Client Privacy Policy
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.
When we use your personal data we are regulated under the General Data Protection Regulation (GDPR) which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal data for the purposes of the GDPR. Our use of your personal data is subject to your instructions, the GDPR, other relevant UK and EU legislation and our professional duty of confidentiality.
Key terms
It would be helpful to start by explaining some key terms used in this policy:
We, us, our
Justin Clark, trading as Therapy Nottingham
Personal data
Any information relating to an identified or identifiable individual
Special category personal data
Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership
Genetic and biometric data
Data concerning health, mental health, sex life or sexual orientation
Personal data we collect about you
The lists below sets out the personal data we will or may collect in the course of providing services to you.
Personal data we will collect
Your name, address, and telephone number
Electronic contact details, eg your email address and mobile phone number
Information relating to the matter in which you are seeking our advice or support
Information relating to your physical and mental health, eg assessments, history, diagnoses, and medication
Information about your use of our IT, communication and other systems, and other monitoring information, eg if using our secure online assessments
Personal data we may collect depending on the nature of our work together
Your racial or ethnic origin, gender and sexual orientation, religious or similar beliefs, eg if you are referred for or accessing psychotherapy
Your medical records and GP details, eg if you are accessing psychotherapy and onward referral or collaboration is appropriate
Information to enable us to check and verify your identity, eg your date of birth or passport details
This personal data is required to enable us to provide our service to you. If you do not provide personal data we ask for, it may delay or prevent us from providing services to you.
How your personal data is collected
We collect most of this information from you, direct or via secure online forms. However, we may also collect information:
directly from a third party, eg:
Employers, in the case of workplace referrals;
Employee Assistance Providers, in the case of them referring you to us;
from a third party with your consent, eg:
consultants and other professionals we may engage in relation to your work with us;
your employer;
your doctors, medical and occupational health professionals;
via our website—we use cookies on our website
via our information technology (IT) systems, eg:
case management, document management, financial management, and time recording systems;
automated monitoring of our websites and other technical systems, such as communications systems, email and instant messaging systems;
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason for doing so, eg:
to comply with our legal and regulatory obligations;
for the performance of our contract with you or to take steps at your request before entering into a contract;
for our legitimate interests or those of a third party;
or where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The list below explains what we use (process) your personal data for and our reasons for doing so:
To provide therapeutic support services to you
For the performance of our contract with you or to take steps at your request before entering into a contract
Conducting checks to identify our clients and verify their identity. Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, eg under health and safety regulation or rules issued by our professional regulator
To comply with our legal and regulatory obligations
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies
To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, eg policies covering security and internet use
For our legitimate interests or those of a third party, ie to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training and quality control
For our legitimate interests or those of a third party, ie to be as efficient as we can so we can delivery the best service for you.
Ensuring the confidentiality of commercially sensitive information
For our legitimate interests or those of a third party, ie to protect our intellectual property and other commercially valuable information. To comply with our legal and regulatory obligations.
Statistical analysis to help us manage our practice, eg in relation to client base, work type or other efficiency measures
For our legitimate interests or those of a third party, ie to be as efficient as we can so we can delivery the best service for you.
Preventing unauthorised access and modifications to systems
For our legitimate interests or those of a third party, ie to prevent and detect criminal activity that could be damaging for us and for you. To comply with our legal and regulatory obligations.
Updating and enhancing client records
For the performance of our contract with you or to take steps at your request before entering into a contract. To comply with our legal and regulatory obligations. For our legitimate interests or those of a third party, eg making sure that we can keep in touch with our clients about existing and new services.
Statutory returns
To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments
To comply with our legal and regulatory obligations. For our legitimate interests or those of a third party, eg to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you.
Marketing our services to existing and former clients, third parties who have previously expressed an interest in our services, and third parties with whom we have had no previous dealings.
For our legitimate interests or those of a third party, ie to promote our business to existing and former clients
External audits and quality checks, eg for BACP accreditation and the audit of our accounts
For our legitimate interests or a those of a third party, ie to maintain our accreditations so we can demonstrate we operate at the highest standards. To comply with our legal and regulatory obligations.
The above list does not apply to special category personal data, which we will only process with your explicit consent.
Promotional communications
We may use your personal data to send you updates (by email, text message, telephone or post) about wellbeing developments that might be of interest to you and/or information about our services, including exclusive offers, promotions or new services.
We have a legitimate interest in processing your personal data for promotional purposes (see above “How and why we use your personal data”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal data with the utmost respect and never share it with other organisations for marketing purposes.
You have the right to opt out of receiving promotional communications at any time by:
contacting us by email at hello@therapynottingham.co.uk
telephone: 0115 7722132
using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts
We may ask you to confirm or update your marketing preferences if you engage us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
Who we share your personal data with
We routinely share personal data with:
The Clinical Lead within Therapy Nottingham;
Associate psychotherapists working as part of the Therapy Nottingham team;
professional advisers who we instruct on your behalf or refer you to, eg medical professionals;
external service suppliers, representatives and agents that we use to make our business more efficient, eg therapeutic supervisors, case management providers, typing services, marketing agencies, document collation or analysis suppliers, accountants, financial services and administrative support providers.
We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers relating to ensure they can only use your personal data to provide services to us and to you.
We may share information relating to you and our work with you for the purposes of writing and publishing articles, case studies, research papers, and books. In such cases, steps will be taken to anonymise this information as far as practicable, unless we seek your explicit consent not to.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal data with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
We will not share your personal data with any other third party.
Where your personal data is held
Information may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see “Who we share your personal data with”).
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal data when this occurs, see below: “Transferring your personal data out of the EEA”.
How long your personal data will be kept
We will keep your personal data after we have finished advising or working with you. We will do so for one of these reasons:
to respond to any questions, complaints or claims made by you or on your behalf;
to show that we treated you fairly;
to keep records required by law.
We will not retain your data for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of data.
Transferring your personal data out of the EEA
To deliver services to you, it is sometimes necessary for us to share your personal data outside the European Economic Area (EEA), eg:
with your and our service providers located outside the EEA;
if you are based outside the EEA;
where there is an international dimension to the matter in which we are working with you.
These transfers are subject to special rules under European and UK data protection law.
If you would like further information please contact us (see “How to contact us” below).
Your rights
You have the following rights, which you can exercise free of charge:
Access
The right to be provided with a copy of your personal data
Rectification
The right to require us to correct any mistakes in your personal data
To be forgotten
The right to require us to delete your personal data—in certain situations
Restriction of processing
The right to require us to restrict processing of your personal data—in certain circumstances, eg if you contest the accuracy of the data
Data portability
The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object
The right to object:
at any time to your personal data being processed for direct marketing (including profiling);
in certain other situations to our continued processing of your personal data, eg processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual decision-making
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
email, call or write to us —see below: ‘How to contact us’; and
let us have enough information to identify you (eg your full name, address and date of birth);
let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
let us know what right you want to exercise and the information to which your request relates.
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to complain
We hope that we can resolve any query or concern you may raise about our use of your information. See “How to contact us” below.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.
Changes to this privacy policy
This privacy policy was published on 20th April 2018 and last updated on 21st March 2023.
We may change this privacy policy from time to time, when we do we will inform you via email and online at www.therapynottingham.co.uk.
How to contact us
Please contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you. You can contact us here.
Our contact details are:
Address: Therapy Nottingham, 8 Eldon Chambers, Wheeler Gate, Nottingham, NG1 2NS
Email: hello@therapynottingham.co.uk
Telephone: 0115 7722132