Privacy Policy
1. Introduction
1.1 We are committed to safeguarding the privacy of our website visitors and patients.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and patients; in other words, where we determine the purposes and means of the processing of that personal data.
1.3 We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.
2. Credit
2.1 This document was created using a template from SEQ Legal (https://seqlegal.com/free-legal-documents/privacy-policy).
3. How we use your personal data
3.1 In this Section 3 we have set out: (a) the general categories of personal data that we may process; (b) the purposes for which we may process personal data; and (c) the legal bases of the processing.
3.2 We may process data about your use of our website ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics and Hotjar. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
3.3 We may process information contained in any enquiry you submit to us regarding our services ("enquiry data"). The enquiry data may be processed for the purposes of responding to your enquiry and providing our services to you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business, and/or taking steps at your request prior to entering into a contract.
3.4 We may process information that you provide when booking an appointment ("appointment data"). This data is collected through our appointment booking system, Cliniko. The appointment data may include your name, email address, telephone number, date of birth, and any health information you provide. This data is processed for the purposes of scheduling and managing your appointments, providing chiropractic care, and maintaining clinical records as required by our professional obligations. The legal basis for this processing is the performance of a contract between you and us, and our legitimate interests in providing healthcare services. For health data, we process this on the basis of providing health treatment.
3.5 We may process clinical and health information relating to your chiropractic treatment ("patient data"). This includes consultation notes, treatment records, and health history. The patient data is processed for the purposes of providing chiropractic care and maintaining records as required by our professional regulatory body. The legal basis for this processing is the provision of health treatment and our legitimate interests in providing healthcare services.
4. Retaining and deleting personal data
4.1 This Section 4 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
4.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
4.3 We will retain your personal data as follows: (a) usage data will be retained for a maximum period of 26 months following the date of collection; (b) enquiry data will be retained for a minimum period of 1 month following the date of the enquiry, and for a maximum period of 3 years following that date; (c) appointment data and patient data will be retained in accordance with our professional obligations as a chiropractor, which requires us to keep clinical records for a minimum of 8 years from the date of last treatment (or until age 25 for children, whichever is longer).
4.4 Notwithstanding the other provisions of this Section 4, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person, or the provision of your treatment.
5. Your rights
5.1 In this Section 5, we have listed the rights that you have under data protection law.
5.2 Your principal rights under data protection law are: (a) the right to access - you can ask for copies of your personal data; (b) the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data; (c) the right to erasure - you can ask us to erase your personal data (subject to our professional record-keeping obligations); (d) the right to restrict processing - you can ask us to restrict the processing of your personal data; (e) the right to object to processing - you can object to the processing of your personal data; (f) the right to data portability - you can ask that we transfer your personal data to another organisation or to you; (g) the right to complain to a supervisory authority - you can complain about our processing of your personal data; and (h) the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
5.3 These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
5.4 You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.
6. About cookies
6.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
6.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
6.3 Cookies do not typically contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
7. Cookies that we use
7.1 We use cookies for the following purposes: (a) analytics - we use Google Analytics cookies to help us analyse the use and performance of our website (cookies used for this purpose include: _ga, _gid, _gat); (b) user experience analysis - we use Hotjar cookies to understand how visitors interact with our website through heatmaps and session recordings (cookies used for this purpose include: _hjSessionUser, _hjSession).
8. Managing cookies
8.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links: (a) https://support.google.com/chrome/answer/95647 (Chrome); (b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox); (c) https://help.opera.com/en/latest/security-and-privacy/ (Opera); (d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer); (e) https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and (f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
8.2 Blocking all cookies will have a negative impact upon the usability of many websites.
8.3 If you block cookies, you will not be able to use all the features on our website.
9. Third party services
9.1 We use the following third-party services that may process your data: (a) Google Analytics - for website usage analysis (data may be transferred to the USA under Google's data processing terms); (b) Hotjar - for user experience analysis (data processed in the EU); (c) Cliniko - for appointment booking and patient record management (data processed in accordance with their privacy policy at https://www.cliniko.com/policies/privacy).
10. Amendments
10.1 We may update this policy from time to time by publishing a new version on our website.
10.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
11. Our details
11.1 This website is owned and operated by Sara Sharp Family Chiropractor.
11.2 Our business address is: 1 Nasmyth Square, Houstoun Industrial Estate, Livingston, West Lothian, EH54 5GG.
11.3 You can contact us: (a) by telephone, on 07494 12 88 88; (b) by email, at sara.sharp@hotmail.co.uk.
12. Data protection contact
12.1 For any data protection queries, please contact: sara.sharp@hotmail.co.uk.