Bepainfree is committed to respecting and protecting your privacy. We wish to be transparent in how we process your data and show you that we are accountable with the GDPR in relation to not only processing your data but ensuring you understand your rights as a client.
It is the intention of this privacy statement to explain to you the information practices of bepainfree in relation to the information we collect about you.
For the purposes of the GDPR the data controller is:
- Contact details of Stephen McDermott and John Smith
- When we refer to ‘we’ it is bepainfree
Please read this Statement carefully as this sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
Who are we?
We are a pain relief service.
Our Data Protection Officer / GDPR Owner and data protection representatives can be contacted directly here:
Purpose for processing your data
To understand your complaint better and decide if you are suitable for Osteopathy and safe to treat.
Why are we processing your data? Our legal basis
In order for us to provide you with Osteopathy bepainfree need to collect personal data for accessing if we can help relieve your symptoms.
Our reason (lawful reason) for processing you data under the GDPR is:
- Contractual – bepainfree needs to process your data as this is necessary in relation to a contract of XXXX to which the individual has entered into or because the individual has asked for something to be done so they can enter into a contract.
In any event, bepainfree is committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.
How will bepainfree use the personal data it collects about me?
Bepainfree will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary.
Special categories of personal data
If we collect any special categories of personal data (e.g. health, racial, ethnic origin – financial information is not classified as special categories of personal data) – we will ensure the below
- we will obtain your explicit consent
Who we might share your data with?
If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your explicit consent, unless we are legally required to do otherwise.
The third parties that we pass your personal data to are:
Hospital or doctor
We have issued all our third party processors with a Data Processor checklist asking them GDPR specific questions
If we transfer personal data to a third party or outside the EU we as the data controller will ensure the recipient (processor or another controller) has provided the appropriate safeguards and on condition that enforceable data subject rights and effective legal remedies for you the data subject are available.
Data subject rights:
Bepainfree facilitate you, our clients, rights in line with our data protection policy and the subject access request procedure. This is available on request.
Your rights as a data subject
At any point while we are in possession of or processing your personal data, you, the data subject, 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 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.
- Right to judicial review: in the event that bepainfree refuses your request under rights of access, we will provide you with a reason as to why.
All of the above requests will be forwarded on should there be a third party involved as we have indicated in the processing of your personal data.
Additional information we are providing you with to ensure we are transparent and fair with our processing
Retention of your personal data
Data will not be held for longer than is necessary for the purpose(s) for which they were obtained. Bepainfree will process personal data in accordance with our retention schedule. This retention schedule has been governed by our internal governance.
In the event that you wish to make a complaint about how your personal data is being processed by bepainfree or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and bepainfree data protection representatives Data Protection Officer / GDPR Owner
Failure to provide further information
If we are collecting additional data needed to gain more information in relation to your issue which would help our management plan and you cannot provide this data the consequences of this could mean the contract between us cannot be completed.
If we intend to further process your personal data for a purpose other than for which the data was collected, we will provide this information prior to processing this data.
If we have received your personal data from another source we will endeavour to share with you:
- Within one month of obtaining the personal data, in accordance with the specific circumstances of the processing;
- at the first instance of communicating in circumstances where the personal data is used to communicate with the data subject;
- when personal data is first disclosed in circumstances where the personal data is disclosed to another recipient.
Your privacy is important to us. If you have any queries, questions or comments regarding this statement, please do not hesitate to contact us.