Privacy and Cookie Policy.
Last updated 15 December 2025.
1. Introduction
1.1 We are Georgia van Embden trading as Georgia van Embden Physiotherapy from Algo Business Centre, Unit 46, Glenearn Road, Perth PH2 0NJ (we, us or our). We are the controller responsible for your personal data and we are responsible for this website. We provide physiotherapy services as a sole trader practice.
1.2 We comply with our obligations under the Data Protection Act 2018 and the EU law retained version of the General Data Protection Regulation ((EU) (2016/679) (UK GDPR) (data protection laws). If any of these laws are replaced or superseded, we will also comply with those.
1.3 We are registered with the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (ico.org.uk), and our registration number is ZB947725. If you have any concerns about data protection, we would appreciate if you contacted us first so we can discuss these with you before you approach the ICO. You also have the right to make a complaint at any time to the ICO. For data protection matters, please email us at info@gvephysio.com.
1.4 We respect your privacy and are committed to protecting your personal data. This policy explains the terms on which we collect and process your personal data, and how we protect your personal data, such as when you:
(a) visit our website at https://www.gvephysio.com/,
(b) contact us with any enquiry by post, email, social media, or phone,
(c) engage us for our services,
(d) are referred to us by your employer, and
(e) when you otherwise engage with us.
1.5 We are registered with the Health and Care Professions Council (HCPC) and are a member of the Chartered Society of Physiotherapy (CSP). As a physiotherapy practice, we have legal and ethical obligations to keep accurate clinical records, protect your personal data and maintain confidentiality, except where the law requires us to disclose information or where there is a risk of serious harm to you or others.
2. The data we may collect about you
2.1 Personal data/information means any information about an individual from which that person can be identified. It does not include anonymous data. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
(a) Identity Data includes your full name, marital status, title, date of birth, gender, employer, job title.
(b) Contact Data includes home address, billing address, email address and telephone number, together with work contact details where you are referred by your employer.
(c) Financial Data includes bank account and payment card details.
(d) Transaction Data includes details about payments to and from you and other details of the services you have purchased from us.
(e) Technical Data includes internet protocol (IP) address, your login data, time of access, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website.
(f) Profile Data includes your username and password (if applicable), purchases or orders made by you, your interests, preferences, feedback, and survey responses.
(g) Usage Data includes information about how you use our website and services.
(h) Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
(i) Aggregated Data such as statistical or demographic data for any purpose, is not considered personal data in law as this data will not directly or indirectly reveal your identity to us. We may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.
(j) Special Category Data means special categories of personal data and includes information about your health, race or ethnicity, criminal convictions, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, genetic and biometric data.
3. Do we collect special categories of personal data?
3.1 Under UK GDPR, there are certain types of personal data is likely to be more sensitive and so these are given additional protections. These are referred to as ‘Special Category Data’ and include the following:
(a) personal data revealing racial or ethnic origin;
(b) personal data revealing political opinions;
(c) personal data revealing religious or philosophical beliefs;
(d) personal data revealing trade union membership;
(e) genetic data;
(f) biometric data (where used for identification purposes);
(g) data concerning health (history of current complaint, medical history, medication list, previous investigations and/or treatment);
(h) data concerning a person’s sex life; and
(i) data concerning a person’s sexual orientation.
3.2 As a physiotherapy practice, we do not collect most categories of Special Category Data as part of our standard processes. However, we do collect and process information concerning your health, and you may also share other sensitive information with us during the course of treatment. This information is handled with the highest level of care. It is processed in line with our legal obligations under data protection laws and our professional duties as a registrant of the Health and Care Professions Council (HCPC).
3.3 We also owe you a strict duty of confidentiality. This is explained in our client contract. We will not disclose your information unless required by law or where we believe there is a risk of harm to you or others.
3.4 We process health information because it is necessary for the provision of physiotherapy treatment and for the management of your care. Our legal bases for doing so are Contract and Consent, as explained in section 5. In limited circumstances where you choose to provide other types of Special Category Data, we may rely on your explicit consent to process that information.
3.5 We will only use your personal data for the purpose for which it was collected, which in the context of our services is to assess, treat, and manage your physiotherapy needs.
3.6 You have specific rights over your personal data, although there are situations where our professional and legal duties to retain clinical records may override a request to delete information. More details can be found under ‘What are your legal rights to your personal data?’
4. How is your personal data collected?
We may use different methods to collect data from and about you including through:
4.1 Direct interactions. You may give us your Identity Data, and Contact Data by filling in forms, by corresponding or engaging with us by post, phone, email, social media or otherwise, by creating, funding or receiving an e-gift card collection, by contacting customer support, or by interacting with our social-media pages.
4.2 Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies including third-party website tracking technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
4.3 Public sources. We may collect personal data about you from public sources, such as Google, Companies House, or the electoral register.
4.4 Employer. We may receive your Identity Data, Contact Data, and Special Category Data if you have been referred by your employer.
5. How we use your personal data
We will only use your personal data when we can rely on a legitimate (lawful) basis, such as:
5.1 Contract: Where we need to perform the contract we are about to enter into or have entered into with you, or where we have entered into a contract with your employer.
5.2 Legitimate Interests: Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
5.3 Legal Obligation: Where we need to comply with a legal obligation.
5.4 Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter or you complete our physio assessment form prior to our provision of services.
6. Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
7. Direct marketing
7.1 You will receive marketing communications from us if you have opted in (or, where legally permitted, if you have previously purchased from us and have not opted out).
7.2 We may also analyse your Identity Data, Contact Data, Technical Data, Usage Data and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.
8. Third party marketing
We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.
9. Opting out of marketing
9.1 You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us at info@gvephysio.com.
9.2 If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to updates to our terms and conditions and checking that your contact details are correct.
10. Cookies
10.1 Our website uses third-party website tracking technologies to gather cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and to display advertisements according to your interests, and also allows us to improve our website services.
10.2 A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive. Some emails and pages contain a tiny graphic file that lets us see when you open a message or visit a page. Web beacons work together with cookies; if you disable cookies, they may stop working.
10.3 We display a cookie banner the first time you visit, allowing you to accept or reject non-essential cookies.
10.4 We use the following cookies:
(a) Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
(b) Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
(c) Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
10.5 When you first visit, a cookie banner lets you accept, reject or customise non-essential cookies. You can change your choices at any time by clicking “Cookie Settings” in the website footer. Most browsers also let you block or delete cookies through their settings; see www.allaboutcookies.org for instructions.
11. Disclosures of your personal data
11.1 We may disclose your information in the following cases:
(a) We can disclose your personal data to our employees, workers, and subcontractors in order to facilitate the provision of services to you.
(b) We can disclose it if we have a legal obligation to do so, or in order to protect other people’s property, safety, or rights.
(c) We can exchange information with others to protect against fraud or credit risks.
11.2 We may communicate with your GP or another healthcare professional involved in your care where you have provided consent, or where we have a professional duty to do so in your best interests.
11.3 Where we provide physiotherapy services on behalf of Health Partners Group Limited, we act as a data processor. We share treatment reports and outcome information securely with Health Partners Group Limited in line with their instructions and professional requirements.
11.4 We use a variety of third party services (sub-processors) as part of our business activities and you/we will therefore share your personal data with these sub-processors. The types of sub-processors we might use fall into different categories, as follows:
(a) Payment processing services;
(b) Order fulfilment service providers;
(c) Analytics service providers;
(d) Event/campaign management service providers;
(e) Website management service providers;
(f) Information technology and related infrastructure provision;
(g) Email delivery services;
(h) Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
11.5 Specifically, we use:
(a) Jane, a third party practice management system, to support the administration of our physiotherapy services. This means that Jane acts as a data processor on our behalf.
Jane provides appointment scheduling, clinical recordkeeping, payment processing and related administrative functions, and therefore processes personal data (including health information) strictly in accordance with our instructions.
Jane is UK GDPR compliant and implements appropriate technical and organisational measures to keep your personal data secure. Your data is stored on Jane’s secure servers and access is restricted through password protection and two factor authentication. Further information about Jane’s data protection practices can be found at https://jane.app/legal/privacy-notice.
(b) Heidi Health, a third party clinical documentation and transcription platform, to assist with preparing and maintaining accurate clinical notes.
Heidi acts as a data processor on our behalf. During some consultations, we may use Heidi to create an audio recording and transcript of the session for note taking purposes. Heidi processes personal data (including health information) strictly in accordance with our instructions and only for the purpose of generating and storing clinical documentation.
Heidi is an Australian company but states that UK personal data is held in the UK and processed within the UK and the European Economic Area (EEA). Heidi implements appropriate technical and organisational measures to keep your personal data secure. Further information about Heidi’s data protection practices can be found in its privacy policy at https://www.heidihealth.com/en-gb/legal/privacy-policy.
11.6 We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
12. Data security
12.1 Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure data we collect. In particular, we use the following measures:
(a) storing data on secure platforms
(b) password protected accounts.
Clinical notes are stored securely within Jane, which is password protected and accessed using two factor authentication.
12.2 In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
12.3 If there is an incident where we become aware that there has been a data breach, we will let you know without undue delay. We will then take all necessary steps, including informing the ICO, to limit the extent of the breach and to prevent a further recurrence.
12.4 Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
12.5 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your information transmitted to our website; any transmission is at your own risk.
13. International transfers
13.1 We may transfer your personal data outside of the UK or the EEA where we engage third parties to provide services on our behalf, such as to receive services or deal with payment. Whenever we transfer your personal data out of the UK or the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
(a) We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data
(b) We may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely the International Data Transfer Addendum to the European Commission’s standard contractual clauses for international data transfers.
13.2 Jane’s servers may be located outside the UK. Where this is the case, appropriate safeguards such as standard contractual clauses are in place.
13.3 Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or the EEA.
14. Data retention
14.1 We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. However, as a physiotherapy practice, we are legally and professionally required to retain clinical records for specific minimum periods. Clinical records for adults must be kept for at least seven years from the date of last treatment. Clinical records for children must be kept until the patient is 25 years old (or 26 years old if treated at age 17). These retention periods may be extended if a complaint, claim or safeguarding concern is raised. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
14.2 To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
14.3 By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
14.4 As explained in section 15, you may request deletion of certain personal data, but clinical notes and treatment records cannot be deleted before the end of the required retention period due to our legal and professional obligations. Where deletion is not possible, we will explain the reason and, if appropriate, restrict access to the data.
14.5 After the relevant retention periods have expired, clinical records and other personal data will be securely erased. We may anonymise certain data for research or statistical purposes; anonymised data is not personal data and may be used indefinitely.
15. Your legal rights
15.1 You have several rights under data protection laws in relation to your personal data. These rights are not absolute and may be limited in certain circumstances, particularly where we must retain clinical records for legal or professional reasons. Your rights include the following:
(a) Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
(c) Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
(d) Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
(e) Object to processing of your personal data where we are relying on a legitimate interest (or those of a third-party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
(f) You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see ‘Opting out of marketing’ in section 9 for details of how to object to receiving direct marketing communications).
(g) Request the transfer of your personal data to you or to a third-party. We will provide to you, or a third-party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
(h) Withdraw consent at any time where we are relying on consent to process your personal data (see the table in section 6 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
(i) Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
i. If you want us to establish the data's accuracy;
ii. Where our use of the data is unlawful but you do not want us to erase it;
iii. Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
iv. You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
15.2 If you wish to exercise any of the rights set out above, please contact us at info@gvephysio.com.
15.3 You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
15.4 We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
15.5 We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
16. Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
17. Changes to this privacy and cookie policy and your duty to inform us of changes.
17.1 We keep our privacy and cookie policy under regular review. This version was last updated on the date at the header of this policy.
17.2 It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.