This is the privacy notice of Ms. Gillian Karen Sinclair bwrtmiddle-east. In this document, “we”, “our”, or “us” refer to operating in the capacity of sole owner and therapist of bwrtmiddle-east.
Dear client, Gillian Karen Sinclair understands that your privacy is important to you and that you care about how your personal data is used.
I respect and value the privacy of all of my clients and potential clients enquiring about services and will only collect and use personal data in ways that are described here, and in a way that is consistent with GDPR obligations and your rights under the law.
Information About Us
Gillian Karen Sinclair, bwrtmiddle-east.
BWRT® Advanced Therapist, Master Coach, Advanced Hypnotherapist and Psychologist
Registered Address: MAZ Business Center.
Main trading address: Flat 344, Building 2648, Road 5720, Block 257, Amwaj Lagoon. Bahrain
Data protection Registration: Gillian Karen Sinclair is a registered data controller for his Therapy practice. Registration Reference: ZA377317
Email address: email@example.com
Telephone number: 0973 37755134
We are registered with the information Commissioners office.
Address: Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
T. 0303 123 1113 F. 01625 524510
What does this notice cover?
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
(1) What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in Part 3, below.
(2) What are my rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
(a) The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in part 9.
The right to access the personal data we hold about you. Part 8 will tell you how to do this. (Please note that when working with you as a client that there may very well be a sound reason of a legitimacy of interest not to disclose information that might affect the success and permanency of your treatment. Revealing certain details and information may risk undoing all the good that has been done. As a client we will discuss fully those reasons with you. However ultimately, we do have to observe the law and respect your rights)
(b) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 9 to find out more.
(c) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 9 to find out more.
(d) Please note that when you are a client being treated, our governing body’s regulations require us to hold your personal records and data for a period of up to seven or eight years. These records will be stored securely and the storage period would be determined as a legitimacy of interest in the scope of historical records being made available should a person require additional therapy. Eight years is deemed by our governing body to be a sensible time frame to store client records for.
(These records will be stored securely and securely destroyed under the terms of the data protection act after this time period)
(e) The right to restrict (i.e. prevent) the processing of your personal data.
(f) The right to object to us using your personal data for a particular purpose or purposes.
(g) The right to data portability. This means that you can ask us for a copy of your personal data held by us to re-use with another service or business in many cases.
(h) Rights relating to automated decision-making and profiling. We do not use your personal data in this way
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 9.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
(3) What personal data do you collect?
We may collect some or all of the following personal data (this may vary according to your relationship with us
- Date of birth
- Email address
- Telephone number
- Your presenting issue or specific goals etc.
- Information about your lifestyle and work life balance.
- Information about any previous therapy treatments
- GP details
- Medical and health conditions where applicable
- Job title
- Payment information
- Information about your preferences and interests
- We will also need to ask and record if you are the subject of any criminal investigation or pending court case or if you are attending jury service as this will exclude us from helping you at this time if so. This must be recorded on your data
- Other sources of personal data: Your personal data is obtained from the following third party
- Your GP if there are any contra indications to treatment
- CPN if applicable
(4) How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data.
This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate interests to use it. i.e. patient/client record keeping
Your personal data will be used for the following purposes:
• Managing your client/patient records.
• Supplying our products /services to you. Your personal details are required in order for us to enter into a contract with you.
• Personalising and tailoring our therapy services for you.
• Communicating with you. This may include responding to emails or calls from you.
• Supplying you with information by email or post that you have opted-in to.
(You may unsubscribe or opt-out at any time by notifying us in writing or email.)
• In accordance with ethical obligations and duty of care to our clients’ welfare and others associated, as stated upon our terms and conditions of treatment
With your express permission, we may also use your personal data for marketing purposes, i.e. Testimonials on our website and social media which will be anonymised.
With your express permission, we may also use your personal data for marketing purposes which may include contacting you by email, telephone or text message and/or post with information, news, and offers on our services.
You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.] We do not use any automated systems for carrying out, certain kinds of decision-making or profiling
(5) How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason for which it was first collected. Your personal data will therefore be kept for the following period.
• All client records and case histories whether manual notes or electronic data will be stored for a period of seven – eight years in compliance with the current guidelines and requirements of our professional bodies.
In our case, The Complementary and Natural Healthcare Council. Association for Professional Hypnotherapists and Psychotherapist and The British BrainWorking Research Society.
• These measures are regarded as a legitimacy of interest and are put in place as best client practice designed to protect our client’s long-term interests.
• After this period unless specifically requested by you the client they will be securely destroyed in accordance with the directives of the data protection act.
(6) How and Where Do You Store or Transfer My Personal Data?
We will only store your personal data in the UK and Bahrain where I reside as an expat. This means that it will be fully protected under the GDPR.
The security of your personal data is essential to us and to protect your data, we take a number of important measures, including the following:
• Where stored on a P.C. it is encrypted and password protected and the PC is kept in a secure locked location when not in use by us.
• All written case notes and personal data is stored under lock and key in a filing cabinet in a secure location
(7) Do You Share My Personal Data?
We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation. Therefore, we will not share any of your personal data with any third parties for any purposes, subject to two important exceptions.
• In some limited circumstances, we may be legally required to share certain personal data, which might include yours. For example, this may be if we are involved in legal proceedings, or we may be required to comply with certain legal obligations, or the instructions of a government authority, or give information to legal authorities if they so request if they have the proper authorisation such as a court order.
• In the course of therapy treatment, should there be legitimate concerns of self-harm or risk to a minor or other person then a duty of legal obligation under the code of ethics that we adhere to requires notification and sharing. There are no exceptions.
(8) How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 9. There is not normally any charge for a subject access request.
However, if your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding. Costs available upon application
We will respond to your subject access request within not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
(9) How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:
For the attention of: Gillian Sinclair
Email address: firstname.lastname@example.org
Telephone number: 0973 37755134
Postal Address: Villa 2317, Road 5718, Amwaj Island, Kingdom of Bahrain
(10) Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be made available contacting you directly with notification as to the nature of the changes.