This Notice is designed to help you understand what kind of information we collect in connection with our services and how we will process and use this information. In the course of providing you with services we will collect and process information that is commonly known as personal data. This Notice describes how we collect, use, share, retain and safeguard personal data. This Notice sets out your individual rights; these rights include your right to know what data is held about you, how this data is processed and how you can place restrictions on the use of your data.
What is personal data?
Personal data includes an individual’s name, age/date of birth, gender and contact details e.g. address/email/telephone number. Personal data may contain information which is known as special categories of personal data. This may be information relating to and not limited to, an individual’s health, GP/other professional details, family, lifestyle or social circumstance, racial or ethnic origin, political opinions, religious or philosophical beliefs and data relating to sexual orientation. Personal information may include ’criminal offences’ if applicable. For the purposes of safeguarding and processing criminal conviction and offence data responsibly, this data is treated in the same manner as special categories of personal data, where we are legally required to comply with specific data processing requirements.
Personal data we collect
In order for us to provide assessment and treatment psychotherapy services, we will collect and process sensitive personal data about you. We will also collect your personal data where you request information about our services. We may also need to collect personal data relating to others in order to provide services. In most circumstances, you will provide us with this information. Where you disclose the personal data of others, you must ensure you are entitled to do so. You may provide us with personal data when completing online contact forms, when you contact us via the telephone, when writing to us directly or where we provide you with paper based forms for completion or we complete a form in conjunction with you.
We will share your personal data with your knowledge and consent with appropriate professionals if applicable and appropriate e.g. GP, psychiatrist, social care, medical insurance companies, solicitors and family members e.g. parents if under the age of 18 years. We will share information with other professionals e.g. GP and the police if you disclose any risk to yourself or others and this may be without your consent.
We may collect your personal data when you visit our website, where we may collect your unique online electronic identifier; this is commonly known as an IP address. We will also collect electronic personal data when you first visit our website where we will place a small text file that is commonly known as a cookie on your computer. Cookies are used to identify visitors and to simplify accessibility, and to monitor visitor behaviour when viewing website content, navigating our website.
Where we collect data directly from you, we are considered to be the controller of that data i.e. we are the data controller. Medical insurance companies also process your data, these parties are known as processors of your personal data. Where there are other parties involved in treatment they may also process your data in which circumstance we will be a joint data controller of your personal data. A data ‘controller’ means the individual or organisation which, alone or jointly with others, determines the purposes and means of the processing of personal data. A data ‘processor’ means the individual or organisation which processes personal data on behalf of the controller. As a provider of services, we will process the following categories of data: Personal data such as an individual’s name, address, date of birth, gender, contact details. Special categories of personal data such as health. If you object to the collection, sharing and use of your personal data we may be unable to provide you with our services.
Why do we need your personal data?
We will use your personal data for the performance of our contract with you, to offer consultation, signposting, assessment and treatment, to respond to any requests from you about services we provide and complaints. We also have a legitimate interest in good governance and auditing business operations.
We will retain your personal data at the end of our treatment contractual agreement for a further 7 years. This data will be retained for the protection of you and the service and is required by professional liability insurance Terms and Conditions.The records shall be kept for at least 7 years following the last occasion on which treatment was given. In the case of treatment to minors, it is advisable that records should be kept for at least 7 years after they reach the age of majority (18 years). Manual data is kept secure in a locked filing cabinet. Electronic data is held on our encrypted secure and GDPR complaint Google cloud based storage, on internal hard drive and external hard drives, all password protected. After this retention period data will be securely deleted.
Where you have requested information only or contacted us for details of our services, and where this does not progress to assessment and or treatment and we do not have any contracts with you, we will retain your personal data a period of 18 months. Where you make a complaint we will retain the data for 10 years. Where you or law enforcement agencies inform us about any active investigation or potential criminal prosecution, we will comply with legal requirements when retaining this data. The retaining of data is necessary where required for contractual, legal or regulatory purposes. Sometimes we may need to retain your data for longer, for example if we are defending ourselves in a legal dispute or as required by law or where evidence exists that a future dispute may occur.
Individuals are provided with legal rights governing the use of their personal data. These grant individuals the right to understand what personal data relating to them is held, for what purpose, how it is collected and used, with whom it is shared, where it is located, to object to its processing, to have the data corrected if inaccurate, to take copies of the data and to place restrictions on its processing. Individuals can also request the deletion of their personal data.
These rights are known as Individual Rights under the Data Protection Act 2018. The following list details these rights:
– The right to be informed about the personal data being processed;
– The right of access to your personal data;
– The right to object to the processing of your personal data;
– The right to restrict the processing of your personal data;
– The right to rectification of your personal data;
– The right to erasure of your personal data;
– The right to data portability (to receive an electronic copy of your personal data);
– Rights relating to automated decision making including profiling.
Individuals can exercise their Individual Rights at any time. As mandated by law we will not charge a fee to process these requests, however if your request is considered to be repetitive, wholly unfounded and/or excessive, we are entitled to charge a reasonable administration fee. In exercising your Individual Rights, you should understand that in some situations we may be unable to fully meet your request, for example if you make a request for us to delete all your personal data, we may be required to retain some data for regulatory and other statutory purposes. If being treated under a insurance claim we may be restricted by the instructing party who we can provide information to even with your consent. 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.
Protecting your data
We will take all appropriate technical and organisational steps to protect the confidentiality, integrity, availability and authenticity of your data, including when sharing your data within our group of associates and authorised third parties. Gmail is our encrypted email service. Wherever possible we use pseudonymisation and encryption when communicating with you and authorised third parties. Mobile phones hold your telephone number but are anonymised and a secure PIN protects the phone and information.We remove details from the phone when there is no longer a reason to retain it. If lost the phone can be remotely erased. Within clinical supervision we use initials only when discussing clinical content. We will share your information in an emergency that would protect your vital interests. If there is a breach we inform you and the ICO within 72 hours.
If you are dissatisfied with any aspect of the way in which we process your personal data please contact us. You also 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, by live chat or by calling their helpline on 0303 123 1113.
If you have any questions regarding this Notice, the use of your data and your Individual Rights please contact us directly.