Privacy Policy

Privacy Notice for Bowen Manchester

As a Bowen therapy practitioner, I take your privacy seriously. This statement explains how I collect, store, use, and protect your personal information in line with the UK General Data Protection Regulation (UK GDPR).

1. Who I Am

Data Controller: Denise McAvoy, Sole Trader, Bowen Manchester

Contact Details: bowenmanchester@gmail.com / 07927 868363

2. What Information I Collect

To provide safe and effective Bowen therapy in your sessions, I collect:

Personal Details: Your name, date of birth, address, phone number, and email. We may ask for, and hold, an emergency contact number for family or friend.

Health Information: Your medical history, symptoms, current medication, and treatment notes. (This is known as Special Category Data - see below)

I am the only person with access to your collected data.  Your health records are kept in a safe locked unit and mobile/email contact is password protected.

3. Our Legal Basis for Holding Your Data

Because I hold health information, the law requires me to meet two different steps under the UK GDPR:

Step 1: The Lawful Basis (Article 6)
I process your basic personal details under Article 6(1)(b) Contract. This is because I need your information to fulfil our agreement to provide you with treatment, to communicate to book your appointments, and take payments.
I may also rely on Article 6(1)(f) Legitimate Interests to maintain records for business and insurance purposes.

Step 2: The Special Category Condition (Article 9 Explained)

Health records are highly private, so Article 9 normally bans people from holding them. However, the law provides exemptions. I hold your health data under Article 9(2)(h). This rule allows me to handle sensitive health information because it is necessary for the provision of health or social care or treatment. Under UK law (the Data Protection Act 2018), this applies to private therapists who operate under a professional duty of confidentiality.

4. How I Share Your Data

Your information is strictly confidential. I will never share, sell or exchange your information with third parties for marketing purposes. I will only share your information if:

• You ask me to share it (for example, sending notes to your GP). 

• I am legally required to do so by a court of law.

• There is an immediate risk to your life or safety.

5. How Long I Keep Your Data

I keep your records secure for at least 7 and no more than 8 years after your last treatment. This timeframe aligns with standard industry insurance requirements and professional association guidelines. For children, records are kept until they turn 25.

6. Your Rights and How to Access Your Data

Under UK data protection laws, you have specific rights regarding your personal information. Most notably, you have the Right of Access.

Requesting a copy: You can ask for a copy of the personal details and health records I hold about you at any time.

The response timeline: I will normally provide this information within one calendar month of receiving your request.

"Stopping the clock": Should I need to ask you for proof of identity, or if I need to clarify exactly what information you need, the one-month countdown pauses. The clock restarts as soon as you provide the necessary details.

Proportionate searches: In line with the law, I will conduct a reasonable and proportionate search to locate your data within my record systems.

Other rights: You also have the right to ask me to correct mistakes in your records or restrict how I use your information in certain situations.

7. How to Complain about Data Processing

If you have any concerns or are unhappy with how I handle your personal information, you have the right to lodge a formal complaint directly with me.

How to submit: Please send your complaint in writing to:

    Denise McAvoy at bowenmanchester@gmail.com

What to expect: In line with UK data protection rules, I will acknowledge your complaint within 30 days of receiving it.

Investigation: I will investigate your concerns thoroughly and provide you with a clear, final outcome without undue delay.

Escalation: If you remain unhappy with my final response, or if I fail to respond, you then have the right to escalate your complaint to the Information Commissioner’s Office (ICO) at ico.org.uk