Privacy Policy

Privacy Policy

​Clarissa Millar is committed to processing data in accordance with its responsibilities under the GDPR. 

Clarissa Millar is a sole trader operated by Clarissa Millar You can contact Clarissa for all matters relating to business either by post, email or telephone.
Clarissa Millar will collect certain information about you during the course of business. This information will be used for the following reasons:

1. Your contact information may be used to send you marketing as Clarissa Millar’ legitimate interest in promoting its business. You may request that this cease at any time or not used from the beginning.

2. Your post or email address may be used to send you an invoice or confirmation of booking.

3. All information gathered from you during consultation will be stored in a paper-based system and only used in connection with Craniosacral therapy with Clarissa Millar. It will not be shared with anyone under any circumstance. This is processed to enable Clarissa Millar to meet its legal obligations.

Clarissa Millar will keep different information for different periods of time. Financial information is required by law to be kept for 7 years, this includes contact information as invoiced.

Consultation details will not be kept longer than 7 years after the last appointment or in the case of children, 7 years after the 18th birthday.

You have the right to have your contact information removed but no information relating to consultations will be deleted as Clarissa Millar is legally obliged to retain it for the 7 years.

You have the right to be sent a copy within 30 days. We will endeavour to honour this request. You have the right to correct information but bear in mind consultations are taken in good faith and they contain subjective commentary.
Clarissa Millar endeavours to keep your information with respect, any concerns please do not hesitate to contact us with the information above.

1. DATA PROTECTION PRINCIPLES

Article 5 of the GDPR requires that personal data shall be:

  1. processed lawfully, fairly and in a transparent manner in relation to individuals;
  2. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
  3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
  4. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
  5. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and 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.
2. GENERAL PROVISIONS
  1. This policy applies to all personal data processed by Craniosacral therapy with Clarissa Millar.
  2. The Responsible Person shall take responsibility for Craniosacral therapy with Clarissa Millarongoing compliance with this policy.
  3. This policy shall be reviewed at least annually.
  4. Homeopathy with Tracy is registered with the Information Commissioner’s Office as an organisation that processes personal data.
3. LAWFUL, FAIR AND TRANSPARENT PROCESSING
  1. To ensure its processing of data is lawful, fair and transparent, Craniosacral therapy with Clarissa Millarshall maintain a Register of Systems.
  2. The Register of Systems shall be reviewed at least annually.
  3. Individuals have the right to access their personal data and any such requests made to Craniosacral therapy with Clarissa Millar shall be dealt with in a timely manner.
4. LAWFUL PURPOSES
  1. All data processed by Craniosacral therapy with Clarissa Millar must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information).
  2. Craniosacral therapy with Clarissa Millar shall note the appropriate lawful basis in the Register of Systems.
  3. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
  4. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in Craniosacral therapy with Clarissa Millar systems.
5. DATA MINIMISATION
  1.  Craniosacral therapy with Clarissa Millar shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
6. ACCURACY
  1.  Craniosacral therapy with Clarissa Millar shall take reasonable steps to ensure personal data is accurate.
  2. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.
7. ARCHIVING / REMOVAL
  1. To ensure that personal data is kept for no longer than necessary,Craniosacral therapy with Clarissa Millar  shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
  2. The archiving policy shall consider what data should/must be retained, for how long, and why.
  3. As a licensed and registered Craniosacral therapist, I am required to retain records for 7 years.
8. SECURITY
  1.  Craniosacral therapy with Clarissa Millar shall ensure that personal data is stored securely using modern software that is kept up-to-date.
  2. Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.
  3. When personal data is deleted this should be done safely such that the data is irrecoverable.
  4. Appropriate back-up and disaster recovery solutions shall be in place.
9. PRIVACY POLICY

 Craniosacral therapy with Clarissa Millar takes your privacy seriously and will only use your personal information to administer any treatment you have requested or to send you relevant information via emails and newsletters.  We will not share your data with any third parties*

* Analytics information:

We use third-party analytics tools to help us measure traffic and usage trends for the Service. These tools collect information sent by your device or our Service, including the web pages you visit, add-ons, and other information that assists us in improving the Service. We collect and use this analytics information with analytics information from other Users so that it cannot reasonably be used to identify any particular individual User.

10. BREACH

In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, Craniosacral therapy with Clarissa Millar shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO (more information on the ICO website).

END OF POLICY