At Bristol CBT and Psychotherapy, We are committed to protecting and respecting your privacy. This Privacy Notice explains in detail the type of personal data which may be collected about you when you interact with us or our website https://www.bristolcbtandpsychotherapy.co.uk. It also explains how we store and handle that data and keep it safe.
We know there’s a lot of information here but it is important you are fully informed about your rights, and how your data is used. We hope the following sections will answer any questions you have, but if not, please do get in touch. It’s likely we will need to update this Privacy Notice from time to time and you will be notified of any significant changes. However, you are welcome to come back and check it whenever you wish. When you are using the Bristol CBT and Psychotherapy website, Emma Pye and Vanessa Shaw are the data controllers and they are responsible for your personal data.
Our full details are:
Emma Pye and Vanessa Shaw trading as Bristol CBT and Psychotherapy. www.bristolcbtandpsychotherapy.co.uk firstname.lastname@example.org
It is very important that the information held about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at email@example.com. By providing us with your data, you warrant to us that you are over 13 years of age.
EXPLAINING THE LEGAL BASES WE RELY ON
The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:
In specific situations, we can collect and process your data with your consent. For example, when you fill out a client contract. When collecting your personal data, it will always be made clear to you which data is necessary in connection with a particular service.
In certain circumstances, your personal data is required to comply with contractual obligations. For example, when you have an assesment we will collect your address, phone number, email and GP details. These will be kept on a secure client notes system accessible to us. If appropriate with your consent, we may share information with BABCP accredited colleagues who practice from our premises to offer you treatment.
In specific situations, your data is required to pursue our legitimate interests in a way which might reasonably be expected as part of running Bristol CBT and Psychotherapy and which does not materially impact your rights, freedom or interests.
WHAT SORT OF PERSONAL DATA DO WE COLLECT? WHY? ON WHAT GROUNDS DO WE PROCESS IT?
Personal data means any information capable of identifying an individual. It does not include anonymised data.
We may ask for, or hold, ‘confidential client information’ about you which will be used to support delivery of appropriate, safe and effective treatments. We need to be able to process such data (referred to as ‘data processing’) in all the locations where we provide our services – whether that is in your home, or at consultation rooms.
We may process the following categories of personal data about you:
Communication Data that includes:
- Details of your interactions with us through the contact form on our website;
- Interactions through email or text;
- Your comments and reviews;
- Information shared during an appointment.
We process this data for the purposes of communicating with you, for record keeping and for matters related to legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
Customer Data that includes:
- Details of treatments booked;
- Your name, title, home address, email address, phone number, next of kin and other contact details;
- Payment history information;
- Contact we have had over time with you, such as appointments and home visits;
- Details and notes about treatment and care, including notes and reports about your health.
We process this data in order to carry out treatments, provide the products you have purchased and to keep records of such transactions. We also process it to maintain records of contact we have had with you, such as appointments, home visits, details about treatments, including notes and reports about your health. Our lawful ground for this processing is consent and the performance of a contract between you and us and taking steps at your request to enter into such a contract.
User Data that includes:
How you use our website and any online services together with any data that you post for publication on our website or through other online services.
We process this data to operate our website and ensure relevant content is provided to you, to ensure its security, to maintain back-ups of our website and databases and to enable publication and administration of our website, other online services and business.
Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.
Technical Data that includes:
Your use of our website and online services such as;
- your IP address and login data;
- details about your browser;
- length of visit to pages on our website;
- page views and navigation paths;
- details about the number of times you use our website.
The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant content and adverts to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website, to grow our business and to decide our marketing strategy.
Marketing Data that includes:
Information about your preferences in receiving marketing from us;
Details of your communication preferences.
We may also need to collect more sensitive information (defined in the GDPR as ‘Special Category’ Data) such as whether you have any disabilities, allergies, health conditions or take prescription medication. It is important for us to have a complete picture, as this information assists therapists involved to deliver appropriate treatments, plans and to meet your needs. We require your explicit consent for processing sensitive data, so when you submit your details, we will send you a further communication asking for you to confirm your consent to this processing.
Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to deliver our treatments to you. If you don’t provide us with the requested data, we may have to cancel a service you’ve booked, but if we do, we will notify you at the time.
We will only use your personal data for the purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this, or if you have any questions about how we are collecting and using your personal data, please don’t hesitate to ask or email us at firstname.lastname@example.org
We may process your personal data without your knowledge or consent where this is required or permitted by law.
We do not carry out automated decision making or any type of automated profiling.
WHEN AND HOW DO WE COLLECT YOUR PERSONAL DATA?
Information is collected in a number of ways, but here are some of the most commonly used.
- Verbally when you are with a member of Bristol CBT and Psychotherapy;
- Manually when you fill in client consultation cards and other documents;
- Via our website when you fill out the online enquiry form;
- Directly given by carers, relatives and friends over the phone or in person;
- When you contact us by any means with queries;
- When you book any kind of appointment with us or book to attend an event;
- When you choose to complete any surveys we send you;
- When you comment on or review our services.
HOW DO WE USE YOUR PERSONAL DATA?
- To help inform decisions that we make about your care;
- To ensure that your treatment is safe and effective;
- To review care provided to ensure it is of the highest standard possible;
- For clinical supervision;
- To send you communications which you have requested and that may be of interest;
- To notify you of changes to our services;
- To seek your views or comments on the services we provide;
- To remind you of upcoming appointments.
- To improve our products and services.
Our lawful basis for processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow Bristol CBT and Psychotherapy).
Under the Privacy and Electronic Communications Regulations, we may send you marketing communications if (i) you’d booked a treatment or asked for information from us about our products or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Don’t forget that you can still opt out of receiving marketing emails from us at any time.
Before we share your personal data with any third party for their own marketing purposes we will get your express consent.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing us at email@example.com at any time.
If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other interactions with us, such as treatments booked and purchases made.
DISCLOSURES OF YOUR PERSONAL DATA
We sometimes share your personal data with trusted third parties. We require all third parties to whom we transfer your data to respect the security of it and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions. For example, therapists visiting your home or to handle complaints.
Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:
- We provide only the information they need to perform their specific services;
- They may only use your data for the exact purposes we specify in our contract with them;
- We work closely with them to ensure that your privacy is respected and protected at all times;
- If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.
Examples of the kind of third parties we work with are:
- It companies who support our website and other business systems
- Online booking provider
- Email marketing service
- Google to show you products that might interest you while you’re browsing the internet. This is based on either your marketing consent or your acceptance of cookies on our websites. See our Cookies Notice for details.
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria. Some of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring that safeguards are in place: Our email marketing service for example is a US-based provider. This company is part of EU-US Privacy Shield, so we may transfer data to them, as they have equivalent safeguards in place.
On occasions, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
HOW DO WE STORE YOUR INFORMATION AND KEEP IT SAFE?
The reason why Personal Data is kept safe and secure is to protect your privacy and confidentiality. We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those team members who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.
Information is retained in secure electronic and paper records on our information systems and accessed by staff through desktop computers. Paper records are kept securely locked away when not in use and key holders are strictly monitored. Such access is strictly restricted to Emma Pye and Vanessa Shaw provided with the equipment, passwords and other security devices we use to ensure that only those people who need to see your Personal Data in order to process it correctly can do so.
Ensuring that our clients are aware of the importance of keeping personal records safe and secure at all times is also a key element of risk management around safety and security of record keeping. We adhere to our obligation of condidentiality in our work agreement contracts and policies and procedures provide written, regularly updated guidance on our approach to storage and archiving Personal Data. are required to inform you of how the information we collect will be used, to explain the basis upon which we keep your data on our systems and share it where necessary. These conversations will be noted in your records and you have the right to view these if you wish to.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to. Not all breaches will require further action; all will be investigated internally and what happens next is based on what data has been exposed and what risk that poses. If we discover that a breach is likely to result in a risk to your and other people’s rights and freedoms or will adversely affect them, we will inform you without delay and report to the Information Commissioner’s Office (ICO) within 72 hours.
HOW LONG WILL WE KEEP YOUR DATA FOR?
Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.
When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements. Patient records are kept for the length of time that is required for complying with our business insurance code of practice.
For tax purposes the law requires us to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for seven years after they stop being clients. At the end of that retention period, your data will either be deleted completely or anonymised.
In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
WHAT ARE YOUR LEGAL RIGHTS?
Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.
Under Data Protection Law , you may request access to information (with some exemptions) that is held about you and, as soon as we have verified your identity, and so long as it will not adversely affect the rights and freedoms of others, we will provide it free of charge and respond to your request within one month of receiving it.
You can see more about these rights at:
If you wish to exercise any of the rights set out above, please email us at firstname.lastname@example.org or contact us using the contact details at the top of this Privacy Notice.
We may need to request specific information from you to help us 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. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
The Bristol CBT and Psychotherapy website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.