The following privacy notice outlines how The Treatment Rooms collects, uses, protects and transfers your personal data. The Treatment Rooms is a salon that provides services including massage and beauty therapy treatments. The data protection officer/data owner for the organisation is Clare Rogers. You can contact the data protection officer/data owner by sending an email to firstname.lastname@example.org or writing to The Treatment Rooms, 21 New Rd, Brighton BN1 1UF.
The personal data that we collect:
- Home address.
- Phone number.
- Date of birth.
- Health information.
Purpose and legal basis for processing your data
We take your privacy seriously and will never rent or sell your data to any third party. Sharing of your data and direct marketing activities are only carried out with your express consent, which you are free to withdraw at any time.
We need to obtain and process your personal data to provide you with our products, services and treatments and to fulfil our business and legal obligations. We will never collect any personal data from you that we do not need or retain data that is no longer necessary for the purpose specified in this notice.
Where we request sensitive personal data from you (i.e. health & medical data), the reason for the request will be clearly given along with the purposes of the processing. Explicit consent through a signature will always be required for us to obtain and process your health information.
Who is processing my data?
We are the data controller and process your personal information for the purposes laid out in this privacy notice. Phorest, Anglesea Mills, 9 Anglesea Row, Smithfield, Dublin, DO7 W5NE, Ireland acts as a data processor on behalf of the salon and have access to client information only in cases of software support or troubleshooting is required by the salon. Further, they must process the personal information in accordance with this Privacy Notice and as permitted by applicable data protection laws.
Your personal data is processed to:
- Collect personal data required to enter into a contract to sell a service or product.
- Engage in communication with you to send confirmation and reminders of appointments or change/cancel bookings.
- Collect health information to perform the agreed services appropriately, and potentially highlight areas that services potentially may cause issues to clients because of their health.
- Ensure a safe service and provide industry standard advice.
- Select relevant offers, promotions and information for you.
- Estimate the number of customers we have.
- Hold personal data that is required by law or respond to legal process.
- Hold for insurance purposes.
- Store customer records.
Your rights as the individual
If your personal data is held by the salon, you hold particular rights over it.
Where you have provided consent for us to contact you as part of our marketing services you have the right to modify or withdraw your consent at any time by using the unsubscribe option accompanied with all of our direct marketing or by contacting the salon.
You also have the right:
- To be informed of how your personal data will be used before it is collected.
- To access your personal data and information on how it is used after it has been gathered.
- To have personal data corrected if it is inaccurate, incomplete or out of date.
- To request the removal, deletion of personal data when there is no compelling reason for its continued processing.
- To restrict or block processing of your personal data.
- To data portability, having your data moved, copied or transferred from our organisation to another organisation in an easily readable format.
- To object to direct marketing from us.
Special categories of personal data collected
Health questions are asked in many of our consent forms to potentially highlight treatments that may have a negative effect on your health due to medication you are taking or a medical condition you may have. The salon asks for consent prior to gathering and processing this information. At any time after giving consent you can withdraw your consent, subject to legal, insurance and contractual restrictions (see more on ‘your rights as an individual’). Your privacy is very important to us and we only use this information to for determining your suitability for the treatment.
Process of the collection
Your personal data is collected when you provide it to us through Phorest software, our website, over the phone, in the salon, by email, by social media, in writing or any other means by which you provide it to us. Information is stored using the Phorest software platform as well as some level of paper record keeping.
The salon gives you access about your account and bookings through Phorest software, for the limited purpose of viewing and updating information.
The salon does not collect the personal data of children under the age of 13 without parental or guardian consent. If you believe we hold any information from or about a child under 13 please contact the salon and if we cannot obtain immediately parental or guardian consent, we will remove the personal data from storage.
Your personal data is shared only with Phorest representatives in cases that software support and trouble shooting is required for the salon. The salon does not share your personal information with any third-party without your prior consent, other than those already disclosed in this privacy notice or as part of our legal obligations under the relevant data protection laws.
Use of data processors
Data processors are third-parties who provide some elements of our business services to us. Where we use a third-party, we have strict agreements in place governing the processing of your personal data, on which no action can be taken without instruction from us. The third-parties with whom we work will never share or disclose your personal information and hold it securely at all times.
The salon uses software provided by Phorest to manage the salon for appointment scheduling CRM and marketing.
How long do we keep your data?
The salon retains your personal data for as long is necessary to provide you with our services as our client. The salon is required under tax laws to keep your personal data for a minimum of 7 years. Health & safety records will be retained for 10 years and where we have your consent for marketing purposes, we will retain the minimum required data until you notify us that you no longer wish to receive such information.
The criteria for which we would continue to process your personal information includes:
- Where there is a legal basis, obligation or legitimate interest in continuing processing your personal information.
- Where processing is necessary for the establishment, exercise or defence of legal claims.
Transfers of personal information
When your personal information is processed through Phorest software, all of it is held within the EU. Your information is processed by the Phorest software and stored in the Amazon Web Services cloud. During this process your data is encrypted in transit and at rest.
Consequences of not providing your personal information to the salon
In the event that you want to purchase a product or service from The Treatment Rooms, certain personal information is required to enter into a contract with you. The Treatment Rooms will not be able to enter into a contract with you to fulfil an attempt to purchase a product or service if you do not provide your personal information. As noted in this privacy statement, we are processing your personal data to comply with legal and statutory obligations and in the performance of a contract. You can always choose not to provide personal information; however, we will be unable to provide certain products, services and treatments in these instances.
Safeguarding your Personal Data
Appropriate measures are taken to protect your personal data from access from unauthorized persons or inappropriate access, internal or external. Your connection to the Phorest system uses a HTTP Secure communication protocol and TLS security. This means all information passed to the Phorest system is encrypted during data input and transfer to the cloud. Any paper files recording your personal data are held in a locked filing cabinet which can only be accessed by authorised personnel in the salon. Employees are only assigned specific access rights and can only access the salon software with the PIN number assigned to them by the management of the salon.
In the occurrence that you want to make a complaint about how your personal data was gathered, how it is being processed by The Treatment Rooms (or third parties used by The Treatment Rooms) or you are not satisfied about how a complaint has been handled, you retain the right to lodge a complaint directly with the supervisory authority and also the The Treatment Rooms Data Protection Officer/ GDPR Owner.
Data Protection Commissioner, Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire[GG8] , SK9 5AF +44 (0) 303 123 1113
The Treatment Rooms Data Protection Officer/GDPR Owner Clare Rogers. 21 New Rd. Brighton BN1 1UF email@example.com.