Your privacy is very important to us and you can be confident that your personal information will be kept safe and secure and will only be used for the purpose it was given to us. We adhere to current data protection legislation, including the General Data Protection Regulation (EU/2016/679) (the GDPR), the Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2003. This privacy notice tells you what we will do with your personal information from initial point of contact through to after your therapy has ended, including:
• Why we are able to process your information and what purpose we are processing it for
• Whether you have to provide it to us
• How long we store it for
• Whether there are other recipients of your personal information
• Whether we intend to transfer it to another country
• Whether we do automated decision-making or profiling, and
• Your data protection rights.
We are happy to discuss any questions you might have about our data protection policy and you can contact us via email@example.com
‘Data controller’ is the term used to describe the person/ organisation that collects and stores and has responsibility for people’s personal data. In this instance, the data controller is Dr Chris MacGregor for London City Therapy Ltd. Associate psychologists and associate therapists taking on referrals with London City Therapy Ltd will be additional data controllers for the clients they work with directly and may have access to more data than Dr MacGregor and/or London City Therapy Clinic due to the confidential nature of their therapy work with a specific client. In such cases, associates will be the primary data controller for those clients. All our associates are registered with the ICO.
We are registered with the Information Commissioner’s Office, ICO:00310017322.
Lawful basis for holding and using your personal information
The GDPR states that we must have a lawful basis for processing your personal data. There are different lawful bases depending on the stage at which we are processing your data. We have explained these below:
If you have had therapy with us and it has now ended, we will use legitimate interest as our lawful basis for holding and using your personal information.
If you are currently having therapy or if you are in contact with us to consider therapy, we will process your personal data where it is necessary for the performance of our contract.
The GDPR also makes sure that we look after any sensitive personal information that you may disclose to us appropriately. This type of information is called ‘special category personal information’. The lawful basis for us processing any special categories of personal information is that it is for provision of health treatment (in this case therapy) and necessary for a contract with a health professional (in this case, a contract between your therapist and you).
How we use your information
When you contact us with an enquiry about therapy services we will collect information to help us satisfy your enquiry. This will include your name, email, phone number, age, gender, current difficulties, drug and alcohol use, risk of self-harm and suicide, availability, and payment method. Alternatively, your GP or other health professional may send us your details when making a referral or a parent or trusted individual may give us your details when making an enquiry on your behalf. If you decide not to proceed we will ensure all your personal data is deleted within 6 months. If you would like us to delete this information sooner, just let us know.
While you are accessing therapy.
Rest assured that everything you discuss with us is confidential. That confidentiality will only be broken if the therapist believes you are at risk of harming yourself or someone else. We will always try to speak to you about this first, unless there are safeguarding issues that prevent this.
After therapy has ended.
Once therapy has ended your records will be kept for 7 years from the end of the contract and then securely destroyed. If you want this information deleted sooner, please contact us.
Third party recipients of personal data.
We sometimes share personal data with third parties, for example, where we have contracted with a supplier to carry out specific tasks. In such cases we have carefully selected which partners we work with. We take great care to ensure that we have a contract with the third party that states what they are allowed to do with the data we share with them. We ensure that they do not use your information in any way other than the task for which they have been contracted.
We try to be as open as we can be in terms of giving people access to their personal information. You have a right to ask us to delete your personal information, to limit how we use your personal information, or to stop processing your personal information. You also have a right to ask for a copy of any information that we hold about you and to object to the use of your personal data in some circumstances. You can read more about your rights at ico.org.uk/your-data-matters.
If we do hold information about you we will:
• give you a description of it and where it came from;
• tell you why we are holding it, tell you how long we will store your data and how we made this decision;
• tell you who it could be disclosed to;
• let you have a copy of the information in an intelligible form.
You can also ask us at any time to correct any mistakes there may be in the personal information we hold about you. To make a request for any personal information we may hold about you, please put the request in writing addressing it to firstname.lastname@example.org. If you have any complaint about how we handle your personal data please do not hesitate to get in touch with us by writing or emailing to the contact details given above. We would welcome any suggestions for improving our data protection procedures. If you want to make a formal complaint about the way we have processed your personal information you can contact the ICO which is the statutory body that oversees data protection law in the UK. For more information go to ico.org.uk/make-a-complaint.