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The following privacy notice outlines how Carlin Hair collects, uses, protects and transfers your personal data. Carlin Hair is a salon that provides services including cutting hair, wig styling, colouring and dressing hair.
The data protection officer/data officer for the organisation is Helen Keane. You can contact the data protection officer/owner by sending an email to firstname.lastname@example.org or writing to 251B Cavehill Road, Belfast, BT15 5BS.
Personal data collected
The personal data we collect is:
- Home Address (if required for a service e.g Wedding)
- Email Address
- Phone Number
- Patch test results
- Colour notes
Purpose and Legal Basis for Processing Your Data
Carlin Hair takes your privacy seriously and we will never sell or rent your personal data to any third party. Sharing of your data and direct marketing activities are only carried out with your express consent, which you are free to withdraw at any time.
We need to obtain and process your personal data to provide you with our products, services and treatments and to fulfil our business and legal obligations. We will never collect any personal information from you that we do not need or retain any data that is no longer necessary for the purpose specified in this notice.
Where we request sensitive data from you (i.e health or medical data), the reason(s) for the request will be clearly given along with the purpose the processing. Explicit consent through a signature will always be required for us to obtain and process your health information.
Who is Processing my data?
Carlin Hair, 251B Cavehill Road, Belfast, BT15 5BS are the data controller ad processes your personal information for the purpose laid out in this privacy notice. Phorest, Anglesea Row, Smithfield, Dublin 7, DO7 W5NE, Ireland, acts as data processor on behalf of Carlin Hair and have access to personal details only in cases of customer support or troubleshooting is required by Carlin Hair. Further, they must process the personal information in accordance with this Privacy Notice and as permitted by applicable data protection laws.
Your personal data is processed to:
- Collect specific personal data (name, address, email, contact number) that is required to enter into a contract to sell a product or service.
- Engage in communication with you including confirmation and reminders of appointments, and requests to change/cancel appointments.
- Collect health information to perform and agreed services appropriately, and potentially highlight areas that products and services may cause issues to clients because of their health.
- Ensure a safe and provide industry standard advice.
- Select relevant offers, promotions and information for you.
- Estimate the number of customers we have.
- Hold personal data that’s is required by law to respond to legal process.
- Hold for insurance purposes.
- Store customer records.
Your rights as the individual
If your personal data is held by Carlin Hair you hold particular rights to it.
Where you have provided consent for us to contact you as part of our marketing services, you have the right to modify or withdraw your consent at any time by using the unsubscribe option accompanied with all of our direct marketing or by contacting the Carlin Hair Data Officer.
You also have the right:
- To be informed of how your personal data will be used before it is collected.
- To access your personal data personal data and to information on how your information is used after it has been gathered.
- To have personal data corrected if it incomplete, inaccurate or out-of-date.
- To request the removal or deletion of personal data where there is no compelling reason for its continued processing.
- To restrict processing, to ‘block’ processing of your personal data.
- To data portability, having your data moved, copied or transferred from Carlin Hair to another organisation in an easily readable format.
- To object to direct marketing from us.
Special categories of personal data collected
Health questions may be asked in many of our consent forms to potentially highlight treatments that may have a negative effect on your health due to medication you are taking or a condition you have. Carlin Hair asks for consent prior to gathering and processing information. At any time after giving consent, you can withdraw your consent, subject to legal, insurance and contractual restrictions (see more on “your rights as an individual”). Your privacy is very important to us and we only use this information for determining your suitability for the treatment.
Process of Collection
Your personal data is collected when you provide it to us through Phorest software, our website, over the phone, in Carlin Hair salons, by email, social media, Inwriting or any other means by which you provide it to us. Information is stored using the Phorest software platform as well as some level of paper record keeping.
Carlin Hair gives you access to information about your account and bookings through Phorest software, for the limited purpose of viewing and updating that information.
Carlin Hair does not collect the personal data of children under the age of 16 without parental or guardian consent. If you believe that we hold any information from or about a child under 16, please contact Carlin Hair and if we cannot immediately obtain parental consent, will remove the personaldata from storage.
Your personal data is shared with Phorest representatives in cases that customer support and troubleshooting is required for the salon. Carlin Hair do not share your personal information with any third party without your prior consent, other than those already disclosed in this privacy notice or as part of our legal obligations under the relevant data protection laws.
Use of Data Processors
Data processors are third parties who provide some elements of our business services for us. Where we use a third party, we have strict agreements in place governing the processing of your personal data, on which no action can be taken without instruction from us. The third-parties with whom we work will never share or disclose your personal information and will hold it securely at all times.
Carlin Hair use software provided by Phorest that gives a computerised appointment booking system that can be used for holding colour information, email, telephone numbers and their own internal marketing (with customer consent that can be withdrawn at any stage).
Read their Privacy Notice
How Long do we keep your data?
Carlin Hair retains your personal data for as long as necessary to provide you you’re your services as our client. Carlin Hair are required under tax laws to keep your personal data for a minimum of 7 years. Health and Safety records will be retained for 10 years and where we have your consent for marketing purposes, we will retain the minimum required data until you notify us that you no longer wish to receive such information.
The criteria for which we would continue to process your personal information includes:
- Where there is a legal basis, obligation or legitimate interest to continuing processing your personal information.
- Where processing is necessary for the establishment, exercise of defence of legal claims.
Transfers of Personal information
When your personal data is processed through Phorest software, all of it is held within the EU. Your information is processed by the Phorest software and stored in the Amazon Web services cloud. During this process your data is encrypted in transit and at rest.
Consequences of not providing your personal information to Carlin Hair
In the event that you want to purchase a product or service from Carlin Hair, certain personal information is required to enter into contract with you. Carlin Hair will not be able to enter into a contract with you to fulfil an attempt to purchase a product or service if you do not provide your personal information.
As noted in this privacy statement, we are processing your personal data to comply with legal and statutory obligations and in the performance of your contract. You can always choose not to provide personal information; however, we will be unable to provide certain products, services and treatments in these instances.
Safeguarding your personal data
Appropriate measures are taken to protect your personal data from access from unauthorised persons or inappropriate access, internal or external. Your connection to the phorest system uses HTTP Secure communication protocol and TLS security. This means all the information passed to the Phorest system is encrypted during data input and transfer to the cloud. Any paper files recording your personal data are held in a locked filing cabinet or safe which can only be accessed by authorised personnel in the salon. Employees are only assigned specific access rights and can only access the salon software with the PIN number assigned to them by the management of the salon.
In the occurrence that you want to make a complaint about how your personal data was gathered, how it is being processed by Carlin Hair or you are not satisfied about how a complaint has been handled, you retain the right to lodge a complaint directly with the supervisory authority and Carlin Hair and also the Carlin Hair Data Protection Officer/ GDPR Owner.
Data Protection Supervisory Authority
Data Protection Commissioner,
Canal House, Station Road,
Ireland R32 AP23
Data Protection Commissioner,
Information Commissioners Office,
+44(0)303 123 1113
Carlin Hair Data Protection Officer/GDPR Owner
251B Cavehill Road