REALFOCUS THERAPY AND BROADCAST MEDIA SERVICES - Data Privacy Notice
Individuals have the right to be informed about the collection and use of their personal data. This is a key requirement under The General Data Protection Regulation (GDPR).
What is the GDPR? The General Data Protection Regulation (GDPR) is a new, Europe-wide law that replaces the Data Protection Act 1998 in the UK. It is part of the wider package of reform to the data protection landscape that includes the Data Protection Bill. The GDPR sets out requirements for how organisations will need to handle personal data from 25 May 2018.
As a service provider I must provide individuals with information including: my purposes for processing their personal data, your retention periods for that personal data, and who it will be shared with. This is called ‘privacy information’.
1. Important Notice
This privacy notice outlines the commitment to keeping your data safe and secure and explains how I collect and process your data.
1.1 This is the Privacy Notice for RealFocus Therapy and Broadcast Media Services, which is the trading used by Denise Freeman. Denise Freeman is a sole trader providing counselling and psychotherapy to individuals and couples and psychological support services to the broadcast media industry.
1.2 How to contact me. The contact details for Denise Freeman and RealFocus Therapy and Broadcast Media Services, are: Website: www.realfocustherpay.co.uk Email: firstname.lastname@example.org and Tel: 07379 44 40 40
1.3 I am registered with the Information Commissioner’s Office (ICO) as the sole Data Controller for RealFocus Therapy and Broadcast Media Services. This means I decide how your personal data is processed and for what purposes. and sets out how I collect and process your personal data. This Privacy Notice also provides certain information that is legally required and lists your rights in relation to your personal data.
1.4 This Privacy Notice relates to personal data that identifies “you” meaning my clients, suppliers or individuals who browse my website and other individuals outside of this, with whom I may interact.
1.5 I refer to this information throughout this Privacy Notice as “personal data” and paragraph 2 sets out further detail of what this includes.
1.6 Please read this Privacy Notice to understand how I may use your personal data.
1.7 This Privacy Notice may vary from time to time so please check it regularly. This original version was published on [3rd] September 2018.
2. What information does the GDPR apply to? The GDPR applies to ‘personal data’, which
means any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier.
2.1 What is personal data? Personal data’ means information that identifies a living person. This could include a person’s name, address, phone number or email address. ‘Personal data’ also means any personal information you provide to me. This may be by phone, text message (SMS), email, social media, letter and other correspondence, and in person. It can include IP addresses and other technical identifying information.
3. .How do I collect personal data? Personal data may be collected directly from you during our interactions together or those associated with the business. For example, during an assessment, during a therapy session and after in the writing of brief factual notes, when you contact me via a web form or by email, phone or via social media with an enquiry, when you pay for any of the services via the online payment platform.
3.1 The categories of personal data about you that I may collect are:
3.2 Individual Data which includes personal data you provide in person, via my website, app or by telephone, including personal and contact details (such as your first name, middle name, last name, username or similar identifier, title, date of birth, gender, billing address, delivery address, email address and telephone numbers) you supply when booking a session, using the Acuity Booking System and when you me to make a general enquiry.
3.3 Account and Profile Data which includes personal data which relates to your account or profile on my website or Acuity app, such as your username and password, bookings made by you, your interests, preferences, feedback and survey responses;
3.4 Advertising and Marketing Data which includes personal data which relates to your marketing preferences, such as information about your preferences in receiving marketing materials from me and your communication preferences
3.5 Sales Data which includes personal data which relates to the transactions you have conducted with me, such as details about payments to and from you
3.6 Economic and Financial Data which includes personal data which relates to your finances, such as your bank account and payment card details (requested when booking and paying for a therapy session online via Acuity).
3.7 Advertising and Market Research Data which includes personal data which is gathered for the purposes of market research.
3.8 Information Technology Data which includes personal data which relates to your use of our website and App, such as your internet protocol (IP) address, login data, traffic data, weblogs and other communication data, browser type and version, time zone setting and location including geolocation, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access my website
3.9 Health Data which includes personal data which is gathered for assessment purposes including any information you provide about other medical conditions during the assessment process
3.10 I may also create Personal Data about you, for example, if you contact me by telephone to arrange a consultation or in relation to services or goods, then I may make a written record of key details of the conversation so that I can take steps to address the enquiry.
3.11 I may also obtain and use certain aggregated data such as statistical or demographic data for any purpose (“Aggregated Data”). Aggregated Data may be derived from your personal data but does not directly or indirectly reveal your identity. For example, I may aggregate some of your Information Technology Data operational data to calculate the percentage of users accessing a specific feature on the website. However, if I re-combine or re-connect Aggregated Data with your personal data so that it can directly or indirectly identify you, I treat the combined data as personal data which will be used in accordance with this Privacy Notice.
3.12 In addition, I may obtain certain special categories of your data (“Special Categories of Data”), and this Privacy Notice specifically sets out how I may process these types of personal data. The Special Categories of Data are: (i) personal data revealing racial or ethnic origin, religious or philosophical beliefs, and (ii) the processing of genetic data, biometric data for the purposes of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. I may also collect information about criminal convictions and offences.
4. What personal data do I retain? Paper: Signed contracts between the client and myself, signed GDPR agreement, brief session notes, outcome measures and feedback forms. Correspondence: via the following means – online via the web contact form, electronically, via email, SMS via text messages, WhatsApp, Facebook, Twitter and Instagram. Telephone: I hold your first name and telephone number in my contacts. This may also be stored as an SMS should we communicate via text messages. Online Booking and Payment: when you make a online payment you may chose to register for a account which stores your personal data (Inc payment details).
5. The retention periods of your personal data. I will only keep your personal information for as long as it is necessary to provide the services you have requested, or for essential purposes such as, complying with legal obligations, resolving disputes, investigating disciplinary matters and enforcing our agreements. Were appropriate I will erase electronic copies of your information and correspondence. I may hold onto your written information for up to seven years past the end of our working together. After this time has passed, this information will be disposed of confidentially. I keep the length of time that I hold your personal data under annual review. My records are stored safely away from the practice premises. The only other person who is aware of where this information is, is my Therapeutic Executor. This is so that if I die whilst you are still in therapy, you will be notified.
6. Who else has may have access to your data?
General Practitioners (GP): During an assessment (to ascertain your suitability into the service or prior to participating in a television programme). I will discuss your current mental and physical health. I will ask questions to help identify if your health is impacting on your ability to cope with everyday situations. I will ask for contact details of you GP and medical practice and any professional involved in your care. The information you provide during your assessment may be shared with your GP and other professionals. Your consent for this will be sought prior to the assessment, along with the rationale before any disclosure.
6.1 British Association for Counselling and Psychotherapy (BACP): I am required by the BACP to write brief factual notes after each therapy sessions. Within these notes each individual is kept anonymous and no personal data is included.
6.2 Clinical Supervisor: As a BACP requirement I have monthly clinical supervision with a BACP registered supervisor this allows me the opportunity to participated monthly case management. Ensuring that I am adhering to the BACP Ethical framework and working in the best interest of the client. Any client discussed during supervision is anonymised.
6.3 Relevant Authorities: if you the individual disclose any information that pertains to harm to yourself or another person and or organisation (e.g. terrorism, drug money laundering), then the law may require that I inform the relevant authority without seeking your permission. In such a situation, the law may require that I share your personal information without your knowledge.
6.4 I may also disclose the personal data you provide to:
6.5 HMRC, legal and other regulatory authorities, including those who request your personal data or to report any potential or actual breach of applicable law or regulation;
6.6 external professional advisers such as clinical supervisor, accountants, auditors, bankers, insurers and lawyers;
6.7 law enforcement agencies, courts or other relevant party, to the extent necessary for the establishment, exercise or defence of legal rights;
6.8 third parties where necessary for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties;
7. How do I use the information you provide? The data collected enables me to provide you with information about my work and evaluate my services by using any feedback you provide.
7.1 RealFocus Therapy complies with its obligations under the Data Protection Act 2018 and the GDPR: by keeping personal data up to date by storing and destroying it securely, by not collecting or retaining excessive amounts of data , by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.
7.2 personal data will not be shared with third parties without your explicit consent. You have the right to object to how I process your data. If you would like to exercise this right, please contact me using the information below. Email: email@example.com Tel: 07379 44 40 40
8. Your marketing communication preferences. I will only send you marketing communications with your explicit consent. If you give permission for me to contact you, I will ensure that there is a clear way to opt out of receiving these communications. I will endeavour to promptly update your contact details and preferences at your request.
10. Your rights and personal data. Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data: the right to request a copy of your personal data which RealFocus Therapy holds about you, the right to request that RealFocus Therapy corrects any personal data if it is found to be inaccurate or out of date; the right to request your personal data is erased where it is no longer necessary for RealFocus Therapy to retain such data, the right to withdraw your consent to the processing at any time, the right to request that the data controller provide the data subject with their personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), the right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing, the right to object to the processing of personal data, the right to lodge a complaint with the Information Commissioners Office (www.ico.org.uk)
11. Accessing the information held about you. If you would like to see the information I hold about you you can make a request in writing, by either email, to firstname.lastname@example.org. I am committed to responding to any request to access your information promptly. We are also committed to making any corrections or updates as quickly as possible.
12. Changing your preferences about how I communicate with you. Simply contact me by phone: 07379 44 40 40, Email: email@example.com or via the webform on my website: www.realfocustherpay.co.uk if you would like to change your preferences about how I contact you.
13. Asking for your data to be deleted. You can request that we stop using your personal data and delete it. In order to do this simply contact us by phone: 07379 44 40 40, Email: firstname.lastname@example.org or via the web form on my website: www.realfocustherpay.co.uk I may need to keep a minimum amount of information to ensure that we do not contact you again in the future.
14. Contact Details. I take my responsibilities around managing your personal data seriously. If you have a query, complaint or wish to exercise your rights in relation to the data we hold about you, in the first instance please contact Denise Freeman on 07379 44 40 40, or Email: email@example.com or via the web form on my website: www.realfocustherpay.co.uk You can contact the Information Commissioners Office on 03031231113 or via their website: https or in writing Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.