Privacy Policy

Data Protection & Privacy Policy

Data Protection / Privacy Policy

This is a statement of the Data Protection Policy adopted by the Scottish Massage Therapists Organisation (SMTO). To perform its function, the SMTO needs to collect and use certain types of information about Massage Therapists who join or apply to join the SMTO.

As this data is held electronically, the Scottish Massage Therapists’ Organisation is registered with the Information Commissioner’s Office (I.C.O.)  

The SMTO regards the lawful and correct treatment of personal information as important to the achievement of our objectives. We therefore strive to ensure that our organisation treats personal information lawfully and correctly.

Data Protection Principles

The SMTO endorses and is committed to adhering to the eight data protection principles set out in the Data Protection Act 1998. The eight Principles require that personal information is

  • Fairly and lawfully processed

  • Processed for limited purposes

  • Adequate, relevant and not excessive

  • Accurate, and kept up-to-date

  • Not kept longer than necessary

  • Processed in accordance with the data subject’s rights

  • Held securely

  • Not transferred to countries outside the European Economic Area without adequate protection being provided to the personal data on individual subjects

What information does SMTO hold?

As an SMTO member you have elected to join SMTO by either completing a paper application form or applying online. You have consented to SMTO holding your personal details, including your name, address, email address, phone numbers, website address, date of birth, and which therapies you are qualified to practice.

Use of Your Personal Data

We will use personal information provided by you for the purpose of processing your membership, or gathered by the SMTO for the following purposes

  • To decide your eligibility to join the SMTO and entry into the SMTO Directory of Therapists
  • To update your details and renew your membership whenever required, including taking payment
  • To enable the general public to search the Directory of Therapists to utilise your service
  • To administer, update and maintain the Directory of Therapists, if you choose to be in it.
  • To process and respond to requests, enquiries and complaints received from you
  • To process and respond to requests, enquiries and complaints received about your fitness to practise
  • To send you the SMTO e-magazine called ‘On The Massage Scene’ 3 times per annum, usually in February, June and October.
  • To communicate with you about SMTO services, up-coming training and events in Scotland, work and volunteering opportunities, and other news and notes of interest that we feel therapists might be interested in.
  • To analyse trends and profiles, and compile statistics
  • For auditing purposes
  • To carry out customer satisfaction research
  • To prevent or detect fraud
  • To enable third parties to carry out any of the above on our behalf, once we have given them permission to do so.

We will hold your personal information on our systems for as long as is necessary for the purposes set out above and we will remove it when the purposes have been met.

Published Directory of Therapists

SMTO will make your Directory entry information available to any enquirer as part of the published Directory of Therapists, unless you specifically opt out from inclusion.

The general public can inspect the following information on the online register:

  • Your full name

  • Your telephone number

  • Your website (where provided)

  • Your approximate geographical location

  • Your skills/disciplines that you practice

  • Your home address, contact details, date of birth and other data are not available to the public unless given to us specifically for that purpose by you.

Consent to collect personal information

In compliance with the General Data Protection Act 2018, when a new applicant applies to join the SMTO, or when an existing SMTO member renews their annual membership, they will be asked to formally consent to allow the SMTO to collect and process their personal information.

The SMTO must process SMTO members and new applicant’s personal information to perform its function. If an individual is not content to allow the SMTO to process personal information, that individual will not be eligible to join the SMTO.

Security and Storage of Your Personal Data

The SMTO will take appropriate technical and organisational measures to limit the opportunity for unauthorised or unlawful processing of personal data and to guard against accidental loss, destruction of, or damage to personal data. All access to SMTO data is password protected.

Appropriate contractual obligations shall be incorporated into contracts that SMTO enters into with third parties. SMTO shall ensure that all staff employed to undertake data processing are aware of their responsibilities in relation to the processing of personal data as it applies to their area of work.

Sharing of Personal Data

We may share information in the following circumstances:

  • Where we are required to do so by Law, with authorised legal authorities and SMTO’s lawyers

  • Where we are required to do so with authorised Regulatory Authorities, such as the General Council for Massage Therapies (G.C.M.T.) or the Complementary & Natural Healthcare Council (C.N.H.C.)

  • When you are applying for entry in to other registers, e.g. CNHC registration.

  • Where we are required to do so with our insurance company, Balens Insurance Ltd, to confirm that you are in fact an SMTO member or wishing to be.

  • If you pay your membership fee by card, we are required to share your name, city/town you live in, phone number, email address and card details with WorldPay.
  • When you have given consent for us to do so

Please note – if you have elected to be in the Directory of Therapists then some of your details will be accessible BY THE PUBLIC.

Your individual rights under the Data Protection Act 2018 (G.D.P.R.)

You have:

  • the right of access to your personal data. You can do this by logging into the Member’s section of the SMTO website, using your user name and password that you have created. If you have any problems getting in, please email SMTO and we can reset your password for you.
  • the right to object to and restrict the processing of your personal data. To advise SMTO of any objections and/or restrictions to the use of your data, please email SMTO advising us of this fact. 
  • the right to rectification of your personal data. You can do this by logging into the Members’ section of the SMTO website, using your user name and password that you have created. Once logged in, you can change your details held within the SMTO admin system. Any new therapies listed must first be advised to SMTO with the submission of a Diploma certificate or by a Certificate of Attendance. Only then will SMTO update your list of therapies. 
  • the right to erasure of your personal data. To remove your data from the SMTO database, please email SMTO advising us of this fact. We should be able to remove your data from the database relatively quickly, but details of your last renewal will need to be kept until the end of the financial year and the completion of SMTO’s accounts. 
  • the right to data portability (to receive a copy of your personal data). You can do this by logging into the Members’ section of the SMTO website, using your user name and password that you have created, and then printing off your details. If you have any problems getting in, please email SMTO and we can reset your password for you.

SMTO’s Rights

In exercising your Individual Rights, you should understand that in some situations SMTO may be unable to fully meet your request. For example, if you make a request for me to delete all your personal data, I may be required to retain some data for taxation, legal, regulatory and insurance purposes.

You should understand that when exercising your rights, a substantial public or vital interest may take precedence over any request you make. In addition, where these interests apply, we are required by law to grant access to this data for law enforcement, legal and/or health related matters.


If you are dissatisfied with the way in which I process your personal data, you have the right to complain to the UK’s Data Protection Supervisory Authority, the Information Commissioner’s Office (ICO).

The ICO may be contacted via its website which is ICO Concerns by live chat or by calling their helpline on 0303-123-1113.

How to contact SMTO

If you have any questions regarding the use of your data, please contact SMTO on:

  • 08454-638852 or 07715-663852
  • Write to us at 27 Craigs Avenue, Edinburgh, EH12 8HS.
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