Mistletoe Clinic has adopted the following policy in line with The General Data Protection Regulation (GDPR) legislation that came into force on 25th May 2018.
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 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 – Who we are
Mistletoe Clinic is owned by Sarah Barron who offers kinesiology services at 31 Shooters Hill, Pangbourne, Berkshire, RG8 7DZ. Sarah Barron is a sole trader. We are pleased to provide the following information.
2 – Personal data
a) For the purposes of providing treatment, Mistletoe Clinic may require detailed medical information. We will only collect what is relevant and necessary for your treatment. When you visit our practice, we 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 Mistletoe Clinic to document and process your personal medical data. Contact details provided by you, such as telephone numbers, email addresses and postal addresses, may be used to provide you with treatment summaries and other relevant information concerning your treatment, as well as to remind you about future appointments.
b) For marketing purposes, Mistletoe Clinic may also use the contact details provided by you to respond to your enquiries, and to send any information which the practice believes may be of interest to you (via telephone or email).
c) In making initial contact with the practice, you consent to Mistletoe Clinic 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. Mistletoe Clinic do not broker your data and you can ask to be removed from our marketing database by emailing or phoning the clinic using the contact details provided at the end of this Privacy Notice.
d) Some basic personal data may be collected about you 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.
e) Mistletoe Clinic website uses cookies, which is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Create.net uses cookies to help Mistletoe Clinic to identify and track visitors and their website access preferences. Mistletoe Clinic website visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using the website.
f) Mistletoe Clinic will only collect the information needed so that we can provide you with the services you require, the business does not sell or broker your data.
3 – 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.
4 – Legitimate interests pursued
To promote treatments for patients with all types of health problems indicated for kinesiology.
5 – Consent
Through agreeing to this privacy notice you are consenting to Mistletoe Clinic processing your personal data for the purposes outlined. You can withdraw consent at any time by using the postal, email address or telephone number provided at the end of this Privacy Notice.
6 – Disclosure
Mistletoe Clinic will keep your personal information safe and secure. Mistletoe Clinic will not disclose your Personal Information unless compelled to, in order to meet legal obligations, regulations or valid governmental requests. The practice 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 its staff.
7 – Retention policy
Mistletoe Clinic will process personal data during the duration of any treatment and will continue to store only the personal data needed for eight years after the contract has expired to meet any legal obligations. After eight years all personal data will be deleted, unless basic information needs to be retained by us to meet our future obligations to you, such as erasure details. Records concerning minors who have received treatment will be retained until the child has reached the age of 25.
8 – Data storage
All Data is held in the United Kingdom. Mistletoe Clinic does not store personal data outside the EEA.
9 – Your rights as a Data Subject
At any point whilst Mistletoe Clinic 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 we hold about you.
· Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
· Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our 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 we 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 Mistletoe Clinic refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge.
10 – You can request the following information
· Identity and the contact details of the person or organisation (Mistletoe Clinic) that has determined how and why to process your data.
· The purpose of the processing as well as the legal basis for processing.
· If the processing is based on the legitimate interests of Mistletoe Clinic 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.
11 – To access what personal data is held, identification will be required
Mistletoe Clinic 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 Mistletoe Clinic is dissatisfied with the quality, further information may be sought before personal data can be released. All requests should be emailed to sarah@mistletoe-clinic.co.uk or by writing to us at Mistletoe Clinic, 31 Shooters Hill, Pangbourne, Berkshire, RG8 7DZ.
12 – Compliments and comments
We do our best to deliver the best possible care to all our clients. It’s our aim try to make your experience, from the moment you walk through our clinic door, as pleasant and successful as we can.
Hopefully that’s evident to you, and if you’d like to leave a review, we’d really appreciate it. It’s always reassuring to hear that we’ve helped.
If there’s an aspect of your treatment, or anything about the whole process from booking to discharge where you think we could make any improvements, then please send an email so that we can look into it: sarah@mistletoe-clinic.co.uk.
13 – Complaints
a) Sending your complaint directly to Mistletoe Clinic
Very occasionally, something might not go according to plan, and you might wish to complain. We take complaints very seriously, so if you have concern about any aspect of your treatment, please let us know the full details as soon as possible. We will do our best to deal with it as quickly as we can. Where necessary, we will also make appropriate changes to the way we conduct future treatments.
You can make your complaint in person, by phone, by letter or in an email. Please use the following contact details:
Mistletoe Clinic, 31 Shooters Hill, Pangbourne, Berkshire, RG8 7DZ
07884434120
We promise to look into your concern within a few days and will aim to:
• Find out what gave rise to your concern
• Explain or apologise, if this is appropriate
• Reflect on what we can do to ensure that this problem does not arise again
b) Seeking mediation from the Kinesiology Association
If you feel uncomfortable complaining directly or do not feel that your complaint has been resolved to your satisfaction, you can contact the Kinesiology Association on: +44 (0) 1980 881646; admin@kinesiologyassociation.org. The Association is an independent organisation who will try to help you resolve your complaint.
c) Data protection guidance regarding your complaint
References:
i) Data Protection Act 2018 (DPA)
ii) UK GDPR
iii) Data (Use and Access) Act 2025
The Data (Use and Access) Act 2025 (DUAA) came in to force in June 2025. It does not replace the DPA or GDPR, but amends certain areas. One area is the requirement to have a policy specifically related to data protection complaints.
Principles
The Practice will take all data protection complaints seriously, treat complainants fairly and respectfully, investigate complaints impartially, respond within reasonable timescales and take corrective action where appropriate.
How to make a complaint
Complaints may be submitted by email, post, telephone, or in person. Where a complaint is made orally, staff should document the complaint and seek confirmation from the complainant that the record is accurate.
Information required
Complainants should provide their name, contact details, a description of the concern, relevant dates, supporting evidence, and their desired outcome where known.
Complaint handling procedure
Complaints will be acknowledged within five working days, investigated appropriately, and a written response will normally be provided within one calendar month. Complex matters may be extended by up to two further months where permitted by law.
Personal data breaches
Where a complaint identifies a potential breach involving sensitive or personal data, the Practice will assess the breach and comply with applicable ICO notification requirements.
Subject access request complaints
The Practice will ensure searches are reasonable and proportionate in accordance with current legislation.
Escalation
If dissatisfied, complainants should first contact the Practice Manager/Clinic Director. If their issue cannot be resolved this way, then they may contact the Information Commissioner's Office (ICO), Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, www.ico.org.uk.
Complaint records
The Practice will maintain a Data Protection Complaints Register and retain complaint records for a minimum of six years from closure unless a longer period is required by law.
Learning and improvement
The Practice will periodically review complaints to identify trends, training needs and opportunities for improvement.
Responsibilities
The Clinic Director is responsible for overall compliance. All staff (including assistants, associates and consultants working as part of the Practice) must recognise and report complaints, cooperate with investigations and maintain confidentiality.
Policy review
This policy will be reviewed annually, following significant legislative changes, significant incidents or updated regulatory guidance.