General Data Protection Regulation
"Communication lies at the heart of life on Earth, and of all we do"
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 I must give you even more information than I do now about the way in which I use, share and store your personal information.
This means that I 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 I hold on you and the legal basis on which I use it.
This new privacy notice comes into effect and will be published on our website on 25 May 2018.
Who am I?
I, Jocelyne Houghton am the data controller and the data protection officer for
The Natural Fusion Clinic.
This means that I 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 I collect from:
people who subscribe to my newsletters;
visitors to my website;
job applicants and our current and former employees.
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 I 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 I may hold about you include your patient notes.
How does The Natural Fusion Clinic process your personal data?
I Jocelyne Houghton am in compliance with my 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.
I only use your personal data for the purposes set out below.
Sections 1 – 16 apply to patients, prospective patients, former patients and visitors to my clinic
1. I use your name, address, telephone number and email address to make and rearrange appointments. I am unable to send or receive encrypted emails, so you should be aware that any emails I send or receive may not be protected in transit. I also monitor any emails sent to me, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send to me is within the bounds of the law.
2. I use your name, address, telephone number and email address, only if I have your explicit consent, to send you marketing materials. I am unable to send or receive encrypted emails, so you should be aware that any emails I send to you or receive may not be protected in transit. I also monitor any emails sent to me, 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.
3. Some patients and prospective patients return pre- 1st appointment questionnaires or tell me about their medical conditions and medication by email or online enquiry forms. I am unable to send or receive encrypted emails, so you should be aware that any emails I send or receive may not be protected in transit. I will also monitor any emails sent to me, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send to me is within the bounds of the law.
4. secure potential evidence in the event of a criminal prosecution, civil litigation, insurance claim or complaint to my regulatory body, the British Acupuncture Council.
5. I use your date of birth to help identify patients with the same name to avoid mistakes being made as to safe and appropriate treatment, for identification purposes if referring a patient to another health practitioner, and for identification purposes if writing to a registered medical practitioner so that they correctly identify the patient.
I also use your date of birth to draw up your birth chart for the purpose of making a full traditional Stems and Branches diagnosis, formulating a treatment strategy and treatment planning. This is important within my diagnostic framework.
6. I use your presenting complaint and symptoms reported by you for the purposes of making a full traditional diagnosis, formulating treatment strategy and treatment planning.
7. I use any relevant medical and family history you have told me for making a full traditional diagnosis, formulating treatment strategy and treatment planning.
8. I collect your GP’s name and address if I need to contact your GP including in an emergency and because it is a mandatory requirement in the British Acupuncture Code of Professional Conduct.
9. I use my clinical findings about your health and well-being for making a full traditional diagnosis, and formulating treatment strategy and treatment planning.
10. I keep a record of and refer to that record of any treatment given and details of progress of your case, including reviews of treatment planning to enable me to: review the full traditional diagnosis, treatment strategy and planning; and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint.
11. I record and use any information and advice that I have given, especially when referring patients to any other health professional, to help you to receive the most appropriate treatment and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint.
12. I record any decisions made in conjunction with you to help you to receive the most appropriate treatment and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint.
13. I keep accident records for any patients, visitors or staff who are involved in accidents at our clinic 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.
14. In the event of an adverse incident occurring to any of our patients we report the matter to the British Acupuncture Council and our insurance company to enable the insurance company to deal with any potential claims and to help the British Acupuncture Council to develop its safe practice guidelines, as well as providing research data and information for the BAcC’s insurers and other interested parties.
15. Where relevant we maintain records of the patient’s consent to treatment, or the consent of their next-of-kin to be able to prove that the patient (and/or parent/guardian/next of kin) has given informed consent to treatment to secure evidence in the event of a civil claim, criminal prosecution, insurance claim or complaint.
16. All data files are stored on paper in filing cabinets that are locked and secure. I am the only person to have access to these files. I do not store any patient information electronically.
Section 17 applies if I were to receive a complaint about my practice
17. If I receive a complaint from a patient I will make up a file containing the details of the complaint. This will include the identity of the complainant and any other individuals involved in the complaint.
I will only use the personal information I collect to process the complaint and to check on the level of service I provide. I will 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, I will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis. I may need to provide personal information collected and processed in relation to complaints to the British Acupuncture Council or my insurance company.
I will keep personal information contained in complaint files in line with my 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 me I will only use the information supplied to me to deal with the enquiry and any subsequent issues and to check on the level of service I provide.
All data files are stored on paper in filing cabinets that are locked and secure. I am the only person to have access to these files. I do not store any patient information electronically.
Sections 18 and 19 apply to subscribers to my newsletter
18. I maintain and use records of subscribers to my Natural Fusion newsletters, only with their consent, for marketing purposes.
19. I use a third-party provider, WIX email marketing tool Shout out, to deliver my e-newsletters. I gather statistics around email opening and clicks using industry standard technologies including clear gifs to help me monitor and improve my e-newsletter. For information, please see https://support.wix.com/en/article/wixs-privacy-policy privacy notice.
Sections 20 – 24 apply to my website users
20. When someone visits my website I use a WIX service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. I do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. I do not make, and do not allow Google to make, any attempt to find out the identities of those visiting my website. If I do want to collect personally identifiable information through my website, I will be up front about this. I will make it clear when I collect personal information and I will explain what I intend to do with it.
21. I use website cookies to improve user experience of my website by enabling my website to 'remember' users, either for the duration of their visit - using a 'session cookie' - or for repeat visits - using a 'persistent cookie'.
22. My website search is powered by WIX. Search queries and results are logged anonymously to help me improve my website and search functionality. No user-specific data is collected by me or any third party.
23. We use a third-party service WIX to help maintain the security and performance of our website. To deliver this service it processes the IP addresses of visitors to my website.
24. We use a third-party service, WIX, to host our website including publishing our blog. This site is hosted at WIX, which is run by WIX. We use a standard WIX 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. WIX requires visitors that want to post a comment to enter a name and email address. For more information about how WIX processes data, please see https://support.wix.com/en/article/wixs-privacy-policy
Sections 25 to 29 apply to job applicants, current and former employees
25. I Jocelyne Houghton am the data controller for The Natural Fusion Clinic and the information job applicants provide during the process.
All of the information you provide during the process will only be used for the purpose of progressing your application, or to fulfil legal or regulatory requirements if necessary.
I will not share any of the information you provide during the recruitment process with any third parties for marketing purposes or store any of your information outside of the European Economic Area. The information you provide will be held securely by me whether the information is in electronic or physical format.
I will use the contact details you provide to me to contact you to progress your application. I will use the other information you provide to assess your suitability for the role you have applied for.
I do not collect more information than I need to fulfil our stated purposes and I will not retain it for longer than is necessary.
The information I ask for is used to assess your suitability for employment. You don’t have to provide what I ask for, but it might affect your application if you don’t.
I ask you for your personal details including name and contact details. I will also ask you about your previous experience, education, referees and for answers to questions relevant to the role you have applied for.
I shortlist applications for interview.
26. If I make a conditional offer of employment I will ask you for information so that I can carry out pre-employment checks. You must successfully complete pre-employment checks to progress to a final offer. I am required to confirm the identity of my staff, their right to work in the United Kingdom and seek assurance as to their trustworthiness, integrity and reliability.
You will therefore be required to provide:
Proof of your identity – you will be asked to attend our clinic with original documents, I will take copies.
Proof of your qualifications – you will be asked to attend our clinic with original documents, I will take copies.
You will be asked to complete a criminal records declaration to declare any unspent convictions.
I will contact your referees, using the details you provide in your application, directly to obtain references.
If I make a final offer, I will also ask you for the following:
Bank details – to process salary payments
Emergency contact details – so I know who to contact in case you have an emergency at work.
27. If you are successful, the information you provide during the application process will be retained by me as part of your employee file for the duration of your employment plus 6 years following the end of your employment. This includes your criminal records declaration, fitness to work, records of any references.
If you are unsuccessful at any stage of the process, the information you have provided until that point will be retained for 6 months from the closure of the recruitment process.
Information generated throughout the assessment process, for example interview notes, is retained by us for 6 months following the closure of the recruitment process.
28. All the information gathered during the application process is considered in order to make a final recruitment decision.
29. You can ask about decisions made about your application by speaking to Jocelyne Houghton or by emailing firstname.lastname@example.org.
Sharing your personal data
Your personal data will be treated as strictly confidential, and will only 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 I am subject to 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 regulatory body, the British Acupuncture Council, or 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/for-the-public/personal-information/sharing-my-info/
How long do I keep your personal data?
I keep your personal data for no longer than reasonably necessary.
I keep patient records for a period of 7 years in accordance with the British Acupuncture Code of Professional Conduct https://www.acupuncture.org.uk/public-content/effective-practice/bacc-professional-codes.html
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 I hold about you.
The right to request that I 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 me to retain such data.
The right to withdraw your consent to the processing at any time. This right does not apply where I am processing information using a lawful purpose other than consent.
The right to request that I 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) This right only applies where the processing is based on consent or is necessary for the performance of a contract with you and in either case the we are processing the data by automated means.
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. 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
If I wish to use your personal data for a new purpose, not covered by this Privacy Notice, then I 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, I will seek your prior consent to the new processing.
Lit.Ac.BSc (Hons) Ac.MBAcC
To exercise all relevant rights, queries or complaints please in the first instance
contact me at:
The Natural Fusion Clinic
Friars Gate Farm, Mardens Hill, St Johns Road
Crowborough, East Sussex, TN6 1XH