Privacy Policy
Introduction
Your privacy is important to me and you can be confident that your personal information will be kept safe and secure and will only be used for the purpose it was given to me. I adhere to current data protection legislation, including the General Data Protection Regulation (EU/2016/679) (the GDPR), the Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2003. This privacy notice tells you what I will do with your personal information from initial point of contact through to after your Constellation sessions have ended, including:
• Why I am able to process your information and what purpose I am processing it for
• Whether you have to provide it to me
• How long I store it for
• Whether there are other recipients of your personal information
• Whether I intend to transfer it to another country
• Whether I do automated decision-making or profiling
• Your data protection rights
I am happy to chat through any questions you might have about my data protection policy and you can contact me via abi@abiberger.net
‘Data controller’ is the term used to describe the person/ organisation that collects and stores and has responsibility for people’s personal data. In this instance, the data controller is me. I am registered with the Information Commissioner’s Office. My postal address is: 35 Fitzroy Road, London NW1 8TP
My lawful basis for holding and using your personal information:
The GDPR states that I must have a lawful basis for processing your personal data. There are different lawful bases depending on the stage at which I am processing your data. I have explained these below:
If you have had Constellation sessions with me, I will use legitimate interest as my lawful basis for holding and using your personal information.
If you are currently having Constellation sessions or if you are in contact with me to consider Constellation work, I will process your personal data where it is necessary for the performance of our contract.
The GDPR also makes sure that I look after any sensitive personal information that you may disclose to me appropriately. This type of information is called ‘special category personal information’. The lawful basis for me processing any special categories of personal information is that it is for provision of services (in this case, Constellation sessions) and necessary for a contract with a professional service provider (in this case, a contract between me and you).
How I Use Your Information
Initial contact.
When you contact me with an enquiry about my services I will collect information to help me satisfy your enquiry. This will include:
• Name
• Pronouns
• Phone number (optional)
• Summary of why you are getting in touch (optional)
If you decide not to proceed I will ensure all your personal data is deleted within 1 year. If you would like me to delete this information sooner, just let me know.
Exemption:
• Blocked telephone numbers or spammed email addresses, where the content of messages is misaligned with the service offered here.
Everything you discuss with me is confidential. That confidentiality will only be broken where required to by law. I will always try to speak to you about this first, unless there are safeguarding issues that prevent this.
I will keep a record of your personal details to help your sessions run smoothly. These details are kept securely and are not shared with any third party. I may keep brief written “aide-mémoire” style notes of each session and a family history intake form if you return one.
Likewise, any email correspondence will be deleted after 1 year if it is not important.
After your session has ended.
Once your session has ended, I will secure any notes made for 3 years in the event that you may return for more work. The notes will then be securely deleted or shredded. If you want me to delete your information sooner than this, or you have any questions regarding the exemptions in this privacy policy, please tell me.
Exemptions:
• Data retained that relates to non payment of fees.
Third Party Recipients of Personal Data
I sometimes contract a supplier to carry out specific tasks. I take care to choose third parties with robust privacy standards. Current third party contractors are as follows (privacy and legal statement linked to where appropriate):
• Mailchimp: for the purposes of my general mailing list.
For third party website information, read on below.
Your Rights
I try to be as open as I can be in terms of giving people access to their personal information. You have a right to ask me to delete your personal information, to limit how I use your personal information, or to stop processing your personal information. You also have a right to ask for a copy of any information that I hold about you and to object to the use of your personal data in some circumstances. You can read more about your rights at ico.org.uk/your-data-matters. If I do hold information about you I will:
• give you a description of it and where it came from
• tell you why I am holding its, tell you how long I will store your data and how I made this decision.
• tell you who it could be disclosed to
• let you have a copy of the information in an intelligible form.
You can also ask me at any time to correct any mistakes there may be in the personal information I hold about you. To make a request for any personal information I may hold about you, please put the request in writing addressing it to abi@abiberger.net. If you have any complaint about how I handle your personal data please do not hesitate to get in touch with me by writing or emailing to the contact details given above. I would welcome any suggestions for improving my data protection procedures.
If you want to make a formal complaint about the way I have processed your personal information you can contact the ICO which is the statutory body that oversees data protection law in the UK. For more information go to ico.org.uk/make-a-complaint.
Data Security
I take the security of the data I hold about you very seriously and as such I take every effort to make sure it is kept secure. I do this as follows:
• Prioritising privacy standards when choosing contractors.
• Using strong passwords.