The Green Man
6 High Street
Upton upon Severn
The Green Man Herbal Apothecary takes your privacy seriously. In keeping with the new General Data Protection Regulation (GDPR), which comes into effect on 25 May,2018, I have put together a privacy notice to inform you about the procedures followed with respect to your personal data, how it is kept and how it is used.
1. Intended Purpose: The purpose for collecting and processing patient data in consultation is to obtain a holistic understanding of their condition, create an appropriate treatment based on that data, and monitor the ongoing success of that treatment.
The nature of the business, as it now stands, is that I am the only legitimate person present to collect and process patient information on a daily basis (except where necessary under Article 9 (2) (f) for use in a judicial capacity). Should this status change at any time, the nature of this notice will be updated accordingly and patients notified of the change.
Part of my professional organisation's purpose is as an educational body. The International Register of Consultant Herbalists and Homoeopaths (IRCH), of which I am a member, requires, as part of its training syllabus, that students undergo a minimum number of hours gaining clinical experience. From time to time, specific cases present themselves as ideal examples for those training purposes. In this instance, patient information will be made available to students for the purpose of developing their skills. This will be achieved under the same expectations of purpose that govern myself and through the provision of Lawful Basis, under Student training access, below, namely written consent.
The direct beneficiary of this purpose is the patient foremost, but also family and friends associated with the patient as well as the greater society in general through its impact on interpersonal relationships, productivity, general well-being and resources (domestic and social).
Subsequent usage to this purpose: From time to time, some cases will present themselves as particularly outstanding examples to provide the opportunity for further education of therapists as well as public awareness and knowledge through the use of patient data, in the form of case histories in presentations, publications (articles and books) and documentary, with respect to holistic therapy, the understanding of the energetics of herbs, and the combining and usage of herbal remedies. To safeguard patient privacy the patient information will be represented by age (at the time of initially obtaining the data) and sex (male or female) of the patient it was sourced from.
2. Lawful Basis: The lawful basis for collecting and processing a patient's personal data is:
In Consultation: Under Article 6, Legitimate interest.
Under Article 9 (h), (I)
Student training access: Article 6 Consent (written)
Article 9 (h), (I)
Subsequent usage (public presentations, articles, publications, documentary and testimonials): Article 6 Consent (written)
Article 9 (h), (I), (J)
The consent for subsequent usage can be withdrawn at any time, but will be limited only to future publications, presentations and productions as it is impossible to withdraw those already in circulation.
3. How Your Information is Held
1. Consultations: At the Green Man Herbal Apothecary, I have given much thought as to the best way to secure your data. I have decided, among other reasons to preserve the therapeutic nature in which consultations are conducted, to minimalize technology in the process.
Hand written paper files are used to collect information that you provide me to help me understand your condition from a holistic perspective and provide the appropriate holistic treatment. It is achieved in this fashion in order to preserve the attentive nature of the patient/therapist relationship I wish to establish from the beginning.
Other information such as: the results of medical tests, diaries or statistics you record for me, as well as photos, which are used to visually gage your progress in certain conditions (and are printed out and placed in your file and the original erased) will all be kept in your file.
These files are kept locked away, which makes them out of reach of hidden hackers that eventually can find their way into more technologically based systems.
2. Skype Consultations: Those patients who contact me through Skype will need to request a connection to my Skype address for each separate contact. On completion of this business their address shall be removed. All Skype based correspondence, where applicable, shall be copied into your paper file and then the original source erased.
3. Phone: I will no longer use any form of mobile communication for the purpose of conveying information (either by voice or texting), storing contact details or making appointments. This is because mobile phones are more open to hacking, loss, theft and fraudulent misrepresentation of the caller. Phone communication will be done via my land line number listed above. On one to one contact, a code word, provided to me on our first consultation, will be asked to further verify the legitimate identity of the caller before any information is exchanged.
A provision for leaving a message is in place for times when I am absent or during out of hours. Messages will be accessed by me alone, and in privacy, and will be deleted after the information is appropriately processed.
4. Primary Correspondence: Primary correspondence will be conducted by post or by Email.
Post correspondence will be retained in your file. Email correspondence will be printed where applicable and placed in your file. The Email will then be deleted.
5. Word Processing: Because of its speed and ease in correction, word processing on a computer will be used for such functions as writing up analysis of a case or organising the results of a food diary etc. These will be printed out on completion and placed in the patient's paper file. The original will be Erased using a multiple run system
If the process of writing these documents is protracted, the unfinished work will be stored on a stick and then the work erased from the stick when it is completed and printed. In the meantime, the stick will be kept under lock and accessed by myself.
An Email address or mailing address will also be compiled for the purpose of sharing relevant information to the case, confirming appointments or sending out privacy notice updates. This information will also be stored on a computer stick and kept locked away.
6. Time Limitation: For patients that were of the age of majority at the time of their last consultation, the allows patient data to be kept for a minimum of 7 years and then the destruction of the case file will be determined on an individual basis and by provision of consent for further purpose as outlined above.
The Data collected with respect to minors will be kept for 7 years beyond the date that they reach the age of majority and then be dealt with as in the previous statement, but where consent is obtained from the child when that child has reached the age of majority.
Files will be destroyed using a cross cutter shredder.
7. Friends of The Green Man: Email address provided to me under consent will be used for the purpose of sending out notices and reminders of events (such as herb walks, presentations and workshops) that the individual provided me with their email address to specifically notified of. This list is controlled by me and will not be past on to any third party for any purpose. The addresses are held by consent and the individual has the right to withdraw that consent at any given time.
8. Facebook: Presently, a number of patients contact me via my The Green Man Herbal Apothecary page Using messenger. These messages will be noted and necessary information put in your patient file. Afterwards, the message will be removed to maintain your facebook anonimity.
9. The Green Man Herbal Apothecary Website: The Privacy Notice will be posted on this website as well as all updates in this policy. The website can be reached at www.tgm-mobileherbalist.com