This document refers to personal data, which is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain.
The General Data Protection Regulation (GDPR) which is EU wide and far more extensive than its predecessor the Data Protection Act, along with the Privacy and Electronic Communications Regulations (PECR), seek to protect and enhance the rights of EU data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU and its storage within the EEA.
1 – Harpenden SportsnSpinal, based at 21 Leyton Road, Harpenden, which hereafter for the purposes of this Privacy Notice will be referred to as the HSnS, is pleased to provide the following information:
2 – Who we are
The clinicians (Garry O’Dell & Gillian Brown) diagnose and treat health conditions. Treatments are carried out in accordance with the protocols set out by CSP and GOSC. The practice may also provide other treatments, about which our staff will be pleased to provide more details.
3 – Personal Data
a) For the purposes of providing treatment, the clinicians may require detailed medical information. We will only collect what is relevant and necessary for your treatment. When you visit our practice, we will make notes which may include details concerning your medication, treatment and other issues affecting your health. This data is always held securely, 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. To be able to process your personal data it is a condition of any treatment that you give your explicit consent to allow us to document and process your personal medical data. 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. As part of our obligations as primary 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 e.g GPs, consultants, surgeons and/or medical insurance companies. Where this is required we will always inform you first unless we are under a legal obligation to comply.
b) For marketing purposes, the clinicians may also use the contact details provided by you to respond to your enquiries, including making telephone contact and emailing information to you which the practice believes may be of interest to you.
c) In making initial contact with the practice you consent to the clinicians maintaining a marketing dialogue with you until you either opt out (which you can do at any time) or we decide to desist in promoting our services. We may occasionally also act on behalf of its patients in the capacity of data processor, when we may promote other practitioners based at our premises, who may not be employed by us. The clinicians do not broker your data and you can ask to be removed from our marketing database by emailing or phoning the practice using the contact details provided at the end of this Privacy Notice.
d) Some basic personal data may be collected about you from the marketing forms and surveys you complete, from records of our correspondence and phone calls and details of your visits to our website, including but not limited to, personally identifying information like Internet Protocol (IP) addresses.
f) We will only collect the information needed so that we can provide you with the services you require, the business does not sell or broker your data.
4 – Legal basis for processing any personal data
To meet our contractual obligations obtained from explicit Patient Consent and legitimate interest to respond to enquiries concerning the services provided.
5 – Legitimate interests pursued by the clinicians
To promote treatments for patients with all types of health problems indicated for our care.
6 – Consent
Through agreeing to this privacy notice you are consenting to the clinicians processing your personal data for the purposes outlined. You can withdraw consent at any time by using the postal, email address or telephone number provided at the end of this Privacy Notice.
7 – Disclosure
We will keep your personal information safe and secure, only staff engaged in providing your treatment will have access to your patient records, although our administration team will have access to your contact details so that they can make appointments and manage your account. We will not disclose your Personal Information unless compelled to, in order to meet legal obligations, regulations or valid governmental requests. The practice may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of its staff.
8 – Retention Policy
We will process personal data during the duration of any treatment and will continue to store only the personal data needed for eight years after the contract has expired to meet any legal obligations. After eight years all personal data will be deleted, unless basic information needs to be retained by us to meet our future obligations to you, such as erasure details. Records concerning minors who have received treatment will be retained until the child has reached the age of 25.
9 – Data storage
All Data is held in the United Kingdom. The clinicians do not store personal data outside the EEA.
10 – Your rights as a data subject
At any point whilst the clinicians are in possession of, or processing your personal data, all data subjects have the following rights:
• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.
In the event that the clinicians refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge. At your request we can confirm what information it holds about you and how it is processed.
11 – You can request the following information:
• Identity and the contact details of the person or organisation that has determined how and why to process your data.
• Contact details of the data protection officer, where applicable.
• The purpose of the processing as well as the legal basis for processing.
• If the processing is based on the legitimate interests of the clinicians and information about these interests.
• The categories of personal data collected, stored and processed.
• Recipient(s) or categories of recipients that the data is/will be disclosed to.
• How long the data will be stored.
• Details of your rights to correct, erasure, restrict or object to such processing.
• Information about your right to withdraw consent at any time.
• How to lodge a complaint with the supervisory authority (ICO).
• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
• The source of personal data if it wasn’t collected directly from you.
• Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
12 – To access what personal data is held, identification will be required
The clinicians will accept the following forms of identification (ID) when information on your personal data is requested: a copy of your driving licence, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If we are dissatisfied with the quality, further information may be sought before personal data can be released. All requests should be made to [email protected] or by phoning +44 (0) 582 76440 or writing to us at the address further below.
In the event that you wish to make a complaint about how your personal data is being processed by the clinicians you have the right to complain to us. If you do not get a response within 30 days, you can complain to the ICO.
The details for each of these contacts are:
Garry O’Dell/ Gillian Brown
Telephone (01582) 760444 or email: [email protected]
Wycliffe House, Water Lane, Wilmslow, SK9 5AF Telephone +44 (0) 303 123 1113 or email: https://ico.org.uk/global/contact-us/email/
[Sports and Spinal Clinic] (the “Company”) respects the privacy concerns of the users of its website, www.kajabi.com and the services provided therein (the “Site”). The Company thus provides this privacy statement to explain what information is gathered during a visit to the Site and how such information may be used.
Use of Information: As a general policy, no personally identifiable information, such as your name, address, or e-mail address, is automatically collected from your visit to the Site. However, certain non-personal information is recorded by the standard operation of the Company’s internet servers. Information such as the type of browser being used, its operating system, and your IP address is gathered in order to enhance your online experience.
The Site’s various mailing lists, downloads, special offers, contests, registration forms, and surveys may request that you give us contact information such as your name, mailing and/or e-mail address, demographic information such as your age and gender, and personal preference information such as your preferred software and interests. Information submitted at the time of submission will be used by the Company only as necessary for our legitimate business interests, including without limitation the improvement of our products, services and the contents of the Site. The Company may also share such information with our business and promotional partners to further those interests. Personally identifiable information is never sold or leased to any third parties. With your permission, we may use your contact information to send you information about our company and products. You may always opt-out of receiving future mailings as provided below. The Company does not store any credit card information it may receive in regard to a specific transaction and/or billing arrangement except as necessary to complete and satisfy its rights and obligations with regard to such transaction, billing arrangement, and/or as otherwise authorized by a user.
The Company may disclose user information in special cases when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference (either intentionally or unintentionally) with the Company’s rights or property, other users of the Site, or anyone else that could be harmed by such activities.
The Company may also be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Children Age 16 and Under: The Company recognizes the special obligation to protect personally identifiable information obtained from children age 16 and under. AS SUCH, IF YOU ARE 16 YEARS OLD OR YOUNGER, THE COMPANY REQUESTS THAT YOU NOT SUBMIT ANY PERSONAL INFORMATION TO THE SITE OR TO THE COMPANY. If the Company discovers that a child age 16 or younger has signed up on the Site or provided us with personally identifiable information, we will delete that child’s identifiable information from our records.
Kajabi nonetheless encourages parents to go online with their kids. Here are a few tips to help make a child’s online experience safer:
- Teach kids never to give personal information, unless supervised by a parent or responsible adult. Includes name, address, phone, school, etc.
- Know the sites your kids are visiting and which sites are appropriate.
- Look for Website privacy policies. Know how your child’s information is treated.
- Check out the FTC’s site for more tips on protecting children's privacy online
Kajabi uses the following cookies on the Site:
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Malware/Spyware/Viruses: Neither the Company nor the Site knowingly permit the use of malware, spyware, viruses, and/or other similar types of software.
Bulletin Boards and Chat Areas: Guests of the Site are solely responsible for the content of messages they post on the Company’s forums, such as chat rooms and bulletin boards. Users should be aware that when they voluntarily disclose personal information (e.g., user name, e-mail address, phone number) on the bulletin boards or in the chat areas, that information can be collected and used by others and may result in unsolicited messages from other people. You are responsible for the personal information you choose to submit in these instances. Please take care when using these features.
Choice/Opt-Out: The Site may provide you the opportunity to opt-in to receive communications from us at the point where we request information about you. You always have the option of removing your name from any e-mail list in order to discontinue any such future communications. In order to ensure immediate removal from any list, please follow the specific instructions set forth within the communications you receive from the Company which you no longer wish to receive. If you are unsuccessful in completing the instructions specified in any such communication, please e-mail us at [INSERT LEGAL EMAIL ADDRESS], including a copy of the undesired email attached to the request, and state you wish to be removed from the mailing list.
Transfer of Information Across National Borders: Our site and various information we collect are operated on servers located in various jurisdictions, including the United States. When you access or use the Site and/or our services, personal information about you may be transferred outside the country in which you are situated to these other locations. The Company’s policies ensure that such personal information is protected to the same standard when processed by any Company entity or office around the world. We also ensure that appropriate contracts containing standard data protection clauses approved by the European Commission to protect that information and the rights of individuals are in place with any and all third-party service providers we may use.
Your Access to and Control Over Your Personally Identifiable Information: At any time, but only once per calendar year, or as otherwise required under applicable law, users may contact Company to review the personally identifiable information that Company has collected about you. If you discover any errors, please notify Company and the information will be corrected. To review the personally identifiable information that company has collected about you, please send an email to [INSERT LEGAL EMAIL ADDRESS] with the subject line: “Personal Information Review Request.” Users may also request that Company delete a user account(s) or, if you have not established a user account, your email address, and any related data at any time. If you wish to delete your user account(s), please email us at [INSERT LEGAL EMAIL ADDRESS] with the words “Delete Account” in the subject line. If you do not have a user account and wish to delete your email address or other personally identifiable information that you might have provided through your use of the Site, any Games, and/or any Services, please email us at [INSERT LEGAL EMAIL ADDRESS] with the words “Delete My Information” in the subject line.
You may also choose to confirm that the Company does not use your personal information in certain ways and/or to otherwise “opt out” of certain uses of that personal information, including without limitation (i) when your personal may to be disclosed to a third party unrelated to the Company and/or parties directly related to providing your Services and/or (ii) when your personal information may be used for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by you. If you wish to limit your personal data in either such way, or have other questions about how the Company may use your personal data, please contact us at [INSERT LEGAL EMAIL ADDRESS] with the words “Privacy Request” in the subject line.
Your California Privacy Rights: California Civil Code Section 1798.83 permits California residents to request from companies conducting business in California a list of third parties to which the company has disclosed personally identifiable information during the preceding year for direct marketing purposes. Company has not and will not share your personally identifiable information with third parties for their direct marketing purposes; accordingly, it will not maintain such a list of third parties. If you are a resident of California and want additional information confirming how Company does not share your personally identifiable information with third parties for their direct marketing purposes, you may contact us at [INSERT LEGAL EMAIL ADDRESS] with the words “California Privacy” in the subject line of your email.
Contact Information for Complaints or Concerns: If you have any complaints or concerns about the Company or about this privacy statement, please contact:
Via email: [INSERT LEGAL EMAIL ADDRESS]
Via regular mail:
[INSERT FORMAL COMPANY NAME – i.e. include “Inc.” or “LLC”]
[INSERT ADDRESS HERE]
Information provided by you via general e-mail inquiries to the Company such as your e-mail address is used only to respond to your inquiries in the ordinary course of business, and is never shared with third parties.
If you are a resident of the EU and have an unresolved data privacy concern or personal information collection, use, or disclosure concern, you may file a complaint/inquiry with us at:
Security/How Your Personally Identifiable Information Is Protected: Security for all personally identifiable information is extremely important to us. We have implemented technical, administrative and physical security measures to attempt to protect your personally identifiable information from unauthorized access and improper use. We also protect your personally identifiable information offline. Only employees who need the information to perform a specific job (for example, customer service) are granted access to personally identifiable information. The computers/servers in which we store personally identifiable information are kept in a secure environment. We continually review all such measures and update them when appropriate. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, Company cannot ensure or warrant the security of any information you transmit via the internet. By transmitting any such information to Company, you accept that you do so at your own risk.
Last Updated: May 30, 2018
DISCLAIMER: This document and all of information contained herein are presented for informational purposes only. Nothing contained herein is intended as legal advice. The receipt or review of any information does not create an attorney-client relationship with Kajabi, LLC nor any attorney associated with Kajabi, LLC. Nothing in this document is intended to be a substitute for legal advice obtained from an attorney licensed in the appropriate jurisdiction.