This is the privacy policy for Mairi Stones, trading as Change Is Always Possible
and as the following website(s) and social media identities:
Website: www.changeisalwaysossible.com
Linkedin: Mairi Stones – Change Is Always Possible
Contact details:
Inverlochan, Benderloch, Argyll, PA37 1SA
Email: mairi@changeisalwayspossible.com

Change Is Always Possible is committed to safeguarding and preserving the privacy of it’s visitors.
This Policy explains what happens to any personal data that you provide to us, your rights regarding that data and how we use cookies on this website.

We do update this Policy from time to time so please do review this Policy regularly.

There are three sections to the following information:

• About your personal data: the type of data that is collected or used, including when, how and why.
• Your rights: all the ways that you can control what happens with your data.
• Cookies: the use of cookies on this website.

• When you make an enquiry: The name and contact details you give whether by post, phone, email, or otherwise and the content of your message(s) are retained for three reasons:

1. By your consent
2. As part of a ‘contract’ (only while we communicate)
3. For legitimate business interests – for good business practice I keep track of who has made contact in the past and for what reason.

• When you make an online purchase as a single purchase, a membership or subscription: This is a contract for services. Your contact details are dealt with as above (consent, contract, legitimate reasons in addition the following details are retained for six years beyond the end of the contract for legal reasons – your purchase history and the payment details sent to me from Paypal, bank accounts or card services.)
• When you attend a workshop or training: All of the above applies. I also keep a record of your attendance and so that I can send you updates or offers which may be of specific interest to you as a previous attendee.
• When you work with me 1:1: Client work is different. Dependent on the work, you may wish (or need) to provide personal details of a sensitive nature.

Intake forms and questionnaire: these are retained in printed or handwritten format and include your contact details and where appropriate, signature. The sensitive nature of such documents will generally be in relation to health or medical history.

Session notes: these are brief handwritten notes made by me for the purpose of fulfilling our contract and keeping track of the work during the session and from one week to the next, filed separately with only initials and date as identifiers so that no other person may connect these details alone to your personal identity.

Session Follow up: these are brief notes regarding key points from our sessions which will be emailed as a password protected document.

In all cases I am required by law to retain these records for six years after the completion of our contract – or in the case of a minor, from six years beyond the date of their eighteenth birthday.
• Other data sources:

• Incoming data is also received from my website host, Paypal, Skype or Zoom.
• I may receive information from another practitioner or therapist as part of a referral. In such a case you may be unaware that the consented data transfer has taken place, I will therefore inform you of receipt within 28 days.

• Sharing your data:

• Your privacy is important and I do not sell your data nor share it except by your consent or under the law.
• When working together, I may give out elements of your personal information to another practitioner or therapist as part of a referral. This will always only be with your personal consent.
• In continuation of current UK law on confidentiality I also retain the right and in some cases the legal requirement to breach confidentiality to inform an authority such as the police or your GP of impending harm or illegality.

The GDPR sets out clearly what your rights are. It also lays out deadlines for a reply and other rules which are reproduced for your information at the bottom of this section.

• Right to be informed: You have the right to be informed about the collection and use of your personal data. This is a key transparency requirement under the GDPR.

• I must provide you with information including: my purposes for processing your personal data, my retention periods for that personal data, and who it will be shared with. This ‘privacy information’ is provided above.
• I must provide you with privacy information at the time I collect your personal data from you, in other words it has to be available to you before you fill in a form or hand over your data such as your email address.
• If I obtain your personal data from other sources, e.g. by referral or from the payment service provider you selected, I must provide you with privacy information within a reasonable period of obtaining the data and no later than one month.
• There are a few circumstances when I do not need to provide people with privacy information, such as if an individual already has the information or if it would involve a disproportionate effort to provide it.
• The information I provide to people must be concise, transparent, intelligible, easily accessible, and it must use clear and plain language. Therefore if there is anything you do not understand, please get in touch.

• Right of access

• You have the right to access your personal data and supplementary information. This allows you to be aware of and verify the lawfulness of the processing.
• You are entitled to confirmation that your data is being processed, access to your personal data, and other supplementary information as provided in this privacy notice.

• Right to rectification

• You have the right to have the data your personal data corrected if it is incorrect, or completed if it is incomplete.

• Right to erasure

You may request, verbally or in writing, to have your data erased. This is also commonly known as ‘the right to be forgotten’. This right only takes effect when:
• Your personal data is no longer necessary for the purpose for which it was originally collected or processed,
• you withdraw your consent when the sole legal basis to hold this information is your consent,
• there is a legitimate interest in processing this data, which does not override your request,
• processing/analysing of the personal data was for direct marketing purposes and this is the use you object to,
• your personal data was processed unlawfully without a proper legal basis,
• There is a legal obligation to comply with your request; or
• If the personal data was processed to offer information society services to a child.

• Right to restrict processing

You have the right to request the restriction or suppression of your personal data. In other words you want to stop the data being used but keep it on file. In this case your personal data cannot be used and can only be stored unless:
• you give your consent;
• it is for the establishment, exercise or defence of legal claims;
• it is for the protection of the rights of another person (natural or legal); or
• it is for reasons of important public interest.

• Right to data portability

This allows you to obtain and reuse your personal data for your own purposes across different services. It allows you to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without affecting its usability. Doing this is meant to enable you to take advantage of applications and services that can use this data to find you a better deal or help you understand your spending habits. In general this rule exists for data held by big service providers, such as your call history or insurance or gas bill history. The right also only applies to information you have provided.

If, as a private client you wish to carry a copy or your case notes or other sensitive data to another practitioner or other mental, physical or spiritual health service, these may be provided to you or to the nominated provider, on request, as an encrypted and password protected document.

• Right to object

Individuals have the right to object to:
• processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling);
• direct marketing (including profiling); and
• processing for purposes of scientific/historical research and statistics.
Your objection must be made on grounds relating to your particular situation. Once you object your data can no longer be processed, unless,
• there are demonstrably compelling legitimate grounds for the processing, which override the interests, rights and freedoms of the individual; or
• the processing is for the establishment, exercise or defense of legal claims.

You may complain directly to me using the contact details above. If you find the outcome unsatisfactory you are then able to object or complain to:

Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues:
www.ico.org.uk
Helpline on 0303 123 1113.

You may of course also exercise your right to legal action.

• Timelines:
You can claim a right verbally or in writing.

A response should come without delay and at least within one month of receipt. The time limit is calculated from the day after you make the request (whether the day after is a working day or not) until the corresponding calendar date in the next month. I am to respond within 28 days.

• Exceptions:
When you request access to your data, a copy must be provided free of charge. However, you can be charged a ‘reasonable fee’ when a request is:

• manifestly unfounded or excessive, particularly if it is repetitive, unless that’s because I failed to respond; or
• for further copies of the same information (that’s previously been provided).

Cookies provide information regarding the computer used by a visitor. We may use cookies where appropriate to gather information about your computer in order to assist us in improving our website.
This website uses cookies specifically from Google Analytics, this is to give users a better experience when visiting our site. More information on this can be read on Google’s website
You can adjust the settings on your computer to decline any cookies if you wish. This can be done within the “settings” section of your computer. For more information please read the advice at AboutCookies.org.

Disclaimer: The views expressed here, in blog posts and on the website Change Is Always Possible are those of the author Mairi Stones alone, and do not represent the views of any associated bodies. We do not diagnose, treat, prevent or cure any disease or condition. Information provided in this blog is not intended to substitute advice, treatment and/or diagnosis from qualified medical and nutritional professionals. Take what you like and leave the rest.