Dr Sarah Simmonds is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice). Dr Sarah Simmonds is registered with the UK’s Information Commissioner’s Officer, registration number ZA570707 By providing us with your data, you warrant to us that you are over 13 years of age.
Our Contact Details:
Full name of legal entity: Dr Sarah Simmonds trading as “The Leicestershire Psychology Service”
Postal address: 659 Melton Road, Thurmaston, Leicester, LE4 8ED
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at the email address above.
2.WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND WE PROCESS IT (FOR ALL CLIENTS ACCESSING OUR SERVICES AND PROFESSIONALS ACCESSING CLINICAL SUPERVISION AND TRAINING)
Personal data means any information capable of identifying an individual. It does not include anonymised data. We may process the following categories of personal data about you:
Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address, email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
User Data that includes data about how you use our website. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back- ups of our website and/or 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 data about your use of our website and online services such as your IP address, your 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, time zone settings and other technology on the devices you use to access 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 website content and advertisements 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 and our business and to grow our business and to decide our marketing strategy.
Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws and free give-aways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.
We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is our legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).
Sensitive Data (FOR ALL CLIENTS ACCESSING OUR SERVICES)
In order to deliver our services to you we need to collect special categories of personal data which is classified as sensitive data:
Special Personal Data such as sensitive personal information about your difficulties, relationships, medical history, life events and criminal /forensic history if appropriate.
Health Data such as GP details, medical health insurance provider and other relevant health and social care support agencies, and therapy notes from our sessions.
Our lawful ground for processing this type of sensitive data is explicit consent and the performance of a contract between you and us and/or taking steps at your request to enter into such a contract. This is so we can:
Consult with you on whether our services are most appropriate for your difficulties
Conduct a thorough psychological assessment
Devise and implement an effective treatment plan (therapy)
Invoice for the services rendered
Communicate (when necessary and agreed with you) with relevant third parties to support your treatment and manage risks. LPS agrees not to disclose confidential information about you to a third party without your consent unless LPS are required to share such information in line with the proper course of LPS duties to protect the safety of yourself or another person. Please see 5. Disclosures of Your Personal Data for more information.
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 perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to terminate our service to you, we will notify you at the time. We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at email@example.com. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.
We may share your personal data without your knowledge or consent where this is required or permitted by law, for example if we have reason to believe that sharing or processing such data may be required to protect someone from serious harm.
4. MARKETING COMMUNICATIONS Our lawful ground of processing your personal data to send you marketing communications is through your consent. Under the Privacy and Electronic Communications Regulations,we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. However you can still opt out of receiving marketing emails from us at any time. If you opt into receiving marketing messages from us or third parties, you can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences. If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as services provided to you by us.
5.DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below:
Where we have a contract with a third-party supplier, such as our accountants and virtual assistant, to supply certain products or services (i.e., for accounting services, including processing your invoices; and office administration).
Where your service with us is funded through a third-party such as a private medical insurance provider, employer or other agency and as part of this contract they may require information about your engagement with us or may require information regarding the progress of your treatment.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority or if we have to share information with the relevant authorities to ensure compliance with safeguarding risk to yourself or others.
Carrying out a legal duty or as authorised by the Secretary of State.
Protecting vital interests of a Data Subject or other person.
If the data subject has already made the information public.
Providing a confidential service where the data subject’s consent cannot be obtained or where it is reasonable to proceed without consent: e.g., where we would wish to avoid forcing stressed or ill data subjects to provide consent signatures.
We require all third parties to whom we transfer your data to respect the security of your personal data 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. 6.INTERNATIONAL TRANSFERS
In order to run our business we use third party organisations that supply us with software and services such as Google Workspace, Xero, Writeupp, Calendly, Weebly and Barclays Bank. This means we share your data with these third parties in line with their data protection regulations in order to use their products and services. We are subject to the provisions of the General Data Protection Regulations that protect your personal data. Where we transfer your data to third parties outside of the EEA, we will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data. As such:
We may transfer your personal data to countries that the United Kingdom regulatory authorities have approved as providing an adequate level of protection for personal data by; or
If we use US-based providers that are part of a UK regulator approved privacy framework, we may transfer data to them, as they have equivalent safeguards in place; or
Where we use certain service providers who are established outside of the EEA, we may use specific contracts or codes of conduct or certification mechanisms approved by the UK which give personal data the same protection it has in Europe.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
Please contact us using the details above for further information about the data protection safeguards used by us when transferring your personal data to a third country.
We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation
All client files and therapy notes are kept securely within our practice management system.
All professional clinical supervision notes, training records and personal data is stored securely within our practice management system and cloud storage software OneDrive.
Any information you send to us on email, via telephone message or by completing the website booking form is only kept on those platforms for as long as needed to complete the communication with you. If you are a client with us then this information is uploaded onto a secure, password-protected patient management system once the purpose of the communication is fulfilled and the communication is deleted from the contact form, email system or telephone.
We limit access to your personal and sensitive data to those employees, associates with a legitimate ‘need to know’ and we ensure that they are subject to duties of confidentiality.
Data is backed up daily and stored using secure cloud based systems with multi factor authentication access.
All computer hardware used has up to date antivirus and anti malware protection installed and regularly updated.
We ensure up to date cyber security training and cyber insurance to ensure we are taking every steps to protecting your data and having access to the best support for protecting your data should the unlikely event of a data breach or cyber crime occur.
We have procedures in place to deal with any suspected personal data breach. In the unlikely event of a data protection breach we will notify the Information Commissioner’s Office (ICO) so that their procedures can be followed. We will also notify all individuals whose data may have been accessed to alert them to the breach and any potential risks if we are legally required to.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Your data will be kept for the lifetime of your status as a client with us. When you are discharged or you end your professional contract with us in the case of professionals accessing clinical supervision / training with us, your data will be kept for a minimum period of eight years, and a maximum period of ten years in accordance with NHS Records Management Code of Practice 2020 (Link to PDF here).
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. For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.
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.
For those who make an enquiry about our services who do not go on to become a client with us, or enter into a contract with us for professional services, we retain your data for a period of 12 months to satisfy any legal, or reporting requirements in relation to your enquiry.
9.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.
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 would be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
This 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.
THE LEICESTERSHIRE PSYCHOLOGY SERVICE
Hygge House 659 Melton Road Thurmaston Leicester LE4 8DE