This privacy notice provides you with details of how we collect and process your personal data through your use of our site www.afilmerlorch.co.uk
By providing us with your data, you warrant to us that you are over 18 years of age.
ALEXANDER FILMER-LORCH is the data controller and we are responsible for your personal data (referred to as “we” in this privacy notice).
Our full details are:
Full name of legal entity: Alexander Filmer-Lorch
Email address: email@example.com
Telephone number: 07789 152784
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at firstname.lastname@example.org
2. What Information Do We Collect About You
Personal data means any information capable of identifying an individual. It does not include anonymised data.
We may process certain types of personal data about you as follows:
Identity Data may include your first name, maiden name, last name, marital status, title, date of birth and gender.
Contact Data may include your address, email address and telephone numbers.
Marketing and Communications Data may include your preferences in receiving marketing communications from us and your communication preferences.
We need to collect the following sensitive data about you in order to provide you with sessions that are safe, to check for medical contra-indications, to enable us to provide sessions that are tailored to your health requirements and for insurance purposes:
Current State of Health which will include any medical condition for which you are undergoing diagnosis or help through a medical professional such as a GP, Consultant, Physiotherapist, Osteopath, Chiropractor. This also includes details of recent / forthcoming operations, recent accidents and injuries.
Medical / Health History which will include any historical medical conditions that you have sought help for through a medical professional such as a GP, Consultant, Physiotherapist, Osteopath, Chiropractor. This also includes details of historical operations, accidents and injuries.
Medication that has been prescribed by a health professional such as a GP or consultant. This does not include food supplements.
We require your explicit consent for processing sensitive data, so when you submit your details during your first appointment, you will be required to sign and date the Cranial Enrolment Form.
Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (to deliver services to you). If you don’t provide us with the requested data, we have the right to refuse to provide you with these services but if we do, we will notify you at the time.
3. How We Collect Your Personal Data
We collect data about you through a variety of different methods including:
Direct interactions: You may provide data by filling in forms or by communicating with us by post, phone, email or otherwise, including when you:
Complete a Cranial Enrolment Form;
Phone / Skype / Facetime;
Give us information during a session that is added to ongoing note taking during and post-session;
Give us feedback.
Third parties: We may receive personal data about you from various third parties (with your prior approval), as set out below:
Health-related information from your Physiotherapist / Osteopath / Chiropractor / Therapist
4. How We Use Your Personal Data
We will only use your personal data when legally permitted. The most common uses of your personal data are:
Where we need to perform the contract between us (i.e. to ascertain sufficient information to provide you with safe sessions within the limitations of your past or present health or medical conditions. To record the progress and outcome of the sessions.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing us at email@example.com
Purposes for processing your personal data
Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.
We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us at firstname.lastname@example.org if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
You will receive marketing communications from us if you have:
requested information from us or have attended sessions with us; or
if you provided us with your details when you registered for a promotion and
in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for their marketing purposes.
Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us at email@example.com
If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
5. Disclosures of Your Personal Details
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:
Your health professionals (GP, Consultant, Physiotherapist, Osteopath, Chiropractor, Therapist) for the purposes of discussing your treatment parties (with your prior approval)
Professional Accountants who provide accountancy services.
Professional Insurers who provide insurance services.
HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
6. International Transfers
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
Please email us at firstname.lastname@example.org if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data Retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our clients (including Contact and Identity Data) for six years after they cease being clients for tax purposes. However, it is an obligation to our Insurers that we retain all personal data including Contact, Identity and Sensitive Data for a minimum of seven years from the date of the last session provided by us.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.
You can see more about these rights at:
If you wish to exercise any of the rights set out above, please email us at email@example.com
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. Third Party Links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Please note we may change this Privacy Notice from time to time.
Version 1.0 (1st May 2018)
Type of Data
Purpose / Activity
Lawful Basis of Processing
To register you as a new client
Performance of a contract with you
To record Emergency Contact Details for you (relating to a third-party)
(a) Necessary for our legitimate interests to provide you with a complete service
To process and deliver our services including:
(a) Manage payments
(b) Collect and recover money owed to us
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests to recover debts owed to us
(c) Marketing and Communications
To manage our relationship with you which will include:
(b) Asking you to leave a review
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests to keep our records updated
To notify you of new services we may offer in the future that may be of interest to you
(c) Marketing and Communications
Necessary for our legitimate interests to develop our services and grow our business