Privacy Notice for Clients
Therapist- Catherine McNamara- White, BABCP Accredited Cognitive Behavioural Therapy (CBT) psychotherapist.
Purpose of this Notice. To inform you about our processing of personal data as a controller, in accordance with the ‘transparency’ requirement of Article 13 GDPR. It is intended to inform all those who I work with in a professional capacity.
- Privacy laws. The processing of your personal data is governed by the General Data Protection Regulations (GDPR), enacted in the UK by the Data Protection Act 2018.
- The capacities in which we process data in providing you with our services, we act as a controller of personal data (as defined by Article 4(7) GDPR) with respect to any processing for which we determine the purpose and means.
- The types of personal data we collect.
The personal data we use may include:
• Your name, address and contact details, including email address and home and mobile telephone numbers. If you provide these details, we may use them to contact you unless you ask us not to. This could include emails, text or voicemail messages.
• Date of birth.
• Information about your medical history and current medical and health conditions.
• Your General Practitioner’s contact details.
• Information about your lifestyle, including nutritional and eating behaviours.
• The terms and conditions of your contract with us for the provision of our services.
• Emergency contact details
How we collect the personal data.
We may collect this information in a variety of ways. For example, data might be collected directly from you through:
• online web forms completed by you,
• correspondence with you, either verbal, written or electronic.
• Online communication platforms such as Zoom;
• The ‘Recovery Record’ app, or;
• through consultations with you.
We may also collect data from other medical or counselling professionals where they have referred you to us, and you have consented for that data to be shared with us.
Providing your personal data.
We will tell you if providing some personal data is optional, including if we ask for your consent to process it. In all other cases, we need you to provide your personal data so we can provide care and treatment to you.
5. What we use your personal data for
a) Provision of service
• To support the provision of our counselling and nutritional support;
• To decide how best to provide those services to you;
• As necessary to support the contract with you and to allow us to receive full payment for those services;
• To take steps at your request during the course of our relationship;
• To keep your records up to date.
b) Business purposes
• As necessary for our own legitimate interests or those of other persons and organisations;
• For good governance, accounting, and managing and auditing our business operations both internally and by third parties;
• To monitor emails, calls, other communications;
c) To comply with a legal obligation:
• When you exercise your rights under data protection law;
• For compliance with legal and regulatory requirements;
For the establishment and defence of legal rights;
• For activities relating to the prevention, detection and investigation of crime;
• To verify your identity, make credit fraud prevention and anti-money laundering checks; and
• To investigate complaints, legal claims and data protection or clinical incidents.
6. The legal basis for processing
In providing you counselling and nutritional support, we will process your personal data under Article 6 (1)b of the General Data Protection Regulations, on the legal basis that processing is necessary for the performance of a contract for the provision of our services, or in order to take steps at your request prior to entering into a contract. In addition, we may process your personal data on the following legal bases;
• Legal obligation: the processing is necessary for compliance with a legal obligation Article 6 (1)(c)
• Vital interests: the processing is necessary to protect someone’s life. Article 6 (1) (d)
• Public interest: the processing is necessary to perform a task in the public interest. Article 6 (e) • Legitimate interests: the processing is necessary for an organisation’s legitimate interests or the legitimate interests of a third-party Article 6 (1) (f)
When processing special category (health) data, we do so in accordance with Article 9 (2)(h) GDPR for the purpose of providing health care. In addition, we may process your special category data on the following legal bases;
• Vital interests of the Data Subject – Article 9 (2) (c) 7. Sharing of your personal data Subject to applicable data protection laws we may share your personal data with:
• Subject to your consent, your General Practitioner (GP) where we believe this will enhance the quality of your care;
• Subject to your consent, other professionals providing nutritional therapy should we refer you to them;
• Our legal and other professional advisors;
• Professional bodies governing the provision of our counselling and psychotherapy services;
• Courts, to comply with legal requirements, and for the administration of justice;
• In an emergency or to otherwise protect your vital interests;
• To protect the security or integrity of our business operations and other patients;
• When we restructure or buy or sell our business or its assets or have a merger or reorganisation; • Payment systems and providers; and
• Anyone other party where we have your consent or as required by law.
8. Use of your personal data for marketing purposes
With your consent, and subject to your communications preferences, we may use your contact details to send you communications containing information which we think may be of interest to you. We will not share your data with any external party for marketing purposes. You are free at any time to change your mind and withdraw your consent by contacting us using the details given at the top of this Notice. This will not affect the services we provide to you.
9. How long do we keep your data?
Information will be kept for seven years after the last consultation. Information may be held for longer periods where any of the following apply:
• Retention in case of queries. We will retain your personal data as long as necessary to deal with any outstanding queries you may have;
• Retention in case of claims. We will retain your personal data for as long as you might legally bring claims against us or until the completion of any such claim; and
• Retention in accordance with legal and regulatory requirements. We will retain your personal data after you have received nutritional therapy and eating disorder coaching based on legal and regulatory requirements and obligations pertaining at any given time.
10. Your rights under applicable data protection law
Your rights are, where applicable:
• The right to be informed about processing of your personal data;
• The right to have your personal data corrected if it is inaccurate and to have incomplete personal data completed;
• The right to object to processing of your personal data;
• The right to restrict processing of your personal data;
• The right to have your personal data erased (the “right to be forgotten”);
• The right to request access to your personal data and information about how we process it;
• The right to move, copy or transfer your personal data (“data portability”); and
• Rights in relation to automated decision-making including profiling.
You may exercise these rights by contacting us using the details given at the top of this Notice. You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
11. How to complain
If you have any concerns about our use of your personal information, you can make a complaint to us using the details given at the top of this Notice. You can also complain to the Information Commissioner’s Office if you are unhappy with how we have used your data.
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113 ICO
website: https://www.ico.org.uk
If you have any questions about this Privacy Notice, please contact catherinewhite.cbt@gmail.com