Lic.Ac., BA (Hons), MBAcC

Traditional Five Element Acupuncture


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 General Data Protection Regulation (GDPR) which is EU wide and far more extensive than its predecessor the Data Protection Act, along with the Privacy & 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 with the EU and its storage within the EEA.

Who am I

I Pam Everitt am an acupuncturist, member of The British Acupuncture Council and work on a self-employed, sole trader basis in three clinics at Cheltenham, Newent and Stroud.  I am fully insured and operate as a business.

How I obtain your personal data/Retention

  • For the purpose of booking your appointments I will collect contact details from you (name, address, phone numbers).  I may also use contact details provided by you to respond to your enquiries, including making telephone contact and e mailing information regarding appointments

You provide me with personal data in the following ways:

  • By answering verbally my questions at the first & subsequent appointments which I then log manually on paper records
  • By contacting me by e mail to make your appointment and sometimes referring to the health condition that you are seeking help with.  I do not print off these communications and file them in your personal file. The e mails automatically delete after a certain period of time and therefore are not recorded anywhere on your records
  • Through e mail (see above) and telephone
  • Details of contact I have had with you such as referrals and appointment requests
  • Health information including your previous medical history, dietary and lifestyle, supplements and medicine details, clinic notes


I use this information in order to provide you with direct healthcare.  This means that the legal basis of my holding your personal data is for legitimate interest.

Following completion of your healthcare I retain your personal data for the period defined by my professional body The British Acupuncture Council.

Do you share my information with other organisations?

I will keep information about you confidential.  I will only disclose your information with other third parties with your express consent with the exception of the following third parties:

  • The British Acupuncture Council for the processing of a complaint made by you
  • Any legal or crime prevention agencies and/or to satisfy any regulatory request if I have a duty to do so or if the law allows me to do so
  • I will seek your express consent before sharing your information with your GP or other healthcare providers.  However, if I believe your life is in danger then I may pass your information onto an appropriate authority (such as the police, social services in the case of a child or vulnerable adult, or GP in cases of self harm) using the legal basis of vital interests


Your Protection

I undertake at all times to protect your personal data, including any health and contact details, in a manner which is consistent with my duty of professional confidence and the requirements of the General Data Protection Regulation (GDPR) concerning data protection.  I will also undertake reasonable security measures to protect your personal data storage.

I will keep your personal information safe and secure.  I will not disclose your personal information unless compelled to in order to meet legal obligations, regulations or valid governmental requests.


I will ask you to complete a Patient GDPR Response form separately which I am obliged to ask you to complete to give your consent to different purposes and types of processing for the information I hold.

What are your rights?

Every individual has the right to see, amend, delete or have a copy, of data held that can identify you, with some exceptions.  You do not need to give a reason to see your data.

If you want to access your data you must make a subject access request in writing to me at  Under special circumstances, some information may be withheld.

I shall respond within 20 working days from the point of receiving the request and all necessary information from you.  My response will include the details of the personal data I hold on you. The purposes of processing the information.

You have the right subject to exemptions, to ask to:

  • Have your information deleted
  • Have your information corrected or updated where it is no longer accurate
  • Ask me to stop processing information about your where I am not required to do  so by law or in accordance with The British Acupuncture Council guidelines
  • Receive a copy of your personal data, which you have provided to me, in a structured, commonly used and machine readable format and have the right to transmit the data to another controller, without hindrance from me
  • Object at any time to the processing of personal data concerning you

If you would like to invoke any of the above rights then please write to me at one of the clinic addresses shown on my website:

What safeguards are in place to ensure data that identifies me is secure?

I only use information that may identify you in accordance with GDPR.  This requires me to process personal data only if there is a legitimate basis for doing so and that any processing must be fair and lawful.

Within the health sector, I also have to follow the common law of duty of confidence, which means that where identifiable information about you has been given in confidence, it should be treated as confidential and only shared for the purpose of providing direct healthcare.  I will protect your information, inform you of how your information will be used and allow you to decide if and how your information can be shared.

I also ensure the information I hold is in secure locations.  I keep personal and confidential information in locked filing cabinets in a private residence where there is no access for members of the public.


If you have a complaint regarding the use of your personal data then please contact me by emailing me at

and I will do my best to help you.

If your complaint is not resolved to your satisfaction and you wish to make a formal complaint to the Information Commissioner’s Office (ICO), you can contact them on 0303 1231113.

Data Storage

All data is held in the United Kingdom.  I do not store personal data outside the EEA.