Sacred Guide

Beyond the Veil of Perception

Privacy Policy

Privacy notice – Sacred Guide

Purpose of privacy notice

Who are we?

Sacred Guide is the data controller: contact details Jean Hammond, jeanie@sacredguide.co.uk. This means we decide how your personal data is processed and for what purposes.

Whose information does this privacy notice apply to?

The processing of personal data is governed by the General Data Protection Regulation 2016/679 (the GDPR). This legislation has replaced the previous data privacy law, giving more rights to you as an individual and more obligations to organisations holding your personal data.

One of the rights is a right to be informed about how we use, share and store your personal information.

This privacy notice applies to information we collect from patients and participants of courses, workshops and other group activities (shortened to “patients and participants” from here on), as run by Whitegold Discovery:

patients and participants of courses, workshops or other group activities;
prospective patients and participants;
former patients and participants;
people who subscribe to our newsletters;
visitors to our website;
job applicants and our current and former employees.

What is personal data?

Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. Examples of personal data we may hold about you include your contact and appointment details.

Special category data is a sub-category of personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. Examples of special category data we may hold about you include your patient notes.

How do we process your personal data?

We comply with our obligations under the GDPR by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data. We use your personal data for the purposes set out below.

Sections 1 – 15 apply to our patients and participants, prospective patients participants, former patients and participants of Whitegold Discovery (Also, please state how you store and transport your records: paper or electronically.)

We use your name, address, telephone number and email address to make and rearrange appointments and register you as participant. 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.
We use your name and email address, only if we have your explicit consent,tosend you marketing materials. This will be mostly in form of 1-2 monthly electronic newsletters with the main focus on upcoming courses, workshops and other group activities. 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.
The Sacred Guide website sacredguide.co.uk includes an online contact form through which you can get in touch. Please be aware that your message may not be fully protected in transit, and do not include sensitive information. We will also monitor any messages sent to us through the contact form, 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.
We keep a permanent attendance register on paper or electronically, which records of all patients and participants attending appointments or sessions run by Whitegold Discovery for tax purposes and to secure potential evidence in the event of a criminal prosecution, civil litigation, insurance claim or complaint to my regulatory body, the British Acupuncture Council.
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.
When attending appointments as a patient, 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.

When attending appointments as a patient, we use any relevant medical and family history you have told us for making a full traditional diagnosis, formulating treatment strategy and treatment planning.
When attending courses, workshops or other group activities as a participant, we use any relevant medical and family history you have told us to evaluate any health and safety needs specific to you during the sessions you attend. Please be aware that some sessions may require participants practicing on each other, and/or may lead to intense emotional states or shifts. It is therefore your responsibiliy to inform us about relevant health issues, including pregnancy, mental health, chronic or acute illness or pain, recent surgeries and similar. This information will be kept confidential and not shared beyond you and Sacred Guide and will be stored on paper or electronically to secure potential evidence in the event of a criminal prosecution, civil litigation or insurance claim
When attending appointments as a patient, we use our clinical findings about your health and wellbeing for making a full traditional diagnosis, and formulating treatment strategy and treatment planning.
When attending courses, workshops or other group activities as a participant, limited diagnostic or clinical findings may be discussed and shared in the group, but only with your consent, and only if such findings are deemed relevant and beneficial in context of the subject matter taught in the session. A permanent paper or electronic record will generally not be kept of such findings, unless deemed necessary to secure potential evidence in the event of a criminal prosecution, civil litigation, insurance claim or complaint to my regulatory body, the British Acupuncture Council.
When attending appointments as a patient, we keep a paper 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.
When attending appointments as a patient, we record on paper 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.
When attending appointments as a patient, we record on paper 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.
We keep accident records electronically or in paper form for any patients, participants, visitors or staff who are involved in accidents when attending appointments or sessions run by Whitegold Discovery, 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.
In the event of an adverse incident occurring to any of our patients or participants, we report the matter to the British Acupuncture Council and the our insurance company to enable the insurance company to deal with any potential claims and to
Where relevant, for those attending appointments as a patient, we maintain records for 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.
Participants attending courses, workshops or other group sessions may be asked to consent to being practiced on by other participants, and will be made aware of possible risks either prior to the session, or at appropriate times during the session. It is your responsibility to highlight any health issues (see also #8) prior to the session or when asked, and to inform the person(s) running the course if you encounter any issues or discomfort during the session. We may record such information electronically or in paper form, to secure evidence in the event of a civil claim, criminal prosecution, insurance claim or complaint.

Section 16 applies to those who complain about our services (please delete all sections that do not apply to your practice or amend those that need amending)) (Also, please state how you store and transport your records: paper or electronically.)

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.

19. When we receive a complaint from a person we make up an electronic or paper file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint.

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, electronically or in paper form, 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.

Sections 17 and 18 apply to subscribers to our newsletters (please delete all sections that do not apply to your practice or amend those that need amending)) (Also, please state how you store and transport your records: paper or electronically.)

20. We maintain and use electronic records of subscribers to our newsletters, only with their consent, for marketing purposes.

Sections 19 – 23 apply to our website users (please delete all sections that do not apply to your practice or amend those that need amending)) (Also, please state how you store and transport your records: paper or electronically.)

21.

When someone visits

our website

we may 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.

22. We may use website cookies to

23.

24.

cookie’ – or for repeat visits – using a ‘persistent cookie’.

improve user experience of our website by enabling

our website to ‘remember’ users, either for the duration of their visit – using a ‘session

Search queries and results may be logged anonymously to help us improve our

website and search functionality. No user-specific data is collected by us or any third

party.

We use a third party service Ethical Internet to help maintain the security and

performance of our website. To deliver this service it processes the IP addresses of

visitors to our website.

25.Out website, whitegolddiscovery.co.uk, is powered by WordPress (https://wordpress.com) and hosted at Ethical Internet (https://ethicalinternet.co.uk/). We do all content management and design ourselves with use of standard tools and plugins provided through WordPress or Ethical Internet. We may use standard tools

provided through WordPress or Ethical Internet to collect anonymous information about users’ activity on the site, for example the number of users viewing pages on the site, to monitor and report on the effectiveness of the site and help us improve it.

Sections 24 to 28 apply to job applicants, current and former employees (please delete all sections that do not apply to your practice or amend those that need amending) (Also, please state how you store and transport your records: paper or electronically.)

26. We are the data controller for the information job applicants provide during the process.

 All of the information you provide during the process will only be used for the purpose of progressing your application, or to fulfil legal or regulatory requirements if necessary.
 We will not share any of the information you provide during the recruitment process with any third parties for marketing purposes or store any of your information outside of the European Economic Area. The information you provide will be held securely by us whether the information is in electronic or physical format.
 We will use the contact details you provide to us to contact you to progress your application. We will use the other information you provide to assess your suitability for the role you have applied for.
 We do not collect more information than we need to fulfil our stated purposes and will not retain it for longer than is necessary.
 The information we ask for is used to assess your suitability for employment. You don’t have to provide what we ask for but it might affect your application if you don’t.
 We ask you for your personal details including name and contact details. We will also ask you about your previous experience, education, referees and for answers to questions relevant to the role you have applied for.
 We shortlist applications for interview.

27. If we make a conditional offer of employment we will ask you for information so that we can carry out pre-employment checks. You must successfully complete pre- employment checks to progress to a final offer. We are required to confirm the identity of our staff, their right to work in the United Kingdom and seek assurance as to their trustworthiness, integrity and reliability.

You will therefore be required to provide:

 Proof of your identity – you will be asked to attend our clinic with original documents, we will take copies.
 Proof of your qualifications – you will be asked to attend our clinic with original documents, we will take copies.
 You will be asked to complete a criminal records declaration to declare any unspent convictions.

 We will contact your referees, using the details you provide in your application, directly to obtain references.
 If we make a final offer, we will also ask you for the following:
 Bank details – to process salary payments
 Emergency contact details – so we know who to contact in case you have an emergency at work.

28. If you are successful, the information you provide during the application process will be retained by us as part of your employee file for the duration of your employment plus 6 years following the end of your employment. This includes your criminal records declaration, fitness to work, records of any references.

If you are unsuccessful at any stage of the process, the information you have provided until that point will be retained for 6 months from the closure of the recruitment process.

Information generated throughout the assessment process, for example interview notes, is retained by us for 6 months following the closure of the recruitment process.

29. All of the information gathered during the application process is taken into account to make final recruitment decisions.

30.You are able to ask about decisions made about your application by speaking to (insert name) or by emailing (insert email address).

Sharing your personal data

Your personal data will be treated as strictly confidential, and will be shared:

 with named third parties with your explicit consent;
 with the relevant authority such as the police or a court, if necessary for compliance witha legal obligation to which we are subject e.g. a court order;
 with your doctor or the police if necessary to protect yours or another person’s life;
 with the police or a local authority for the purpose of safeguarding a children or vulnerable adults; or
 with my regulatory body, the British Acupuncture Council, or my insurance company in the event of a complaint or insurance claim being brought against me; or
 my solicitor in the event of any investigation or legal proceedings being brought against me.

For further details about the situations when information about you might be shared please see the Information Commissioner’s website at https://ico.org.uk/for-the-public/personal- information/sharing-my-info/

How long do we keep your personal data?

We keep your personal data for no longer than reasonably necessary.

We keep patient and participant records for a period of 7 years in accordance with the British Acupuncture Code of Professional Conduct https://www.acupuncture.org.uk/public- content/effective-practice/bacc-professional-codes.html and to meet tax and insurance requirements.

We keep employee records until the end of the tax year following employment termination, or for the duration of pending disputes.

Your rights and your personal data

Unless subject to an exemption under the GDPR, you have certain rights with respect to your personal data as set out below.

 The right to request a copy of your personal data which we hold about you.
 The right to request that we correct any personal data if it is found to be inaccurate or outof date.
 The right to request your personal data is erased where it is no longer necessary for us to retain such data.
 The right to withdraw your consent to the processing at any time. This right does not apply where we are processing information using a lawful purpose other than consent.
 The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable) [This right only applies where the processing is based on consent or is necessary for the performance of a contract with you and in either case the we are processing the data by automated means].
 The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing.
 The right to object to the processing of personal data, (where applicable) [This right only applies where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics].
 The right to be informed if your data is lost. We shall also inform the Information Commissioner’s Office in accordance with the time limits in the GDPR.
 The right to lodge a complaint with the Information Commissioner’s Office.

For further details about these rights please see the Information Commissioner’s website at

https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/

Further processing

If we wish to use your personal data for a new purpose, not covered by this Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.