This document sets out my policy regarding the information I record about you. It sets out the conditions under which I process information I collect from you, or that you provide to me. It covers information that could identify you (“personal information”). In this context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information. This policy complies with UK law, including that by the UK Data Protection Act 2018 and the EU General Data Protection Regulation (GDPR).

I need to collect information about you so that we can:

• Know who you are so that we can communicate with you in a personal way. The legal basis for this is a legitimate interest.
• Deliver services to you. The legal basis for this is the contract with you.
• Process your payment for the services I provide. The legal basis for this is the contract with you.
• Verify your identity so that I can be sure we are dealing with right person. The legal basis for this is a legitimate interest.
• Send you relevant information (such as self-help resources). The legal basis for this is your consent.
• Provide you with a useful and relevant website. The legal basis for this is legitimate interest.

If I send you marketing communications and you no longer wish to receive them, you can opt out anytime by contacting me or clicking on the ‘unsubscribe’ button on my marketing communications.

I may process your personal data for more than one lawful reason at a time, depending on the specific purpose for which I am using your data.  If you’d like more information on the specific legal ground I am relying on, on occasions where I rely on more than one legal ground, please feel free to contact me.

I collect three categories of personal information about you and (where this applies) your dependents:

• Standard personal information: this includes your name, gender (or preferred identity), address, date of birth, email address, phone numbers, the name and policy number of any health insurance policy.
• Special category data: this includes information about your mental and/or physical health, prescribed medication, psychological history, current difficulties, sexuality. I may collect some of this information from your referrer, if you have one, and some of this information will be collected directly from you. I will ask for your consent to share information with your GP, and seek consent for us to occasionally communicate via email or text, for example when arranging appointments. When you are a patient I record all details of your appointments and assessment/treatment so I can plan and review your treatment appropriately. At the end of therapy I will ask you to complete a service evaluation form that we use to evaluate and improve our clinical practice. This is anonymous. We will ask you whether you consent to sharing any comments on our website as anonymous testimonials. I require your explicit consent for processing special category data, so when you submit your details, I will send you a further communication asking for you to confirm your consent to this processing.
• Technical Data: this includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• 
  

I use the data we collect from you in the following ways:

• To communicate with you so that I can inform you about your appointments with me I use your name, your contact details such as your telephone number, email address or postal address
• To create an invoice, I use your name, address and email address
• To write an assessment report, I use information relating to your current and past psychological difficulties and diagnoses.
• To provide you with written resources that you may request via my website.
• The technical data I collect is used to help run my business, provide administration and IT services, network security and to prevent fraud.  It is also used to help develop my business and improve my marketing.

I will only use your personal data when the law allows me to. Most commonly, I will use your personal data in the following circumstances:

• Where I need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for my legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where I need to comply with a legal obligation.

Generally, I do not rely on consent as a legal basis for processing your personal data although I will get your consent when collecting special category data (such as health information).

I use different methods to collect data from and about you. The majority of the time, the information is collected directly when you contact me in the following ways:

• When you fill in any new client/supervision onboarding forms;
• When you complete any forms before or during an appointment;
• Verbally during discussions;
• Correspondence with me via post, phone, email or otherwise;
• When you apply for my services or any of my products;
• When you subscribe to my services or publications;
• When you request marketing communications to be sent to you; or
• When you give me feedback or contact me.

Another method I may use to collect data includes the use of automated technologies or interactions, like website cookies or other similar technologies. This includes information about your equipment, browsing actions and patterns and information about your browsing activity if you visit another website that uses the same cookies as my website. This means I receive information about how you use these third-party websites.

This data collection helps me to improve user experience, and to gather information about how you use my website. For more information, please refer to my Cookie Policy, which can be seen further below.

We may also receive data from third-parties such as: 

• Technical information from Analytics providers such as Google
• Advertising networks such as Instagram
• Search information provides such as Google
• Publicly available sources, such as Companies House and the Electoral Register.

All personal information and special category information is stored in compliance with EU General Data Protection Regulations (GDPR) rules and in compliance with the Data Protection Act 2018. 

• Storage of Clinical records:  These are kept on Cliniko which is a secure cloud-based practice management software, which uses two-factor authentication login and encrypted data replication to keep information safe. I do not store client identifiable information on computer hard disks.
• Storage of Supervision records: These are kept on Tresorit which is a secure cloud-based storage.
• Payment: I issue invoices using Xero, and as my finance management system.
• Emails: I use Outlook 365 an encrypted email system. 
• Appointment Scheduling: Initial consultations will be arranged via the mail address you provide me on the website contact form.

The Data Protection Act 2018 states that personal data processed for any purpose or purposes should not be kept for longer than is necessary for that purpose all those purposes. This means I will not store or keep personal data for longer than is necessary or required by law. Personal data will need to be retained for longer in some cases than in others. A decision in how long personal data will be retained will be based on individual needs. A judgement will be made about:

• the current and future value of the information;
• the costs, risks and liabilities associated with retaining the information;
• and the ease or difficulty of making sure it remains accurate and up to date.

The minimum recommended period for retention of adult mental health personal data is six years. This also applies to Supervision records.

If you contact me with an initial enquiry and share personal details, but do not then become a client, I will delete your personal information after four weeks. If you confirm you do not want to pursue a service within those four weeks I will destroy the information immediately.

Administrative data is retained for up to six years as necessary in the event there are queries from HMRC. Where it is not necessary to retain the data it will be destroyed as soon as possible.

Your information is kept confidential where possible. There are, however, some circumstances where I have a duty of care to share information (for example safeguarding concerns), or where I have to share your personal information by law (to help law-enforcement agencies perform their duties). In most circumstances I will not disclose personal data without your consent.

Your information may be shared with outside organisations if they are directly involved in your care. For example, your GP, your insurer if they are funding your treatment. Private medical insurance companies and independent case managers sometimes expect written progress reports to authorise treatment. In this instance they will request your written permission for information to be disclosed. I will discuss with you what information is shared. The process of transmitting information will always be in accordance with GDPR rules (for example, using encrypted email software).

If you are referred to another psychologist or healthcare professional for specialist care or assessment, your relevant information may be shared with them to ensure continuity of care and appropriate treatment.

If you are a supervisee I will collect sensitive data related to your psychology practice. This data may be shared with a third party if I am legally or ethically obliged to do so (e.g. if instructed by a court or if there are concerns about malpractice and need to report to a professional body).

Clinical Psychologists are required to have regular supervision to maintain high standards, however steps will be made to protect your identity. I use first names only and do not share identifying details with our supervisors.

Your data may also be shared with the following:

• Services providers, acting as processors who provide IT and system administration services.
• Professional advisers, acting as processors or joint controllers, including healthcare professionals, lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities, acting as processors or joint controllers who require reporting of processing activities in certain circumstances.

I also sometimes Microsoft teams to carry out online consultations and therapies.  You will need to check their privacy policies which can be found here: https://www.microsoft.com/en-gb/privacy/privacystatement

I require all third parties to respect the security of your personal data and to treat it in accordance with the law. I do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with my instructions.

Many of my external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

Whenever I transfer your personal data out of the UK, I ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• Where I use certain service providers, I may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK. 

Please contact me if you want further information on the specific mechanism used by me when transferring your personal data out of the UK.

My website might link to third-party websites, tools and apps. Clicking on these links may allow third parties to collect or share your data.

I do not control said websites and am not responsible for said websites’ privacy policies. When you leave my website, I encourage you to read the privacy policy of every website you visit.

Cookies help make our website work better for you, remembering your preferences and improving your experience. You can control cookie settings in your browser.  Cookies make your browsing experience on our site as smooth as possible, because they remember your preferences.

Our website uses cookies to distinguish you from other users of our website. Please refer to our Cookie Policy here to learn more: https://betterbeginnings.co.uk/cookie-policy/

I 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, I limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on my instructions and they are subject to a duty of confidentiality.

I 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 I am legally required to do so.

You have the following rights (certain exceptions apply):

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 I hold about you and to check that I am lawfully processing it.

Request correction of the personal data that I hold about you. This enables you to have any incomplete or inaccurate data I hold about you corrected, though I may need to verify the accuracy of the new data you provide to me.

Request erasure of your personal data. This enables you to ask me to delete or remove personal data where there is no good reason for me continuing to process it. You also have the right to ask me to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where I may have processed your information unlawfully or where I am required to erase your personal data to comply with local law. Note, however, that I 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 I am 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 I am processing your personal data for direct marketing purposes. In some cases, I 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 me to suspend the processing of your personal data in the following scenarios:

If you want me to establish the data’s accuracy.

Where my use of the data is unlawful but you do not want me to erase it.

Where you need me to hold the data even if I no longer require it as you need it to establish, exercise or defend legal claims.

You have objected to my use of your data but I need to verify whether I have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. I 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 me to use or where I have used the information to perform a contract with you.

Withdraw consent at any time where I am 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, I may not be able to provide certain products or services to you. I will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact me.

No fee usually required.  You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, I may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, I could refuse to comply with your request in these circumstances.

What we may need from you.  I may need to request specific information from you to help me confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. I may also contact you to ask you for further information in relation to your request to speed up my response.

Time Limit to respond.  I try to respond to all legitimate requests within one month. Occasionally it could take me longer than a month if your request is particularly complex or you have made a number of requests. In this case, I will notify you and keep you updated.

I always try to meet the highest standards when collecting and using personal information, and take complaints seriously. Please contact me if you think my collecting or use of information is unfair, misleading or inappropriate. I would also welcome any suggestions for improving procedures.
Email: hannah@enlighten-minds.co.uk

You also have the right to raise your complaint with the Information Commissioners Office (ICO):

Website: https: ico.org.uk
Email: casework@ico.org.uk
Telephone: +44 (0) 303 123 1113

Any changes to this privacy policy will be posted on our website enlighten-minds.co.uk.

I regularly review this privacy policy. Please do keep me updated if your personal data changes.