Privacy Notice

NHS Test and Trace

To support NHS Test and Trace (which is part of the Department for Health and Social Care) in England, I have been mandated by law to collect and keep a limited record of staff, clients and visitors who come to my classes for the purpose of contact tracing.

By maintaining records of staff, customers and visitors, and sharing these with NHS Test and Trace where requested, we can help to identify people who may have been exposed to the coronavirus.

As a client you will be asked to provide some basic information and contact details. The following information will be collected:

the names of all patients or visitors,
a contact phone number and email address for each patient or visitor
date of visit and arrival time and departure time

When that information is requested by the NHS Test and Trace service, the service would at this point be responsible for compliance with data protection legislation for that period of time. The NHS Test and Trace service as part of safeguarding your personal data, has in place technical, organisational and administrative security measures to protect your personal information that it receives from the venue/establishment, that it holds from loss, misuse, and unauthorised access, disclosure, alteration and destruction. In addition, if you only interact with one member of staff during your visit, the name of the assigned staff member will be recorded alongside your information.

NHS Test and Trace have asked us to retain this information for 21 days from the date of your visit, to enable contact tracing to be carried out by NHS Test and Trace during that period. We will only share information with NHS Test and Trace if it is specifically requested by them.

Please note; if you do not wish to have your details passed to NHS Test and Trace then the best option is to delay your decision to attend classes until this requirement is withdrawn.

Privacy notice - Mark Guggiari T/AS Tai Chi Skills

Introduction

In order to comply with my obligations to properly look after your personal data I am obliged to make you aware of how I do that.

The safety of your information is very important to me - I do not share your information with anyone except other than anyone you give me explicit permission to share it with. I do not sell any information.

Why do I need this information?

I need your phone, email and address details to be able to contact you regarding appointments, forwarding information, communicating with you.

Here is the detail:

Purpose of privacy notice

The processing of personal data is governed by the General Data Protection Regulation 2016/679 (the GDPR).

One of the rights is a right to be informed, which means I have to give you information about the way in which I use, share and store your personal information.

This updated new privacy notice comes into effect and will be published on my website on 18th June 2020.

Who are we?

Mark Guggiari is the data controller of Mark Guggiari T/AS Tai Chi Skills. This means I decide how your personal data is processed and for what purposes.

Whose information does this privacy notice apply to?

This privacy notice applies to information I collect from:

people who attend my classes;
prospective people that may attend my classes;
people that have previously attended my classes;
people who subscribe to my newsletters;
visitors to my website
people that sign up for online classes and members services;

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 I may hold about you include your contact and class details.

How do I process your personal data?

I comply with my 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. I use your personal data for the purposes set out below.

Sections 1 – 5 apply to people who attend my classes; prospective people that may attend my classes; people that have previously attended my classes; people who subscribe to my newsletters; visitors to my website; people that sign up for online classes and members services

I use your name, telephone number and email address to communicate details of my classes. I am unable to send or receive encrypted emails so you should be aware that any emails I send or receive may not be protected in transit. I will also monitor any emails sent to me, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send me is within the bounds of the law.
I use your name, address, telephone number and email address, only if I have your explicit consent, to send you marketing materials. I am unable to send or receive encrypted emails so you should be aware that any emails I send or receive may not be protected in transit. I will also monitor any emails sent to me, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send me is within the bounds of the law.
I keep a permanent attendance register which records all people attending my classes to keep a record of when you attended for tax purposes and to secure potential evidence in the event of a criminal prosecution, civil litigation, insurance claim or complaint.
I keep class registration forms on paper, in locked filing cabinets at my home address. Patient phone records are stored on a phone which is password protected in the event of loss.
I keep accident records for any class members, visitors or staff who are involved in accidents at my classes 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.

Section 6 applies to those who complain about my services

When I receive a complaint from a person I 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.
I will only use the personal information I collect to process the complaint and to check on the level of service I provide. I 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, I will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis. I may need to provide personal information collected and processed in relation to complaints to my insurance company.
I will keep personal information contained in complaint files in line with my 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 me I will only use the information supplied to me to deal with the enquiry and any subsequent issues and to check on the level of service I provide.

Section 7 applies to my website users

My website, including my blog, is hosted on the Wix.com platform. Wix.com provides me with the online platform that allows me to sell my products and services to you. Your data may be stored through Wix.com’s data storage, databases and the general Wix.com applications. They store your data on secure servers behind a firewall.
All direct payment gateways offered by Wix.com and used by my adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers.
When you conduct a transaction on my website, as part of the process, I collect personal information you give us such as your name, address and email address. Your personal information will be used for the specific reasons stated above only.
When someone visits my website I use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. I 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. I do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. If I do want to collect personally identifiable information through my website, I will be up front about this. I will make it clear when I collect personal information and will explain what I intend to do with it.
I use website cookies to improve user experience of our website by enabling our website to 'remember' users, either for the duration of their visit - using a 'session cookie' - or for repeat visits - using a 'persistent cookie'.

Section 8 applies to subscribers to my newsletters

I maintain and use records of subscribers to my newsletters, only with their consent, for marketing purposes.
I use a third party providers, MailChimp.com and Wix.com to deliver my e-newsletters. I 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 MailChimp.com and Wix.com privacy notice.
Sharing your personal data
Your personal data will be treated as strictly confidential, and will be shared:

- with the relevant authority such as the police or a court, if necessary for compliance with a legal obligation to which I am 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 children or vulnerable adults; or

- with 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 I keep your personal data?

I keep your personal data for no longer than reasonably necessary.
Class registers and Registration forms are recorded on paper and locked in a metal cabinet. Telephone numbers and email addresses are saved to gmail and protected by a personal identification number.
Patient telephone numbers and email addresses are reviewed and if not attended class in the last year are deleted (they will still be recorded in the registration records for the relevant time).
Simple email enquiries are deleted immediately.
Records for the purposes of complying with HM Revenue and Customers requirements, such as class registers and registration forms, are kept for a minimum of 5 years after the submission deadline for the relevant tax year: https://www.gov.uk/self-employed-records/how-long-to-keep-your-records
At any time you may request that changes are made to your contact details.

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 I hold about you.
The right to request that I correct any personal data if it is found to be inaccurate or out of date.
The right to request your personal data is erased where it is no longer necessary for me to retain such data.
The right to withdraw your consent to the processing at any time. This right does not apply where I am processing information using a lawful purpose other than consent.
The right to request that I 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 I am 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. I 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 I wish to use your personal data for a new purpose, not covered by this Privacy Notice, then I 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, I will seek your prior consent to the new processing.

Changes and clarifications will take effect immediately upon their posting on the website.

Contact Details

To exercise all relevant rights, queries of complaints please in the first instance contact me at Mark Guggiari at www.taichiskills.com

You can contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.

END OF PRIVACY NOTICE