Privacy Policy Scalp Micropigmentation
PHOENIX SMP — PRIVACY POLICY
Last updated: 29/07/2026
1. Who We Are
Phoenix SMP ("we," "us," "our") is a scalp micropigmentation clinic operating from within Clinic Visjeune, 759 Wimborne Rd, Moordown, Bournemouth BH9 2BA.
For the purposes of UK data protection law (the UK GDPR and the Data Protection Act 2018), Phoenix SMP is the **data controller** responsible for your personal information.
Contact details:
Email: phoenixsmpbournemouth@gmail.com
Phone: 07780228391
Address: 759 Wimborne Rd, Moordown, Bournemouth BH9 2BA
2. What Information We Collect
We collect different types of information depending on how you interact with us:
a) Enquiry & Booking Information
- Name, email address, phone number
- Preferred appointment times/dates
- Details of your enquiry or treatment interest
b) Consultation & Medical Information (Special Category Data)
- Medical history relevant to treatment suitability (e.g., skin conditions, allergies, medication, autoimmune conditions, pregnancy status)
- GP details, where provided
- Details discussed during consultation regarding your hair loss pattern and treatment goals
c) Treatment Records
- Treatment consent forms
- Patch test records
- Session notes, pigment batch references, treatment dates
- Photographs of the treatment area (before, during healing, and after treatment) for clinical record-keeping purposes
d) Marketing Consent Information
- Your selected preference regarding use of photos/videos/testimonials (per our tiered consent system)
e) Payment Information
- Transaction records (we do not directly store full card details — these are processed securely via our payment/booking provider, [insert provider name, e.g., Fresha/Stripe])
f) Website & Communication Data
- Information submitted via contact forms or booking widgets
- Email/message correspondence
3. Why We Collect This Information (Our Legal Basis)
Under UK GDPR, we must have a valid legal basis for processing your data. Here's how this applies to each type of information we collect:
| Type of Data | Legal Basis |
| Contact/booking details | Contract — necessary to provide the service you've requested |
| Medical history & health information | Explicit consent (required for special category/health data) and **vital interests** where relevant to your safety during treatment |
| Treatment records & patch test results | Contract and legal obligation (professional/clinical record-keeping requirements) |
| Photographs — clinical record purposes | Consent and legitimate interest (tracking healing progress, ensuring treatment quality) |
| Photographs — marketing use | Explicit, separate consent (per your selected tier — you may withdraw this at any time) |
| Payment information | Contract and legal obligation (financial record-keeping for tax purposes) |
| Marketing communications (e.g., email newsletters) | Consent (opt-in only — we will never add you to marketing lists without clear, active agreement) |
4. How We Use Your Information
We use your information to:
- Assess your suitability for treatment and ensure your safety
- Provide, plan, and deliver your scalp micropigmentation treatment
- Maintain accurate clinical records as required by professional and insurance standards
- Communicate with you regarding appointments, aftercare, and follow-ups
- Process payments
- With your explicit, separate consent: share before/after results on our social media, website, or marketing materials
- Improve our services based on client feedback
- Comply with legal, insurance, and regulatory obligations
We will never use your medical information or images for any purpose beyond what you have specifically consented to.
5. Who We Share Your Information With
We do not sell or rent your personal information to any third party. We may share limited information with:
| Third Party | Purpose |
| Booking/scheduling software provider (e.g., Fresha/Acuity) | To manage appointments and payments securely |
| Bookkeeping/accounting software provider (e.g., FreeAgent/QuickBooks) | To process payment records for financial and tax purposes |
| Insurance provider | In the event of a claim, complaint, or as required by policy terms |
| HMRC / relevant regulatory or legal authorities | Where required by law |
| BCP Council | If required as part of Special Treatment Licence compliance/inspection |
We require all third-party providers to handle your data in accordance with UK GDPR standards.
6. Photographs & Marketing Consent
We operate a **tiered consent system** for any photographs or video taken during your treatment:
- Full Public Consent — used publicly, may include your face and name
- Anonymous Public Consent — used publicly, face obscured/not shown, no name used
- Private Use Only — used solely for internal clinical records, never shared publicly
- Written Testimonial Only — no imagery used, written feedback only (with your permission)
- No Consent — no use beyond mandatory internal clinical records
Your selected preference is recorded on your Photo, Video & Testimonial Consent form and applies until you tell us otherwise. You may withdraw or change your consent at any time by contacting us directly. Please note that content already published to third-party platforms (e.g., previously posted social media content) may not always be fully retrievable upon request, though we will make reasonable efforts to remove it where technically possible.
7. How Long We Keep Your Information
| Data Type | Retention Period |
| Medical history, consent forms, treatment records | 7 years from your last treatment (in line with standard clinical negligence limitation periods — please note your specific insurer may specify a different exact period, which will take precedence if longer) |
| Financial/payment records | 6 years (HMRC requirement for business financial records) |
| Marketing consent preferences | Until you withdraw consent or request deletion |
| General enquiry data (if you do not proceed to treatment) | 12 months, then securely deleted |
After these periods, your information is securely deleted or anonymised.
8. How We Keep Your Information Secure
We take the security of your information seriously:
- Digital records are stored via GDPR-compliant, password-protected software with encrypted data storage
- Physical documents (if any) are kept in a locked, access-controlled location
- Access to your information is limited to Phoenix SMP's practitioner and, where necessary, essential third-party service providers listed above
- Payment information is processed via secure, PCI-compliant third-party payment systems — we do not store full card details ourselves
9. Your Rights Under UK GDPR
You have the right to:
- Access — request a copy of the personal information we hold about you
- Rectification — request correction of inaccurate or incomplete information
- Erasure — request deletion of your information, subject to our legal/clinical record-keeping obligations
- Restriction — request that we limit how we use your information in certain circumstances
- Object — object to processing based on legitimate interest, particularly regarding marketing use
- Withdraw consent — withdraw previously given consent at any time (this does not affect the lawfulness of processing carried out before withdrawal)
- Data portability — request your data in a portable format, where technically applicable
- Complain — lodge a complaint with the **Information Commissioner's Office (ICO) if you believe your data has been mishandled
ICO contact details:
Website: ico.org.uk
Helpline: 0303 123 1113
To exercise any of these rights, please contact us directly at phoenixsmpbournemouth@gmail.com We will respond within **one calendar month** as required by law.
10. Children's Information
Phoenix SMP does not knowingly collect information from, or provide treatment to, individuals under the age of 18. Our services are intended for adult clients only.
11. Cookies & Website Data
Our website may use cookies to improve your browsing experience and understand how visitors use our site (e.g., via Google Analytics). You can control cookie preferences through your browser settings or via our cookie consent banner. For full details, see our separate Cookie Policy [if applicable].
12. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. The "last updated" date at the top of this policy will always reflect the most recent version. We encourage you to review this policy periodically.
13. Contact Us
If you have any questions about this Privacy Policy or how we handle your information, please contact:
Phoenix SMP
759 Wimborne Rd, Moordown, Bournemouth BH9 2BA
Email: phoenixsmpbournemouth@gmail.com
Phone: 07780228391