Who We Are
Bespoke Wellbeing Ltd gather and process your personal information in accordance with this privacy notice and in compliance with the relevant data protection Regulation and laws. This notice provides you with the necessary information regarding your rights and our obligations, and explains how, why and when we process your personal data.
Bespoke Wellbeing Ltd registered office is at The Gym Way, 21 Bryanston Street, London, W1H 7AB and we are a company registered in England and Wales under company number 10170537. We are registered on the Information Commissioner’s Office Register; registration number ZA094451 and act as the data controller when processing your data. Our designated Data Protection Officer/Appointed Person is Clare Henson-Bowen, who can be contacted at email@example.com
Information That We Collect
Bespoke Wellbeing Ltd processes your personal information to meet our legal, statutory and contractual obligations and to provide you with our products and services. We will never collect any unnecessary personal data from you and do not process your information in any way, other than as specified in this notice.
The personal data that we may collect from you include: –
* Title / Name
* Date of Birth
* Home Address
* Personal Email / Business Email
* Home Telephone Number / Mobile Telephone Number / Work Telephone Number
* Work Title
* Medical insurance details
* Referral Source
* Special Category Data (i.e. health/medical information, work history, hobbies, family background)
* GP / Consultant Details
* Bank details (for refund purposes only)
* CV’s for new therapists
We collect information in the below ways: –
* Website ‘contact us’ page
* Email correspondence (either from you or referral from GP / Consultant or employer)
* Face to face consultation
* Social media (i.e. Facebook, Twitter, Instagram, LinkedIn)
* Employment CV’s
How We Use Your Personal Data (Legal Basis for Processing)
Bespoke Wellbeing Ltd takes your privacy very seriously and will never disclose, share or sell your data without your consent; unless required to do so by law. We only retain your data for as long as is necessary and for the purpose(s) specified in this notice. Where you have consented to us providing you with promotional offers and marketing, you are free to withdraw this consent at any time. The purposes and reasons for processing your personal data are detailed below: –
1. We collect your personal data so we can book you an appointment and identify you when providing you with our services.
2. We collect your personal data to ensure that appointment confirmation and reminders are sent out to your preferred phone and email address.
3. We collect and store your personal data as part of our legal obligation for physiotherapy and occupational therapy note keeping.
4. We may share your data with external health care professionals who are involved in, or recommended to be involved in your care. This will always be discussed with you and consent gained.
5. We may share your data with your external referring company or insurer (where applicable) as part of your treatment programme. This will always be discussed with you and consent gained.
You have the right to access any personal information that Bespoke Wellbeing Ltd processes about you and to request information about: –
* What personal data we hold about you
* The purposes of the processing
* The categories of personal data concerned
* The recipients to whom the personal data has/will be disclosed
* How long we intend to store your personal data for
* If we did not collect the data directly from you, information about the source
If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.
You also have the right to request erasure of your personal data or to restrict processing (where applicable) in accordance with the data protection laws; as well as to object to any direct marketing from us. Where applicable, you have the right to data portability of your information.
If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.
Sharing and Disclosing Your Personal Information
We do not share or disclose any of your personal information without your consent, other than for the purposes specified in this notice or where there is a legal requirement. Bespoke Wellbeing Ltd uses third-parties to provide the below services and business functions; however, all processors acting on our behalf only process your data in accordance with instructions from us and comply fully with this privacy notice, the data protection laws and any other appropriate confidentiality and security measures.
We use Cliniko to book our appointments online, provide electronic note keeping and storage for your special category data, send out invoices, send out receipts and store clinic letters. All data in relation to your clinical management is processed and stored here.
For more information about Cliniko, please read their Privacy Notice at https://www.cliniko.com/policies/privacy
We use Xero to electronically assist our book keeping. The only information we provide them with is your name, address, referral source, insurer codes (if applicable) and appointment dates to meet business and legal requirements.
For more information about Xero, please read their Privacy Notice at https://www.xero.com/uk/about/terms/privacy/
We use Izettle to take card payments from self-paying customers at the time of your appointment. Examples of personal data that Izettle may process are your name, personal ID number or date of birth, home address, e-mail address, IP-address, unique identifier of devices you use to access and use the services and our websites, bank account details and transaction history information and encrypted card data.
For more information about Izettle, please read their Privacy Notice at https://www.izettle.com/gb/privacy-policy
We use Sable Accounting to do our bookkeeping and tax returns and they act in the capacity of a processor on our behalf. The only information we provide them with is your name, address, referral source, insurer codes (if applicable) and appointment dates to meet business and legal requirements.
For more information about Sable Accounting, please read their Privacy Notice at https://www.sableinternational.com/privacy-policy
Bespoke Wellbeing Ltd takes your privacy seriously and takes every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place, including: –
* Restricted access / IT authentication
* Anti-Virus / Malware
* Email encryption
Bespoke Wellbeing utilise some products or services (or parts of them) that may be hosted/stored in non-EU countries, which means that we may transfer any information which is submitted by you outside the European Economic Area (“EEA”) for the below purposes: –
* Website hosting
* Email servers
* Marketing database
Therefore, when you use our website, send us an email, sign up to our newsletter etc… the personal information you submit may be stored on servers which are hosted in non-EU countries. Where this is the case, we will take steps to ensure that those providers use the necessary level of protection for your information and abide by strict agreements and measures set out by Bespoke Wellbeing Ltd to protect your data and comply with the relevant data protection laws.
Consequences of Not Providing Your Data
You are not obligated to provide your personal information to Bespoke Wellbeing Ltd, however, as this information is required for us to provide you with our clinical services, we will not be able to offer our services without it.
How Long We Keep Your Data
Bespoke Wellbeing Ltd only ever retains personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations. We are required under UK tax law to keep your basic personal data (name, address, contact details) for a minimum of 6 years after which time it will be destroyed. We are required by UK Physiotherapy and Occupational Therapy guidelines to keep your clinical records for a minimum of 8 years from the date of last treatment for adult records, and for children eight years after their 18 birthday or until 25 years of age.
Where you have consented to us using your details for direct marketing, we will keep such data until you notify us otherwise and/or withdraw your consent.
Special Categories Data
Owing to the services and treatments that we offer, Bespoke Wellbeing Ltd will need to process sensitive personal information (known as special category data) about you, to ensure safe and effective treatment can take place. Where we collect such information, we will only request and process the minimum necessary for the specified purpose and identify a compliant legal basis for doing so.
Where we rely on your consent for processing special category data, we will obtain your explicit consent through a signature at your first consultation. You can modify or withdraw consent at any time, which we will act on immediately, unless there is a legitimate or legal reason for not doing so.
Lodging A Complaint
Bespoke Wellbeing Ltd only processes your personal information in compliance with this privacy notice and in accordance with the relevant data protection laws. If, however you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, you have the right to lodge a complaint with the supervisory authority.
Bespoke Wellbeing Ltd
Clare Henson-Bowen (Data Protection Officer)
Oasis Sports Centre, 32 Endell Street, London, WC2H 9AG / firstname.lastname@example.org
Information Commissioner’s Office
0303 123 1113 / https://ico.org.uk/global/contact-us/email/
Bespoke Wellbeing Ltd take your privacy seriously and will only process your personal data with your consent and in accordance with the terms stated in our Privacy Notice. We will obtain your explicit consent before your online or face-to-face consultation. You can modify or withdraw consent at any time, which we will act on immediately, unless there is a legitimate or legal reason for not doing so.
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