Privacy Policy

We are committed to protecting your personal information and ensuring complete privacy and data security.

Adorn Beauty - Privacy Policy and GDPR Compliance Statement

Effective Date: [01/08/2018]

Adorn Beauty is committed to ensuring the privacy, confidentiality, and security of personal data in accordance with the UK Data Protection Act 2018, the General Data Protection Regulation (GDPR), and all other relevant laws.

This Privacy Policy explains how we collect, process, store, and protect your personal information when:

  • This Privacy Policy outlines how we collect, process, store, and protect your personal information when:
  • You visit our salons in person.
  • You access our websites https://adorn-beauty.com or https://adorn.beauty
  • You download and use the Adorn Beauty Client App for Android or iOS
  • You make bookings via our appointment management partner AppointGem.com

All prices, treatments and information are correct at the time of posting this website and are subject to revision without notice.

1. Who we are and who is responsible for your data

Adorn Beauty is the trading name of a group of salon companies operating across Hertfordshire, Greater London, Buckinghamshire and Berkshire. For data protection purposes, the company that operates the branch you visit is the data controller for your information.
Item Detail
Trading name Adorn Beauty / Adorn Hair & Beauty
Operating companies Adorn Beauty Ltd, Adorn Hair & Beauty, Adorn Spa Ltd, Adora Hair Ltd (registered in England and Wales)
Websites https://adorn-beauty.com and https://adorn.beauty
You can confirm our companies on the Companies House register at https://www.gov.uk/get-information-about-a-company, and you can confirm our data protection registration on the ICO register at https://ico.org.uk/ESDWebPages/Search.
Action required before publishing: every UK business that processes personal data by electronic means must pay a data protection fee to the ICO and appear on the public register. If Adorn Beauty is not currently registered, register at https://ico.org.uk/registration/ and insert the reference above.

2. When this notice applies

This notice covers your information whenever:
• you visit any Adorn Beauty branch in person
• you book, enquire, cancel or reschedule by phone, WhatsApp, email or social media
• you use https://adorn-beauty.com or https://adorn.beauty
• you use the Adorn Beauty Client App on Android or iOS
• you book through our appointment management partner, AppointGem
• you complete a consultation form, patch test record or treatment consent form
• you buy a gift voucher, product or treatment package
• you enter a competition, review us, or join our loyalty or marketing lists
• you are recorded by CCTV inside or immediately outside our premises

3. Why we ask you to complete a consultation form

This is the part clients ask about most often, so we want to be completely open about it.
A consultation form is not paperwork for the sake of paperwork. Every treatment we offer places something on your skin, in your skin, near your eyes or against your circulation. A treatment that is perfectly safe for one person can cause a burn, a scar, an allergic reaction or a lasting sensitisation in another. The only way we can tell the difference is to ask you first.
We ask you to complete a consultation form for six reasons.
3.1 To keep you physically safe
Your health, your medication and your skin history change how your body responds to heat, wax, acid, adhesive, light energy and pressure. Screening you before we begin is how we decide whether a treatment is safe for you today, whether it needs to be adapted, or whether it must be postponed or declined.
3.2 To obtain your informed consent
Under UK law, consent to a treatment is only valid if it is informed. That means you must understand what the treatment involves, what the realistic outcome is, what the risks and side effects are, and what the aftercare requires, before you agree to it. The consultation form is the record that this conversation actually happened.
3.3 Because our insurance requires it
Our professional treatment liability and public liability policies are conditional on us holding a completed consultation and consent record, and where relevant a patch test record, for every client before every qualifying treatment. Without those records our cover can be refused, which would leave both you and us unprotected if something went wrong.
3.4 Because the law and our licences require it
Depending on the treatment and the branch, we operate under local authority registration or licensing for skin piercing, electrolysis, laser and light treatments and other special treatments, and under health and safety and cosmetic product legislation. Those regimes require documented client screening and record keeping. You can find your local council’s licensing team via https://www.gov.uk/find-local-council.
3.5 To evidence what happened, if it is ever questioned
If you later experience a reaction, or make a complaint or a claim, the consultation record is the evidence of what you told us, what we advised, what we used and what you agreed to. This protects you as much as it protects us. In data protection language this is called the establishment, exercise or defence of legal claims, and it is a recognised lawful ground for holding health information.
3.6 To give you a better, more consistent result
Knowing your skin type, your sensitivities, the products you use at home, the brands and shades we used last time and how you reacted means any of our therapists at any of our branches can pick up exactly where the last one left off.
3.7 What happens if you would rather not answer
You are never obliged to answer a health question. However, please understand the consequence: if we do not have the information we need to judge that a treatment is safe for you, we cannot carry it out. That is not us being difficult. It is us refusing to guess with your skin, your eyes or your health. Where possible we will offer you a safe alternative, a patch test, or a referral back to your GP first.

4. Why we need your name, your date of birth and your contact details

What we collect and why

Everything below is collected so that we can treat you safely, meet the law, and keep your records straight. If you would rather not give us something, please ask us first, because some fields decide whether a treatment can go ahead at all.

Information Why we need it What would go wrong without it
Full name To create and identify your client record, to match you to the correct treatment history, patch test record and consent form, to take payment, to issue receipts and vouchers, and to make sure the therapist is treating the right person with the right history. Two clients with similar records could be confused. A therapist could apply a tint to someone who has never been patch tested, or use a product a different client is allergic to.
Date of birth Three distinct reasons, all of them serious. (a) Age verification. Several treatments have a legal or policy minimum age, and for some of them treating a minor is a criminal offence, not just a policy breach. (b) Clinical relevance. Skin thickness, healing speed, hormonal status, collagen levels, bone density and circulation all change with age, and they change what settings, products and pressures are appropriate. (c) Record retention. Where a client is under 18, the period in which a legal claim can be brought does not start running until their eighteenth birthday, so we are required to keep their record considerably longer. Your date of birth tells us which retention rule applies. We could unlawfully treat a minor, apply adult laser or peel parameters to skin that cannot tolerate them, or destroy a record we were legally required to keep.
Age related identity check For age restricted treatments we may ask to see proof of age. We check it, note that it was checked, and record the type of document. We do not photocopy, scan or retain your passport or driving licence. We could not evidence that we complied with age restriction law.
Mobile number and email Appointment confirmations, reminders, changes and cancellations, patch test reminders, aftercare instructions, and urgent contact if we identify a product recall or safety issue affecting a treatment you have received. You would miss appointments, miss patch test windows, and could not be warned about a safety issue.
Home address or postcode Postal correspondence where you have asked for it, fraud checks on card payments, and identifying your nearest branch. Full address is optional for most clients and mandatory only for advanced aesthetics records. We could not verify card payments or send formal correspondence.
GP name and surgery Advanced aesthetics only So that, with your permission, we can seek medical clarification before a prescription only treatment, and so that emergency information is available if you have a significant adverse reaction. A prescriber could not safely assess you.
Emergency contact Advanced treatments and minors So we can reach someone quickly if you become unwell during a treatment. Nobody to call in an emergency.
4.1 Minimum ages we apply
Treatment Minimum age Basis
Anti wrinkle injections and dermal fillers for a cosmetic purpose 18. No exceptions, and parental consent does not change this. Botulinum Toxin and Cosmetic Fillers (Children) Act 2021. It is a criminal offence in England to administer these treatments, or even to book the appointment, for anyone under 18 for a cosmetic purpose. See GOV.UK guidance for businesses.
Sunbed use 18 Sunbeds (Regulation) Act 2010. We do not offer sunbeds.
Laser and light based hair removal, skin peels, body contouring, thread vein removal 18 Company policy, insurer requirement and clinical suitability.
Intimate waxing 18 Company policy and safeguarding.
Ear and nose piercing Under 16 requires a parent or legal guardian to attend and sign in person. We do not pierce a baby under 6 months old, or a baby who has not completed their routine vaccinations. Safeguarding, infection control and local authority registration.
General waxing, threading, facials, nails, brows and lashes Under 16 requires a parent or legal guardian to attend and sign in person. Company policy and safeguarding.
Correction to our previous policy

Our earlier page was headed Under 16 Clients but then referred to consent for under 18s. That was contradictory. The table above is the correct position: parental or guardian consent applies to under 16s for general treatments, and there is an absolute legal prohibition on injectables for under 18s.

5. Why we ask medical history questions, treatment by treatment

Health Information and Why We Ask For It

Health information is what data protection law calls special category data. It gets the highest level of protection, and we are not allowed to collect it simply because it might be interesting. We can only collect it where there is a genuine, specific and demonstrable need. The tables below set out that need for every treatment we offer, so you can see exactly why each question is on the form.

We ask these questions at your first visit and we re confirm them at every subsequent visit, because medication, pregnancy, skin condition and recent sun exposure all change.

5.1 Waxing (face, body and intimate)
What we ask Why we ask it
Isotretinoin (Roaccutane) now or in the last 6 to 12 months This medication thins the epidermis dramatically. Waxing over it can strip skin away and leave permanent scarring. This is an absolute contraindication.
Prescription retinoids, tretinoin, adapalene, glycolic, salicylic or AHA/BHA products used on the area Same risk of skin lifting and tearing, at lower severity. We need at least 5 to 7 days without them.
Antibiotics, particularly tetracyclines such as doxycycline These increase photosensitivity and skin fragility and raise the risk of reaction.
Blood thinning medication such as warfarin, apixaban, clopidogrel or regular aspirin Significantly higher bruising and bleeding risk, especially on intimate and underarm areas.
Diabetes Reduced skin sensitivity means you may not feel a burn, and impaired healing and circulation raise infection risk. Treatment may still proceed, but with adjusted temperature and technique.
Eczema, psoriasis, dermatitis, rosacea or any active skin condition on the area Wax can trigger a flare, break the skin barrier and cause infection.
Recent sunburn, sunbed use, fake tan or a holiday in the last 48 to 72 hours Heat sensitised skin lifts far more easily.
Varicose veins, thread veins, phlebitis or circulatory conditions Hot wax and the lifting action can worsen these.
Moles, warts, skin tags, cuts, bruises or recent scarring on the area We must work around them, not over them.
Recent laser, IPL, chemical peel or microdermabrasion on the area The skin is already compromised.
Pregnancy Raised skin sensitivity, altered pain threshold, and a higher bleeding tendency in intimate areas.
Known allergy to wax, resin, colophony, tea tree, lanolin or fragrance So we select an appropriate wax system for you.
Active cold sore or herpes simplex history (lip and facial waxing) Waxing can trigger and spread an outbreak.
Chemotherapy, radiotherapy or immunosuppressant medication Skin is fragile and infection risk is elevated. We normally require written GP clearance.
5.2 Eyebrow and eyelash tinting

This is the treatment with the highest risk of a severe allergic reaction anywhere in a salon, which is why our questions here are the strictest.

What we ask Why we ask it
Have you had a patch test with us in the last 6 months We will not tint without a valid patch test performed at least 24 to 48 hours before the appointment. This is not optional and it is not waivable, however experienced you are with tinting.
Any previous reaction to hair dye, eyelash tint, eyebrow tint, or a black henna temporary tattoo Black henna contains para phenylenediamine (PPD) and can permanently sensitise you. A previous reaction, even a mild one, means the next reaction can be far worse, including anaphylaxis.
Known allergy to PPD, PTD, ammonia, hydrogen peroxide or resorcinol These are the active sensitisers in tint.
Asthma, hay fever, eczema or a history of allergies generally Atopic clients have a materially higher reaction rate, so we may extend the patch test period.
Conjunctivitis, blepharitis, styes, dry eye or any current eye infection We cannot tint over an infected or inflamed eye.
Contact lenses They must be removed. Tint trapped under a lens can cause a corneal burn.
Laser eye surgery, cataract surgery or any eye surgery in the last 3 to 6 months Post surgical eyes are more vulnerable and often drier.
Glaucoma or prescribed eye drops Some drops alter tear film and increase the risk of migration.
Pregnancy or breastfeeding Hormonal change can alter both skin sensitivity and the way the tint develops.
Chemotherapy, radiotherapy or thyroid medication These change hair structure and skin reactivity.

The Chartered Trading Standards Institute has published dedicated consumer safety guidance on lash lifts and tints as part of its Cost of Beauty campaign. We follow it.

5.3 Facials, advanced skin peels and microdermabrasion
What we ask Why we ask it
Fitzpatrick skin type Deeper skin tones carry a materially higher risk of post inflammatory hyperpigmentation from acid and abrasion. This determines the strength, the acid family and the number of layers we can safely use.
Isotretinoin (Roaccutane) now or in the last 6 to 12 months Absolute contraindication to peels and abrasion. Risk of scarring.
Prescription retinoids or acid based homecare Must be stopped several days before, or the peel goes deeper than intended.
Active acne, rosacea, perioral dermatitis, eczema or psoriasis Changes which actives are safe and which will trigger a flare.
Cold sores or herpes simplex history Peels and heat are a well recognised trigger for a facial outbreak. Antiviral prophylaxis may be advised first.
History of keloid or hypertrophic scarring Higher scarring risk from any controlled injury to the skin.
Melasma, chloasma or pigmentation disorders Certain treatments will worsen these rather than improve them.
Pregnancy or breastfeeding Salicylic acid and certain actives are avoided.
Allergy to aspirin or salicylates, nuts, soy, dairy, fragrance, or latex Peel and mask formulations contain these. A nut allergy alone rules out several professional product lines.
Autoimmune conditions, lupus, immunosuppressants Impaired healing and photosensitivity.
Recent sun exposure, sunbeds or self tan Peels on recently exposed skin cause burns and pigment change.
Anti wrinkle injections or dermal filler in the last 2 to 4 weeks Massage and heat can displace product.
Photosensitising medication Including some antibiotics, diuretics, antidepressants, and St John’s Wort.
Metal implants, pacemaker, epilepsy Relevant to galvanic, high frequency, microcurrent and LED elements of a facial.
5.4 Manicure, pedicure and foot treatments
What we ask Why we ask it
Diabetes The single most important question in a pedicure. Reduced sensation means you may not feel a cut or a burn, and impaired circulation means a minor nick can become a serious infection or ulcer. We use a modified, non invasive protocol on diabetic feet and we do not use blades or aggressive hard skin removal.
Peripheral neuropathy, poor circulation, Raynaud’s, or a history of DVT Same reasoning. Affects water temperature, massage and pressure.
Fungal nail infection, athlete’s foot, verrucae or warts These are contagious. We may need to decline, use single use tooling, treat you at the end of the day, or refer you to a podiatrist or your GP first.
Psoriasis, eczema, or nail psoriasis Affects nail plate integrity and what can safely be filed or buffed.
Open cuts, blisters, ingrown nails, recent injury or recent foot surgery We must not work over broken skin.
Chemotherapy or radiotherapy in the last 6 months Nails become brittle and separate easily, and infection risk is high. GP clearance is normally required.
Pregnancy Certain reflex points and pressure techniques are avoided, and swelling changes fit and comfort.
Latex, acrylate or acetone allergy Determines gloves, products and removal method.
Blood thinning medication Higher bleeding risk from cuticle work.
5.5 Shellac, gel polish, builder gel, acrylic and extensions

There is one question here that matters more than clients usually realise.

What we ask Why we ask it
Have you ever had itching, redness, swelling, lifting, or a rash around the nail fold or on the eyelids or face after gel or acrylic nails This is the classic presentation of (meth)acrylate allergy, most commonly to HEMA. It matters far beyond your nails. Once you are sensitised to acrylates, the sensitivity is usually permanent and can cause you problems with dental composites, orthopaedic bone cement, some medical adhesives, diabetic sensors and insulin pumps for the rest of your life. We record this so that we never re expose you and so that you have a dated record to show a dentist or clinician.
Known HEMA or acrylate sensitivity We select HEMA free systems or decline.
Eczema or dermatitis on the hands A broken skin barrier dramatically increases sensitisation risk from uncured product.
Thyroid conditions, anaemia, or medication affecting the nail plate These change nail growth, adhesion and lifting behaviour.
Pregnancy Hormonal change frequently causes lifting and premature service breakdown, so we set expectations honestly rather than blame the product.
Photosensitising medication Because curing uses a UV or LED lamp on the skin of the hands.
Recent nail trauma, nail biting, or previous damage from removal Determines whether extensions are appropriate at all.
5.6 Lash extensions and lash lift or brow lamination
What we ask Why we ask it
Previous reaction to lash adhesive, or a known cyanoacrylate allergy Adhesive reactions can range from irritation to significant swelling of the eyelid.
Latex allergy Some adhesives and primers contain latex derivatives.
Blepharitis, dry eye, styes, chronic conjunctivitis, or ocular rosacea Extensions worsen lid margin disease and trap bacteria.
Recent eye surgery, LASIK, or cataract surgery We require a clear healing period.
Glaucoma or prescribed eye drops Drops break down adhesive and change the tear film.
Alopecia, trichotillomania, or existing lash loss Weight bearing on already compromised lashes causes further loss.
Asthma or respiratory sensitivity Adhesive vapour can be an irritant, so we adjust ventilation and technique.
Chemotherapy Lashes are fragile and regrowth is unpredictable.
Thioglycolate or perm solution sensitivity (lash lift and lamination) This is the active chemistry in a lift. A patch test is required.
Existing lash extensions (before a lift) A lift over extensions damages both.
Pregnancy Hormonal change affects how the lift takes, and lying flat for long periods may be uncomfortable in later pregnancy.
5.7 Laser hair removal, IPL and light based treatments

This is the treatment where the medical questions are least negotiable, because the energy is real and the damage from getting it wrong is permanent.

What we ask Why we ask it
Fitzpatrick skin type and natural hair colour Laser targets melanin. Skin type determines the wavelength, the fluence and the pulse duration we may use. Getting this wrong causes burns, blistering and permanent pigment loss or gain.
Sun exposure, sunbeds or self tan in the last 2 to 4 weeks Tanned skin holds more melanin and absorbs more energy. This is the most common cause of laser burns.
Photosensitising medication Including tetracycline and doxycycline antibiotics, retinoids, some antidepressants, some diuretics, some diabetes medication, amiodarone, and St John’s Wort. Any of these can turn a routine session into a burn.
Epilepsy Flashing light from IPL and some laser systems can trigger a seizure.
Pregnancy or breastfeeding Hormonal change alters hair growth cycles and pigmentation, and we do not treat in pregnancy.
PCOS, thyroid disorders, hormonal conditions, HRT, steroids These drive hair regrowth. Knowing about them lets us set realistic expectations rather than sell you a course that cannot deliver.
Tattoos, permanent makeup, semi permanent brows, or moles in the treatment area Pigment absorbs laser energy intensely, causing burns and ink damage. We must shield or avoid these areas.
History of cold sores Laser near the lip or bikini line can trigger an outbreak.
Keloid or hypertrophic scarring history Higher risk of abnormal healing.
Diabetes Slower healing and higher infection risk.
Vitiligo, psoriasis, active eczema or any active infection in the area Light energy can trigger a flare or a Koebner response.
Pacemaker, implanted metal, or a recent implant in the area Relevant to certain energy based devices.
Previous laser or IPL, and any reaction to it Tells us what has already been tolerated.
Recent waxing, plucking, threading or epilation These remove the follicle target, so the session would be wasted.
Immunosuppressants, chemotherapy, radiotherapy, or a history of skin cancer Normally requires written GP clearance before we proceed.

For laser we also record, and must keep, a test patch record, your consent, and the exact device, wavelength, fluence, pulse width, spot size and cooling settings used at every single session. This is a technical record of what was done to your body, and it is what allows any subsequent practitioner or clinician to understand your treatment history.

5.8 Advanced aesthetics: anti wrinkle injections, dermal fillers, body contouring, thread vein removal, fat dissolving

These treatments carry the highest clinical risk we offer, and the questions reflect that. Anti wrinkle injections use a prescription only medicine regulated by the Medicines and Healthcare products Regulatory Agency (MHRA), which means a qualified prescriber must assess you personally before any product is prescribed or administered.

What we ask Why we ask it
Full current medication list, including supplements Interactions, bleeding risk and healing are all affected.
Neuromuscular disorders: myasthenia gravis, Lambert Eaton, motor neurone disease Absolute contraindication to botulinum toxin.
Pregnancy, planning pregnancy, or breastfeeding Absolute contraindication.
Known allergy to botulinum toxin, human albumin, hyaluronic acid, lidocaine or any anaesthetic Risk of severe reaction.
Anticoagulants and antiplatelets Significant bruising and haematoma risk from injection.
Autoimmune or connective tissue disease Affects filler safety and healing.
Previous dermal filler, especially permanent or semi permanent filler, and where it was placed This is critical. Permanent filler placed years ago can react to new product, and it changes the risk of vascular occlusion. We need to know what is already in your face.
Recent or planned dental work Dental procedures can trigger delayed filler inflammation.
Recent vaccination or current infection Both are associated with delayed inflammatory filler reactions.
Cold sore history Injection around the mouth can trigger an outbreak. Antivirals may be prescribed first.
Keloid scarring, bleeding disorders, immunosuppression Healing and infection risk.
Body dysmorphic concerns and your expectations of the result An ethical practitioner must assess psychological suitability and decline where treatment is not in your interest.
GP details and consent to contact them So the prescriber can seek clarification where needed.
Pacemaker, metal implants, epilepsy, liver or kidney disease, high cholesterol, cancer history, coil or IUD (body contouring, cavitation, radiofrequency) Energy based body treatments are contraindicated in all of these. The coil question applies specifically to abdominal treatment.

For every injectable session we additionally record the product name, brand, batch number, expiry date, volume used, injection sites and the practitioner who administered it. This is a product traceability requirement. If a batch is ever recalled, this record is the only way we can contact everyone affected.

If you experience a side effect from a prescription medicine or a medical device, you can report it directly to the MHRA through the Yellow Card scheme at https://yellowcard.mhra.gov.uk/. We will also report on your behalf.

The UK Government is introducing a licensing scheme for non surgical cosmetic procedures in England under section 180 of the Health and Care Act 2022. We will comply with it in full as it comes into force.

5.9 Massage and body therapies
What we ask Why we ask it
Pregnancy and stage of pregnancy Determines position, pressure, oils and whether we treat at all in the first trimester.
DVT, blood clots, phlebitis or recent long haul travel Massage over a clot can dislodge it. This is life threatening.
High or low blood pressure, heart conditions Affects pressure, position and duration.
Recent surgery, fractures or injury Healing tissue must not be worked over.
Cancer, current or recent Requires oncology aware technique and usually GP clearance.
Osteoporosis Pressure must be significantly reduced.
Nut, seed or fragrance allergy Base oils are almost all nut or seed derived.
Epilepsy, diabetes, thyroid conditions Relevant to essential oil selection and heat.
5.10 Ear and nose piercing
What we ask Why we ask it
Age, and parent or guardian consent where under 16 Legal and safeguarding requirement. The guardian must attend and sign in person.
For babies: age in months and vaccination status We do not pierce a baby under 6 months old, or one who has not completed their routine vaccinations, because the infection risk is unacceptable.
Diabetes, immunosuppression, or a bleeding disorder Healing and infection risk.
Blood thinning medication Bleeding risk.
Keloid scarring history Piercings are a common keloid trigger.
Nickel or metal allergy Determines stud material.
Heart valve conditions, congenital heart disease, or previous endocarditis Piercing carries a bacteraemia risk and medical advice may be needed first.
Previous piercing problems, current infection, or moles or lesions at the site Determines whether we can proceed.
Eczema or psoriasis at the site Higher infection and healing risk.

Our piercing scope is limited by design. We offer nostril piercing only for the nose, and for ears we do not perform forward helix, helix, tragus, rook, snug or anti tragus piercings, because those require needle technique rather than the system we use.

6. Everything else we collect

6. Everything else we collect
Category Examples
Identity and contact Name, title, date of birth, mobile, email, address, emergency contact, preferred language, preferred branch and preferred therapist
Booking and transaction Appointment history, treatments taken, no shows and late cancellations, deposits, prices paid, payment method, last four digits and card type, gift voucher and package balances, loyalty points
Consultation and treatment Everything described in sections 3 to 5, plus patch test dates and outcomes, consent forms, aftercare given, products and shades used, machine settings, batch numbers, therapist notes and any adverse reaction
Images Before and after photographs, skin analysis images, and app profile photographs, only where you have given separate written consent
Communications Calls to the branch, WhatsApp messages, emails, contact form submissions, social media messages, reviews and complaints
Marketing Your subscription status, channel preferences, and whether you opened or clicked our messages
Technical IP address, device type, browser, operating system, referral source, pages viewed, app version and crash logs
CCTV Images recorded in public areas of our salons
Recruitment CVs, right to work evidence, references and interview notes for job applicants

7. Our lawful bases for using your information

7. Our lawful basis for using your data

We must have a lawful basis under Article 6 of the UK GDPR for everything we do with your data. Where the data is health information, we also need a separate condition under Article 9.

What we do Article 6 lawful basis Article 9 condition (health data)
Take and manage your booking, take payment, issue receipts Contract Not applicable
Screen you for safety before a treatment and record your consultation Contract, and legal obligation Explicit consent, Article 9(2)(a). You give it by signing the consultation form.
Keep treatment, patch test, batch and machine setting records after treatment Legitimate interests: client safety, continuity of care and defence of claims Establishment, exercise or defence of legal claims, Article 9(2)(f)
Meet health and safety, licensing and product traceability duties Legal obligation Article 9(2)(f), and where relevant public health, Article 9(2)(i)
Keep accounting, VAT and company records Legal obligation Not applicable
Send appointment confirmations, reminders, changes and aftercare Contract Not applicable
Issue a safety notice or product recall about a treatment you have had Legal obligation and vital interests Article 9(2)(f) and, in an emergency, Article 9(2)(c)
Send you marketing by email or SMS Consent, or the soft opt in for existing clients Not applicable
Use your photographs in marketing Consent, separately given and separately withdrawable Explicit consent
Operate CCTV Legitimate interests: crime prevention, staff and client safety Not applicable
Website analytics and non essential cookies Consent Not applicable
Handle a complaint, an insurance claim or legal proceedings Legitimate interests and legal obligation Article 9(2)(f)
Recruit and employ staff Contract, legal obligation and legitimate interests Employment law obligations, Article 9(2)(b)

Where we rely on legitimate interests, we have carried out a balancing assessment and concluded that our interest does not override your rights. You may ask us for a summary of that assessment.

Where we rely on consent, you can withdraw it at any time and we will stop. Withdrawing consent does not make anything we did before you withdrew it unlawful, and it does not oblige us to delete a treatment record that we are separately required to keep for safety, insurance or legal reasons.

7.1 A note on why we cannot simply delete a treatment record on request

This is a common misunderstanding, so we want to be transparent about it. The right to erasure is not absolute. Where we hold a treatment record because our insurer requires it, because a licensing regime requires it, or because it may be needed to establish or defend a legal claim within the limitation period, we are entitled and often obliged to retain it. In that situation we will tell you clearly which exemption applies, and we will restrict the record so it is used only for that narrow purpose and nothing else. Marketing data, app data and preference data will always be deleted on request.

8. Who we share your information with

8. Who we share your data with

We do not sell your data, we do not trade it, and we do not share it with advertisers.

Who we share your information with, why we share it, and the role each party plays under the UK GDPR.
Who Why Role
AppointGem Booking, client records, consultation forms, reminders and the client app Processor
Payment providers and card terminal operators Taking and reconciling payment. We never see or store your full card number. Independent controller
SMS, WhatsApp and email delivery providers Sending confirmations, reminders and consented marketing Processor
IT support, hosting and backup providers Keeping our systems running and secure Processor
Accountants, auditors and payroll Statutory accounts, VAT and payroll Processor or independent controller
Insurers, brokers, loss adjusters and solicitors Only where there is a claim, an incident or a legal dispute Independent controller
Regulators: ICO, HMRC, local authority environmental health and licensing, HSE, MHRA, CQC where applicable Where we are legally required or where a serious adverse event must be reported Independent controller
Police or other authorities Only in response to a valid legal request, a court order, or to prevent serious harm Independent controller
Website analytics and social platforms Only with your cookie consent Independent controller or joint controller

Every processor works under a written contract that meets Article 28 of the UK GDPR, restricts them to our documented instructions, requires appropriate security, and prohibits them from using your data for their own purposes.

8.1 Transfers outside the UK

Some of our suppliers, particularly messaging, analytics and cloud hosting providers, process data outside the UK. Where that happens we rely on UK adequacy regulations, or on the International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses, supported by a transfer risk assessment. You can ask us which safeguard applies to a specific supplier. Background guidance is published by the ICO at ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/international-transfers/.

9. How long we keep your information

Our previous policy said we delete client records after three years of inactivity. That was too short for treatment records and we have corrected it.

The reason is straightforward: a personal injury claim can generally be brought up to three years from the date the claimant first knew about the injury, not from the date of treatment, and where the client was a child that clock does not even start until their eighteenth birthday. Deleting a record at three years would leave both you and us without evidence.

What we hold, how long we hold it for, and the reason each period applies.
Record Retention period Why
Consultation, consent, patch test and treatment records: general beauty treatments 7 years after your last treatment Limitation periods for personal injury claims, plus insurer requirements
Consultation, consent and session records: laser, IPL, skin peels, injectables, body contouring and other advanced aesthetics 10 years after your last treatment Higher clinical risk, delayed onset reactions, product traceability
Any record relating to a client who was under 18 at the time of treatment Until their 25th birthday, or 7 years after the last treatment, whichever is later The limitation clock does not start until the client turns 18
Records relating to an adverse reaction, complaint, incident or claim 10 years from resolution, or longer if proceedings are live Defence of legal claims
Booking history, contact details and preferences where no treatment record applies 3 years from your last appointment, then deleted or anonymised No longer needed
Accounting, invoicing and VAT records 6 years from the end of the relevant accounting period HMRC and Companies Act requirements. See gov.uk/vat-record-keeping and gov.uk/running-a-limited-company/company-and-accounting-records
Marketing consents and preferences Until you withdraw, reviewed every 24 months of inactivity Evidence of consent under PECR
Photographs used with consent Until consent is withdrawn, then removed from all active channels Consent based
CCTV footage 30 days, unless retained for a specific incident Proportionality
Accident book and incident records 3 years from the date of the entry, longer where a substance hazardous to health is involved Health and safety law. See hse.gov.uk/riddor
Unsuccessful job applications 6 months Discrimination claim window
Employee records 6 years after employment ends Employment and tax law
Right to work checks Duration of employment plus 2 years Home Office requirement

When a retention period ends we securely delete electronic records and cross shred paper records.

10. Marketing, and how to stop it

We will only send you marketing by email or SMS if you have opted in, or if you are an existing client, we are marketing similar treatments, and you were given a clear chance to opt out when we took your details. That second route is the soft opt in permitted by PECR.
Every marketing message contains an unsubscribe link or a STOP instruction. You can also reply to any message, tell any branch, or email privacy@adorn-beauty.com. We will action it within 72 hours and there is no charge and no consequence to your treatment.
Withdrawing marketing consent will not stop transactional messages such as appointment confirmations, patch test reminders, aftercare instructions or safety notices, because those are part of delivering your treatment safely.
ICO guidance on direct marketing rules: https://ico.org.uk/for-organisations/direct-marketing-and-privacy-and-electronic-communications/

11. Photographs and before and after images

We frequently take clinical photographs, because for laser, peels, injectables and body treatments a visual baseline is the only objective way to assess progress.
• Clinical photographs form part of your treatment record and are retained under section 9. They are stored securely and are never published.
• Marketing photographs require a separate, specific, written consent that names the channels we may use. You are free to refuse and it will not affect your treatment or your price in any way.
• You may withdraw marketing photo consent at any time. We will remove the image from our website, our app and our own social media accounts promptly. Please be aware that we cannot always force removal of a reshare, a screenshot or a repost by a third party, and we will tell you honestly if that applies.
• We do not use identifiable client images in paid advertising without a further specific consent.

12. CCTV

prevention and detection of crime. Cameras are signed at the entrance. We do not place cameras in treatment rooms, changing areas or toilets. Footage is held for 30 days and is accessible only to authorised management. You have the right to request footage of yourself.

13. Cookies and our websites

Cookies and similar technologies

Correction to our previous policy. Our previous policy stated that we do not have access to third party cookies. That statement was inaccurate and has been corrected. Like most business websites we use third party services that set cookies.

Cookies we use, grouped by type
Type Purpose Consent needed
Strictly necessary Booking basket, session security, load balancing, remembering your cookie choice No
Functional Remembering your branch, language and preferences Yes
Analytics Understanding how the site is used so we can improve it Yes
Marketing and retargeting Measuring campaigns and showing relevant ads on third party platforms Yes
Your choice and how to change it

Under the Privacy and Electronic Communications Regulations (PECR) we must obtain your consent before setting anything other than strictly necessary cookies. Our cookie banner lets you accept all, reject all or choose by category, and rejecting is exactly as easy as accepting.

You can change your choice at any time via the cookie preferences link in our website footer, and you can clear or block cookies in your browser settings. Full detail is in our Cookie Policy.

If you would like to read the regulator’s own guidance, the Information Commissioner’s Office explains your rights around cookies at ico.org.uk.

14. The Adorn Beauty Client App

The app is available on Google Play and the Apple App Store. It may request the following permissions, all of which are optional and all of which you can change in your device settings at any time.

  • Google Play, for Android devices
  • Apple App Store, for iPhone and iPad
App permissions and what each one is used for
Permission Used for Optional
Location Finding your nearest branch Yes
Camera and photos Profile picture and, where you choose, uploading a consultation image Yes
Push notifications Appointment reminders and, if consented, offers Yes
Analytics and crash reporting Diagnosing faults and improving stability Yes

Declining any permission still leaves the app fully usable for booking. Deleting the app does not delete your salon records.

To delete your account and associated data, email privacy@adorn-beauty.com or use the in app account deletion option.

15. Automated decision making

We do not make any decision about you that produces a legal or similarly significant effect using automated processing alone, and we do not carry out profiling of that kind. Suitability for every treatment is decided by a qualified human therapist or prescriber. Our booking system may automatically flag that a patch test is missing or out of date, but a person always makes the final call.

16. Recruitment and staff

If you apply for a role with us, we process your CV, contact details, right to work evidence, qualifications, references and interview notes on the basis of taking steps to enter a contract and our legitimate interest in recruiting. Applications received through WhatsApp are handled in the same way. Unsuccessful applications are deleted after six months unless you ask us to keep them on file. Staff data is covered by a separate internal employee privacy notice.

17. How we protect your information

• Electronic records are held in access controlled systems with encryption in transit and at rest
• Paper consultation forms are held in locked storage and are digitised and destroyed where possible
• Access is role based and restricted to staff who need it to do their job
• Staff receive data protection and confidentiality training and are bound by contractual confidentiality
• Suppliers are contractually bound and reviewed
• We take regular encrypted backups and test restoration
• We maintain a documented breach response procedure

18. If something goes wrong

If a personal data breach occurs we will investigate immediately, contain it, and record it. Where it is likely to result in a risk to your rights and freedoms we will report it to the ICO within 72 hours, and where the risk is high we will contact you directly and without undue delay, explain what happened in plain language and tell you what to do.

19. Your rights

Your rights over your data

You have the following rights over the personal data we hold about you. You may use any of them at any time, and we will never treat you differently for doing so.

Your rights and what each one means
Right What it means
Access Get a copy of the personal data we hold about you, including your consultation and treatment records
Rectification Have inaccurate or incomplete information corrected
Erasure Have your data deleted, subject to the exemptions in section 7.1
Restriction Ask us to stop using your data while a dispute or an accuracy question is resolved
Objection Object to processing based on legitimate interests, and object to direct marketing absolutely and at any time
Portability Receive data you gave us in a machine readable format, or have it sent to another provider
Withdraw consent Withdraw any consent you have given, at any time, without penalty
Human review Not be subject to solely automated decisions with significant effects
Complain Complain to us and, independently, to the ICO
How to exercise a right
Ways to make a request
Method Detail
Email privacy@adorn-beauty.com
Post Data Protection, Adorn Beauty, [INSERT ADDRESS]
In branch Ask any branch manager, who will pass it to our data protection contact
Phone Call your branch on the number in section 21
Correction to our previous policy

Our earlier page said requests should be made by calling a branch, and that we would remove data within 30 days. We have corrected both points.

You may make a request by any method, including verbally, and you do not have to use a form or explain why. We will respond within one calendar month, which is the statutory deadline. We may extend by up to two further months for complex or numerous requests, and if we do we will tell you within the first month and explain why. There is no charge, unless a request is manifestly unfounded or excessive. We may ask you to confirm your identity before we release records.

If you are not happy with our response

Please tell us first so we can put it right. You also have the right to complain directly to the Information Commissioner’s Office, the UK’s independent data protection regulator, at any time.

20. Changes to this notice

We review this notice at least annually and whenever the law, our technology or our treatment menu changes. The current version is always published at https://adorn-beauty.com/privacy-policy/, is available in the Adorn Beauty Client App, and can be requested in print at any branch. Where a change materially affects how we use your data, we will tell you directly.

21. Contact us

21. Contact us

Data protection enquiries: privacy@adorn-beauty.com

Branch Address Phone
Adorn Beauty, Atria Watford 44A, Lower Mall, Atria Watford, Watford WD17 2UB 01923 252325
Adorn Hair & Beauty, Watford High Street 104 High Street, Watford WD17 2BW 01923 517325
Adorn Beauty, Uxbridge 9 to 11 Mercer Walk, The Pavilions Shopping Centre, Uxbridge UB8 1LJ 01895 813737
Adorn Beauty, High Wycombe 86 to 87 Eden Shopping Centre, High Wycombe HP11 2DQ 01494 535089
Adorn Beauty, Slough Unit 58 to 59, Queensmere Shopping Centre, Slough SL1 1LN 01753 534737
Adorn Beauty, Aylesbury 19 Hale Leys Shopping Centre, Aylesbury HP20 1ST 01296 415016
Adorn Beauty, Lakeside Arterial Road, Stifford, Lakeside RM20 2ZS 01708 607666
Adorn Beauty, Greenford 1275 Greenford Rd, Greenford UB6 0HY 020 8616 9210

Finally

If you do not agree with this Privacy Policy you should not submit your personal information on our website or in salons.