The Get Well Clinics Ltd – Privacy Policy

1. Introduction and Scope

This document concerns YOUR personal data, legally defined as information concerning any living person that is not already in the public domain, and covers legislation from The Data Protection Act (DPA), Privacy and Electronic Communications Regulations (PECR), The General Data Protection Regulation (GDPR). GDPR applies beyond the EU post-Brexit through the UK GDPR, which is now the governing law in the UK as retained EU law under the European Union (Withdrawal) Act 2018, effective from January 31, 2020.

The aforementioned regulations seek to protect and enhance your rights as a data subjects, and cover the safeguarding of personal data, protecting the user against the unlawful processing of personal data and the unrestricted transfer of personal data within the EU and UK. 

Please be aware; GDPR does not apply to information already accessible in the public domain, for example, Companies House data, or domain registration information. This privacy policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the getwellclinics.co.uk website, social media and booking platforms. This privacy policy should be read alongside, and in addition to our Terms and Conditions, which can be found here.

Please read this privacy policy carefully.

In this policy document, “we”, “us” and “our” refer to the data controller listed in Section 2.4 of this document.

1.1 THE GET WELL CLINICS LTD is committed to safeguarding the privacy of visitors to our clinical practice and website https://www.getwellclinics.co.uk and general service users, in accordance with the General Data Protection Regulation (GDPR) 2018 and UK GDPR, as retained EU law under the European Union (Withdrawal) Act 2018, effective from January 31, 2020.

1.2 This Privacy Policy applies to all cases in which THE GET WELL CLINICS LTD and getwellclinics.co.uk is acting as a data controller responsible for the processing and safeguarding of personal data of website visitors and service users.

1.3 Upon first visiting our website, you will be asked to agree to the terms presented in this policy document, and to the use of cookies. Continued use of our website after the privacy/cookie notice implies consent has been granted by the user (YOU).

2. Who we are

The information provided in this section clearly defines who “we” are, and who is responsible for managing your personal data. Methods of contact should also be clearly defined in accordance with EU & UK laws on service provider transparency.

If you believe information is missing or incorrect in this section, or does not adequately describe the service provider, you should discontinue use of this website immediately.

2.1 Who we are

THE GET WELL CLINICS LTD is a collection of acupuncture clinics across London offering natural health care services including acupuncture,  and natural health advice including but not limited to nutrition, breathing therapy, remedial movements (qigong), meditation; and hosting workshops and retreats. THE GET WELL CLINICS LTD are operating acupuncture clinics at the following locations; ZenYoga (24a Camberwell Grove, Camberwell, SE5 8RE), West London Buddhist Centre (Royal Oak House, 45a Porchester Road, London, W2 5DP) and Held House (42 Hoxton Square, London, N1 6PB). GETWELLCLINICS.CO.UK is the websites of THE GET WELL CLINICS LTD.

GETWELLCLINICS.CO.UK is the online presence for the brand, and includes online learning options and products.

2.2 Physical address

Our principal place of business are; 

• Zen Yoga, 24a Camberwell Grove, London SE5 8RE

– West London Buddhist Centre, Royal Oak House, 45A Porchester Rd, London W2 5DP 

2.3 Contact methods

You can contact us via any of the following methods:

(a) By post to

THE GET WELL CLINICS LTD, 4 Rye Court, 214 Peckham Rye, East Dulwich, London, SE22 0LT.

(b) Use of our website’s contact form at www.getwellclnics.co.uk

(c) By telephone: 07801 813 893

(d) By email:

2.4 Data Protection Officer

Our data protection officer/data controller is George Monkhouse and contact details for the aforementioned controller are as detailed above in section 2.3.

 

3. Whose information does this privacy notice apply to?

This privacy notice applies to information we collect from:

• patients
• prospective patients
• former patients
• people who subscribe to our newsletters & social media accounts or purchase online products and services
• visitors to our website

The policy sets out the different areas where user privacy is concerned and outlines the obligations & requirements of the users, the website and website owners. Furthermore, the way the website processes, stores and protects user data and information will also be detailed within this policy.

3.1 Our patients, prospective patients, former patients and visitors to our clinic:

1. We use your name, address, telephone number, email address, date of birth and credit card details to make and rearrange appointments. We are unable to send or receive encrypted emails so you should be aware that any emails we send or receive may not be protected in transit. We will monitor any emails sent to us, 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. Our email accounts use SSL (Secure Sockets Layer) to encrypt the communication between You and the server, as well as between email servers during transmission.
2. We use your name, address, telephone number and email address, only with your explicit consent, to send you marketing materials. We are unable to send or receive encrypted emails so you should be aware that any emails we send or receive may not be protected in transit. We will also monitor any emails sent to us, 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 tell us about their medical conditions and medication by email or online enquiry forms. We are unable to send or receive encrypted emails so you should be aware that any emails we send or receive may not be protected in transit. We will also monitor any emails sent to us, 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.
4. We keep a permanent attendance register which records all appointments for patients attending our clinics to keep a record of when you were treated for tax purposes and to secure potential evidence in the event of a criminal prosecution, civil litigation, insurance claim or complaint to regulatory body the British Acupuncture Council.
5. We may 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.
6. We 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. We use any relevant medical and family history you have told us for making a full traditional diagnosis, formulating treatment strategy and treatment planning.
8. We use your GP’s name and address in the event that we 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. We use our clinical findings about your health and wellbeing for making a full traditional diagnosis, and formulating treatment strategy and treatment planning.
10. We 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 us 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. We record and use any information and advice that we 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. We 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. We keep accident and near miss records for any patients, visitors or staff who are involved in accidents or near misses 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 the relevant insurance companies 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 in order 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.

3.2 Those who complain about our services

1. When we receive a complaint we make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint. This data is stored and transported electronically.
   We will only use the personal information we collect to process the complaint and to check on the level of service we provide. We usually 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, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis. We may need to provide personal information collected and processed in relation to complaints to the British Acupuncture Council or our insurance company. We will keep personal information contained in complaint files in line with our 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 us we will only use the information supplied to us to deal with the enquiry and any subsequent issues and to check on the level of service we provide.

3.3 Subscribers to our newsletters

1. We maintain and use records of subscribers to our newsletters, only with their consent, for marketing purposes. This data is stored and transported electronically.
2. We use a third party provider, AWeber, to deliver our e-newsletters. We gather statistics around email opening and clicks using industry standard technologies including clear gifs to help us monitor and improve our e-newsletter. For information, please see AWeber’s privacy notice. You can unsubscribe from marketing emails at any time by clicking the unsubscribe link. 

1. Our website users

1. When someone visits our website we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We 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. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.
2. We use website cookies to improve user experience of our website by enabling our website to ‘remember’ users for the duration of their visit – using a ‘session cookie’.

3.5 Our Social Media users

We maintain profiles on various social media platforms Facebook, Instagram, LinkedIn to communicate with our customers, share updates, and engage with the public. When you interact with our profiles (e.g., liking, commenting, sharing posts, or messaging us), we may collect personal data from your social media profile based on the settings you have with that platform.

1. Data Collection and Use
2. We may collect your publicly available profile information, such as your name, username, profile picture, and any additional information you choose to share directly with us.
   Interactions through social media are subject to both this privacy policy and the privacy terms of the respective social media platform.
3. Filming and Photography: We may occasionally take photographs or record film footage within the clinic for promotional purposes, such as marketing materials, social media content, or website use. We are committed to ensuring that this is done in a manner that respects your privacy and confidentiality.

Patient Privacy: No images or footage that could identify you will be taken or used without your explicit consent. 

Consent: You have the right to opt out of being filmed or photographed. Please inform a staff member of your preference before your treatment begins.

Data Use: Any images or footage captured for promotional purposes will only be used after obtaining your written consent.

Retention and Storage: Images or footage will be securely stored and only retained for as long as necessary for the promotional purpose or as required by law.

If you have any concerns about this policy or wish to withdraw consent at any time, please contact us using the details provided in this privacy policy.

3. Purpose of Processing
4. We process your data to:
   Respond to your inquiries or messages.
   Analyze interactions for engagement insights and marketing purposes.
   Share relevant updates, promotional materials, or event information, provided we have obtained appropriate consent when necessary.
5. Third-Party Access
6. Social media platforms are third-party services that independently process your data according to their privacy policies. We recommend reviewing the privacy settings and policies of the social media platforms you use to understand how your data is handled.
7. Your Rights
8. You can request that we delete any personal data we hold about you that was collected through social media interactions. For data handled by the social media platforms themselves, you will need to contact them directly.
9. Advertising and Tracking
   26. Our social media accounts may be used to display targeted ads. These platforms may process personal data, including through cookies or similar technologies, to deliver tailored advertising. You can opt out of such advertising through the settings provided by the platform or using your browser’s privacy tools.

3.5 Legal obligations

27. Should it be legally required to divulge your personal information to a higher authority such as law enforcement organisations, YOU as the user will be notified of any such data transfer.

4. Your rights as a data subject

4.1 Your rights

At any point whilst THE GET WELL CLINICS LTD is in possession of, or processing your personal data, all data subjects have the following rights as dictated by EU & UK laws and regulations:

• 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 erasure– 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 to 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 to be subject to the legal effects of automated processing or profiling.

4.2 Refusal of access

In the event that THE GET WELL CLINICS LTD 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 this refusal, or lodge an official complaint to the ICO (see Section 13).

 

5. Transparency of data held

5.1 Requesting information

THE GET WELL CLINICS LTD is legally obligated to provide the data we have collected concerning YOU at any time. You may request the following information:

• Information concerning how we collected the data.
• Contact details of the data protection officer, if applicable.
• The purpose of the processing of your information, in addition to the legal basis for processing.
• 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, erase, 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.

5.2 Verification requirements

To access what Personal data is held, identification will be required for verification. This may be a copy of your current driving licence, your 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 THE GET WELL CLINICS LTD is dissatisfied with the materials provided, further information may be sought before personal data can be released.

 

6. Consent and withdrawal of consent

6.1 Consenting and withdrawal of consent

Through agreeing to this privacy notice you are consenting to THE GET WELL CLINICS LTD and getwellclinics.co.uk processing your personal data for the purposes outlined. You can withdraw consent at any time by emailing or phoning the data protection officer detailed in this document.

 

7. Data retention policy

7.1 Data storage expiration

THE GET WELL CLINICS LTD will process personal data during the duration of any contract and will continue to store only the personal data needed for seven years after the contract has expired to meet any legal obligations. After this period any personal data no longer required or dormant will be deleted.

 

8. Data storage

8.1 Storage of data across multiple locations

Data collected by this website is held primarily in the United Kingdom using different (multiple) servers.  However, data is backed-up to servers across Europe via cloud storage backup solutions. All servers are located in locations that are required to comply with the same data protection regulations.

8.2 Transparency of data storage by third party providers

As defined in sections 3, your data may be transferred by THE GET WELL CLINICS LTD to a third party service to enhance your user experience or to provide client services.  Companies that may have access to some of your data and the data they are able to process is as follows:

• Google (Analytics) – Email address and website address
• Email Marketing: AWeber – Email address, first name, last name 
• Patient data software: RISE Health Tech
• Payment Processors: Stripe/ Squareup
• Scheduling software: SquareSpace/Acuity scheduling
• Social Media: Instagram & Facebook

9. Amendments

9.1 Policy updates

We may update this policy without notice. The most recent version will always be available on our website.

9.2 Keeping up to date with this policy

Website users should check this page occasionally to ensure you are in agreement with any changes to this policy.

10. Cookies

10.1 Types of cookie

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.

10.2 Data contained within cookies

Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

10.3  Storage of cookie data

Information provided in these cookies may be stored by

THE GET WELL CLINICS LTD in an encrypted MySQL database if it’s necessary for the operation or our website. Cookies will also be stored by YOU, should your browser be set to use them.

10.4 Refusing and deleting cookies

Most modern browsers allow you to refuse to accept cookies and also allow you to delete cookies.

The methods for doing so vary from browser to browser, from version to version, and can be dependent on the operating system. You can however obtain up-to-date information about blocking and deleting cookies via the following:

• https://support.google.com/chrome/answer/95647?hl=en(Chrome)
• https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences(Firefox)
• http://www.opera.com/help/tutorials/security/cookies/(Opera)
• https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies(Internet Explorer)
• https://support.apple.com/kb/PH21411(Safari)
• https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy(Edge)

10.5  The impact of blocking cookies

Blocking all cookies will have a negative impact upon the usability of many websites, and should you block cookies on our website, you will not be able to use all of the features of our website.

 

11. Complaints

11.1 Filing a complaint to the ICO

In the event that you wish to make a complaint about how your personal data is being handled, you have a legal right to complain. If you do not get a response within 30 days of your correspondence, you can initiate a complaint to the ICO.

ICO
Address:  Wycliffe House, Water Lane, Wilmslow, SK9 5AF
Telephone: 0303 123 1113
Email: https://ico.org.uk/global/contact-us/email/

12. Data Breach
    In the event of a data breach We are committed to protecting your personal data and have implemented robust measures to prevent data breaches. However, in the unlikely event of a data breach that could affect your personal information, we will take the following steps in accordance with applicable data protection laws:

Identification and Containment: Immediately identify the scope of the breach and contain it to prevent further loss of data.

Assessment: Assess the potential risks to your rights and freedoms as a result of the breach, including potential harm or adverse effects.

Notification to Relevant Authorities: If the breach is likely to result in a risk to your rights and freedoms, we will notify the Information Commissioner’s Office in the UK within 72 hours of becoming aware of the breach.

Notification to Individuals: If the breach poses a high risk to your rights and freedoms, we will notify affected individuals without undue delay. We will provide clear information on the nature of the breach, the potential consequences, and the steps you can take to mitigate any harm.

Mitigation Measures: Implement measures to remedy the breach and prevent future occurrences, including enhanced security and process reviews.

Contact for Questions: If you have any concerns about a potential data breach or suspect your information has been compromised, you can contact us immediately using the details provided in this privacy policy

12. Policy Updates

12.1 Latest version

The latest version of this document is dated 2nd December 2024.