Julia O’Dwyer Limited / Aesthetic Solutions International Ltd / Scalp Solutions International GDPR 2019 PRIVACY NOTICE
This document refers to personal data, which is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain.
The General Data Protection Regulation (GDPR) which is EU wide and far more extensive than its predecessor the Data Protection Act, along with the Privacy and Electronic Communications Regulations (PECR), seek to protect and enhance the rights of EU data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU and its storage within the EEA.
1 – Julia O’Dwyer Limited / Aesthetic Solutions International Ltd / Scalp Solutions International Ltd, 17 Privet Way, Red Lodge, Bury St Edmunds, Suffolk, IP28 8GQ which hereafter for the purposes of this Privacy Notice will be referred to as Julia O’Dwyer, is pleased to provide the following information:
2 – Who am I
Julia O’Dwyer Permanent Makeup and Scalp Micropigmentation Technician and Aesthetics Practitioner performing Permanent Makeup, Scalp Micropigmentation and aesthetics treatments at the request of clients. The clinics also provides other treatments, about which I will be pleased to provide more details. This document is all encompassing for those persons receiving any of my treatmets.
3 – Personal Data
a) For the purposes of providing treatment, Julia O’Dwyer may require detailed personal information. Julia O’Dwyer will only collect what is relevant and necessary for your treatment. When you visit the clinics, Julia O’Dwyer will make notes which may include details concerning your medication, treatment and other issues affecting your health. This data is always held securely, is not shared with anyone not involved in your treatment. To be able to process your personal data it is a condition of any treatment that you give your explicit consent to allow Julia O’Dwyer to document and process your personal medical data. Contact details provided by you such as telephone numbers, email addresses, postal addresses may be used to remind you of future appointments and instructions or other information concerning your treatment.
b) For marketing purposes, Julia O’Dwyer may also use the contact details provided by you to respond to your enquiries, including making telephone contact and emailing information to you which Julia O’Dwyer believes may be of interest to you.
c) In making initial contact with Julia O’Dwyer you consent to me maintaining a marketing dialogue with you until you either opt out (which you can do at any time) or we decide to desist in promoting our services. Julia O’Dwyer will not broker your data and you can ask to be removed from my marketing database by emailing me using the contact details provided at the end of this Privacy Notice.
d) Some basic personal data may be collected about you from the marketing forms and surveys you complete, from records of our correspondence and phone calls and details of your visits to our website, including but not limited to, personally identifying information like Internet Protocol (IP) addresses.
f) Julia O’Dwyer will only collect the information needed so that I can provide you with the services you require, my business does not sell or broker your data.
4 – Legal basis for processing any personal data
To meet our contractual obligations obtained from explicit Patient Consent and legitimate interest to respond to enquiries concerning the services provided.
5 – Legitimate interests pursued by Julia O’Dwyer
To promote treatments for clients with interests in Permanent Makeup, Scalp Micropigmentation and Aesthetic Treatments.
6 – Consent
Through agreeing to this privacy notice you are consenting to Julia O’Dwyer processing your personal data for the purposes outlined. You can withdraw consent at any time by using the postal or email address provided at the end of this Privacy Notice.
7 – Disclosure
Julia O’Dwyer will keep your personal information safe and secure, only Julia O’Dwyer will have access to your patient records. Julia O’Dwyer will not disclose your Personal Information unless compelled to, in order to meet legal obligations, regulations or valid governmental requests. Julia O’Dwyer may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of Julia O’Dwyer.
8 – Retention Policy
Julia O’Dwyer will process personal data during the duration of any treatment and will continue to store only the personal data needed until asked to erase such data by the client.
9 – Data storage
All Data is held in the United Kingdom. Julia O’Dwyer does not store personal data outside the EEA.
10 – Your rights as a data subject
At any point whilst Julia O’Dwyer is in possession of, or processing your personal data, all data subjects have the following rights:
• Right of access – you have the right to request a copy of the information that I hold about you.
• Right of rectification – you have a right to correct data that I hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data I hold about you to be erased from my records.
• Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.
• Right of portability – you have the right to have the data I hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.
In the event that Julia O’Dwyer refuses your request under rights of access, I will provide you with a reason as to why, which you have the right to legally challenge. At your request Julian O’Dwyer can confirm what information it holds about you and how it is processed.
11 – You can request the following information:
• Identity and the contact details of the person or organisation (Julia O’Dwyer) that has determined how and why to process your data.
• Contact details of the data protection officer, where applicable.
• The purpose of the processing as well as the legal basis for processing.
• If the processing is based on the legitimate interests of Julia O’Dwyer and information about these interests.
• The categories of personal data collected, stored and processed.
• Recipient(s) or categories of recipients that the data is/will be disclosed to.
• How long the data will be stored.
• Details of your rights to correct, erasure, restrict or object to such processing.
• Information about your right to withdraw consent at any time.
• How to lodge a complaint with the supervisory authority (ICO).
• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
• The source of personal data if it wasn’t collected directly from you.
• Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
12 – To access what personal data is held, identification will be required
JuliaO’Dwyer will accept the following forms of identification (ID) when information on your personal data is requested: a copy of your driving licence, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If Julia O’Dwyer is dissatisfied with the quality, further information may be sought before personal data can be released. All requests should be made to firstname.lastname@example.org or writing to us at the address further below.
In the event that you wish to make a complaint about how your personal data is being processed by JuliaO’Dwyer you have the right to complain to me.
The contact details for every company under the Julia O’Dwyer umbrella are:
Julia O’Dwyer Ltd
17 Privet Way
Bury St Edmunds
Should you feel your dispute has still not been rectified or you wish to pursue your complaint further you have the right to contact ICO on 0303 123 1113.