this information in order to provide you with direct healthcare. This means that the legal basis of our holding your personal data is for legitimate interest.

As part of our obligations as healthcare practitioners, there may be circumstances related to your treatment, on-going care or medical diagnosis that will require the sharing of your medical records with other healthcare practitioners, for example, GPs, consultants, surgeons and/or medical insurance companies or other qualified healthcare providers. Where this is required, we will always seek your express consent first unless we are under a legal obligation to comply, for example, if we believe that your life is in danger then we may pass your information onto an appropriate authority (such as the police, social services in the case of a child or vulnerable adult, or GP in case of self-harm) using the legal basis of vital interests.

We may obtain sensitive information about you, from other healthcare providers. The provision of this information is subject to you giving us your express consent. If we do not receive this consent from you, we will not be able to coordinate your healthcare with that provided by other providers which means the healthcare provided by us may be less effective.

Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.

We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at dawn@newdawnhealth.co.uk. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

We do not carry out automated decision-making or any type of automated profiling.

3. FOR WHAT PURPOSE DO WE COLLECT YOUR DATA

We will use your data in order to:

  • Fulfil a legal obligation to retain your records for 8 years after your most recent appointment (or age 25, if this is longer), but after this period you can ask us to delete your records if you wish. Otherwise, we will retain your records indefinitely in order that we can provide you with the best possible care should you need to see us at some future date.
  • Process financial transactions to enable you to purchase our goods our products or our services.
  • Send you customer communications about enhancements to products or services you have bought.
  • Enable us to perform a contract with you and process orders, respond to enquiries related to the order and deal with complaints.
  • Reply to any enquiries you make about our products or services.
  • Send you marketing communications where we are allowed by law to do so.
  • Personalise your experience on our websites.
  • Monitor the use of our website and online services.
  • Ask you to complete surveys or invite you to enter competitions or prize draws.
  • Keep records of orders placed and communications in relation to such orders.
  • Keep records of communications.
  • Analyse your use of our website and other online services.
  • Administer and protect our business and website.
  • Deliver relevant website content and advertisements to you.
  • Understand the effectiveness of our advertising.
  • Bring legal claims against you if you breach a contract or fail to make payment.
  • Comply with any legal obligations we are subject to or as required by a government authority.
  • Obtain or maintain insurance policies.
  • Manage our business.
  • Obtain professional advice.

4. ON WHAT GROUND DO WE PROCESS IT?

We may process the following categories of personal data about you:

  • Communication Data includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
  • Customer Data includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
  • User Data includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.
  • Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. We may process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business to grow our business and to decide our marketing strategy.
  • Marketing Data includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws and free give-aways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.

We may use Communications data, Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).

We may also use Customer Data, User Data, Technical Data and Marketing Data for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to establish, pursue or defend legal claims.

5. HOW WE COLLECT AND STORE YOUR PERSONAL DATA

We may collect data about you by you providing the data directly to us, for example by filling in forms on our site or sending us emails, or by completing questionnaires, or by subscribing to our blog or newsletter, or when you request marketing information, or by entering a competition, or by giving us feedback, or by attending a live talk, or online event, webinar or workshop.

We may automatically collect certain data from you as you use our website by using cookies and similar technologies.

We may receive data from third parties such as analytics providers such as Google Analytics. Mailchimp is based outside the UK, and advertising networks such as Facebook are based outside the UK.

Your records and communications may be stored:

  • on paper, in locked filing cabinets, and the clinic is always locked out of working hours.
  • electronically (“in the cloud”), using a specialist medical records service called Cliniko and exercise software called Rehab My Patient. These providers have given us assurances that they are fully compliant with the General Data Protection Regulation. Their security information is here: https://www.cliniko.com/security/ and here, respectively, https://www.rehabmypatient.com/gdpr.
  • On my personal MacBook which is password protected.

6. MARKETING COMMUNICATIONS

Our lawful ground for processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).

Before we share your personal data with any third party for their own marketing purposes we will get your express consent.

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences, OR by following the opt-out links on any marketing message sent to you, OR by emailing us at dawn@newdawnhealth.co.uk at any time.

If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as osteopathic and nutritional therapy services, purchases etc.

7. DISCLOSURES OF YOUR PERSONAL DATA

We will never share your data with anyone who does not need access unless we have your written consent.

Only the following people/agencies will have routine access to your data:

The medical records service that stores and processes our files

Your practitioner(s) in order that they can provide you with treatment

Other administrative staff, such as our bookkeeper. Administrative staff will not have access to your medical notes, just your essential contact details

Customer Relations Management Software, such as Mailchimp, to coordinate messages, only using your name and email address. They do not have access to your medical notes

We may have to share your personal data with the parties set out below:

Occasionally, we may have to employ consultants to perform tasks which might give them access to your personal data (but not your medical notes). We will ensure that they are fully aware that they must treat that information as confidential, and we will ensure that they sign a non-disclosure agreement

Professional advisers including lawyers, bankers, auditors, insurers and our professional registering bodies. They do not have access to your medical notes.

Supplement and laboratories that require your personal data to provide their service. They do not have access to your medical notes

Third parties to whom we sell, transfer, or merge parts of our business or our assets. They do not have access to your medical notes unless you give express consent

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

We may share your case history in a completely anonymised form with our peers for the purpose of professional development. This may be at clinical supervision meetings, conferences, online forums.

You have the right to see what personal data of yours we hold, and you can also ask us to correct any factual errors. Provided the legal minimum period has elapsed, you can also ask us to erase your records.

8. INTERNATIONAL TRANSFERS

We are subject to the provisions of the General Data Protection Regulations that protect your personal data. Where we transfer your data to third parties outside of the UK, we will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data. As such:

We may transfer your personal data to countries that the United Kingdom regulatory authorities have approved as providing an adequate level of protection for personal data by; or

If we use US-based providers that are part of a UK regulator-approved privacy framework, we may transfer data to them, as they have equivalent safeguards in place; or

Where we use certain service providers who are established outside of the UK, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

9. DATA SECURITY

We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.

10. DATA RETENTION

We have a legal obligation to retain your records for 8 years after your most recent appointment (or age 25, if this is longer), but after this period you can ask us to delete your records if you wish.

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

When deciding what the correct time is to keep the data for, we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

For tax purposes, the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.

In some circumstances, we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

11. YOUR LEGAL RIGHTS

Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent provided the legal minimum period has elapsed.

You can see more about these rights at:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you wish to exercise any of the rights set out above, please email us at dawn@newdawnhealth.co.uk

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.

Complaints

In the event that you wish to make a complaint about how your personal data is being processed, we should be grateful if you would contact us first at dawn@newdawnhealth.co.uk, so that we can try to resolve it for you.

If you do not get a response within 30 days, you can complain to the Information Commissioner’s Office: ICO Wycliffe House, Water Lane, Wilmslow, SK9 5AF Telephone +44 (0) 303 123 1113 or email: https://ico.org.uk/global/contact-us/email.

New Dawn Health is registered with the Information Commissioner’s Office (ICO) as a data controller. A copy of the registration is available through the ICO website (search by business name).

12. THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

13. COOKIES

You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see Cookie Policy.