GDPR for Jubilee College
General Data Protection Regulation (GDPR)
This tells you what personal information Jubilee College and its students hold and why, and what your rights are.
School Name: Jubilee College
Address: 9 St Johns Road, Hythe, Kent, CT21 4BE
Telephone No: 07801 332301
Email Address: david.wayte@jubileecollege.com
Data Controller Contact Details: same as school details.
Generic terms – We / Us / Our = Jubilee College and its students.
The Purpose of Processing Client Data
We hold and use client data in order to provide you with the best possible treatment options, support and advice. We may also need to share some information with tutors and the Awarding Organisation Agored Cymru as outlined below.
Lawful Basis for Holding and Using Client Information
The lawful basis under which We hold and use for information is for legitimate interests i.e. requirement to retain the information in order to provide you with the most appropriate treatment options and advice as part of my case studies.
As we hold special category data (i.e. health related information), the ‘Additional Condition’ under which we hold and use this information, is to enable Us to fulfil our role as a health care practitioner bound under the Association of Reflexologists (AoR) Confidentiality as defined in the AoR Code of Practice and Ethics.
The Information We Hold and What We Do With It
In order to give professional reflexology treatments as part of our case studies, we will need to gather and keep potentially sensitive information about your health. We will only use this for informing reflexology treatments, any advice we give as a result of your treatment, in discussion with the students tutor as part of my learning, and to generate an anonymised case study as required for my course. The information to be held is:
- Your contact details
- Medical history and other health-related information
- Treatment details and related notes
- Reflective practice – my thoughts on how the treatments are progressing
We may contact you by email, phone or text in relation to:
- Appointment times
- Reflexology information or information related to your health
We will NOT share your information with anyone else (other than within our own practice, with my tutor and any examiner, moderator or verifier as required by my course, or as required for legal process) without explaining why it is necessary and getting your explicit consent – see below.
As the student is treating you as a case study, they have to share certain details with their tutor. The information to be shared with the tutor could include:
- Medical history and other health-related information
- Treatment details and related notes
- Reflective practice – notes on how I felt the treatments went
We will be required to keep this information for three years as required by the Awarding Body.
We will keep your information for the following periods in line with the lawful basis listed: claims occurring insurance records to be kept for 7 years after last treatment and children’s records to be kept until the child is 25 or if 17 when treated, then 26.
Protecting Your Personal Data
We are committed to ensuring that your personal data is secure. In order to prevent unauthorised access or disclosure, we have put in place appropriate technical, physical and managerial procedures to safeguard and secure the information we collect from you. We will contact you using the contact preferences you have given them.
Your Rights
GDPR gives you the following rights:
- The right to be informed: to know how your information will be held and used
- The right of access: to see your practitioner’s records of your personal information, so you know what is held about you and can verify it
- The right to rectification: to tell your practitioner to make changes to your personal information if it is incorrect or incomplete
- The right to erasure: for you to request your practitioner to erase any information they hold about you
- The right to restrict processing of personal data: you have the right to request limits on how your practitioner uses your personal information
- The right to data portability: under certain circumstances you can request a copy of personal information held electronically so you can reuse it in other systems
- The right to object: to be able to tell your practitioner you don’t want them to use certain parts of your information, or only to use it for certain purposes
- Rights in relation to automated decision-making and profiling
- The right to lodge a complaint with the information commissioner’s office: if you feel your details are not correct, if they are not being used in a way that you have given permission for, or if they are being stored when they don’t have to be.
Full details of your rights can be found at https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
If you wish to exercise any of these rights, please use the contact details given above. If you are dissatisfied with the response you can complain to the Information Commissioner's Office; their contact details are at www.ico.org.uk
Practitioner’s Rights
Your student practitioner has to keep the records of your treatment for a certain period as described above, which may mean that even if you ask them to erase any details about you, they might have to keep these details until after that period has passed.
Your student practitioner can move records between their computers and IT systems, as long as your details are protected from being seen by others without your permission.