The Psychological Therapy Centre Privacy Policy
What data we collect about you Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you such as:
Personally identifiable information such as first name, last name, username or similar identifier, marital status, title, date of birth and gender, occupation.
Contact Data such as email address, home address and telephone numbers.
We also collect Special Categories of Personal Data about you (this includes details about your health) as this is necessary for us to provide you with the best service. This may include consent to communicate with your GP. We do not collect any other special category including information about criminal convictions and offences.
How we collect data?
Personal information about you may be collected when you correspond with us via phone, email, filling in forms via our website or otherwise.
How we process or share personal data:
We will use your personal data to fulfil your instructions and requirements and we will ask only for data that is adequate, relevant and not excessive for those purposes. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered intowith you. Note that, in this context, a contract does not have to be a formal signeddocument, or even written down, as long as there is an agreement which meets therequirements of contract law. Broadly speaking, this refers to your request to accesstherapy services via our service and need to be contacted as part of this service that yourequire, for which there is a fee payable.
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.
Where we need to comply with a legal or regulatory obligation.
Consultation -All our therapists have regular supervision / consultations with othertherapists qualified in this process. The process is for the regulation of their own practice(rather than seeking instruction on working with you). In order to protect your privacy,they do not relay information that would identify you personally nor professionally.
Emergencies. If you are at risk of harm, I may share your contact information with anemergency healthcare service such as a Mental Health Crisis Team or GP (if you consent).If I have become aware of your intent to cause harm to another person/organisation (e.g.terrorism), the law may require that I inform an authority without seeking yourpermission. In such a situation, the law may require that I share your personalinformation without your knowledge.
How secure is my data?
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees / associates, agents, contractors and other third parties who have a business need 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.
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 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 requirements. We keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for 7 years after they cease being customers, for tax purposes. In some circumstances you can ask us to delete or amend your data see below for further information. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Can I access or amend my data?
Upon receipt of your written request and enough information to permit us to identify your personal data, we will disclose to you the personal data we hold about you, for which we may make a charge up to the maximum as allowed by applicable law. We will also correct, amend or delete any personal data that is inaccurate and notify any third party recipients of the necessary changes. In some cases we may be able to delete data at your request. Access requests should be made in writing to Christina Palmer, Data Controller, 189 Heene Road, Worthing, West Sussex, BN11 4NN. We try to respond to all legitimate requests within one month. Occasionally it may 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.
Glossary
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us. Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
YOUR LEGAL RIGHTS
You have the right to: Request access to your personal data (commonly known as a "data 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. 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. Request correction of the personal data 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 new data you provide to us. Request erasure of your personal data. 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. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 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. Withdraw consent at any time where we are relying on consent to process your personal 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.