PRIVACY POLICY

I hold certain client information in an electronic form in line with Article 9, paragraph 2(h) of the EU Data Protection Regulation, and the Data Protection Act 1998.  This Privacy Policy sets out how I manage personal information you provide and that is collected when using this website and other digital services such as email communication. 

The type of personal information I collect 
‘Personal information’ is any information that can be used to identify you or that can be linked to you.  The personal information I may collect from clients include: name, email address, telephone number, next of kin, GP and referral details. 

I may also automatically collect certain information as you use, access or interact with my services via digital communication.  For example, third party analytical services and similar technologies (‘cookies’) are used to collect and store certain information when you use, access or interact with my digital services.  

Cookie Policy

By accessing this website you consent to the cookie policy unless you wish to opt out. Cookies are small data files created anonymously containing information that is stored on the user's hard drive.   Cookies are generated and used by Google Analytics to understand how users interact with websites. Information stored in these cookies may include such things as the time of the visit, whether a user has visited the site before and what site referred the user to the web page. If you opt out of Google Analytics it will not affect the use of this website. Further information on opting out can be found on this Google page.

 

Information I collect from other sources 

I may receive information about you from other sources, including third parties that help me update, expand and analyse my records, identify new clients or prevent or detect fraud. I may also receive information about you from social media platforms including but not limited to if you interact with me on those platforms or access my social media content. The information I may receive is governed by the privacy settings, policies, and/or procedures of the applicable social media platform and I encourage you to review them. 
 

How I use the information 

  • To respond to enquiries;

  • To provide therapeutic and other appropriate services, as requested;

  • To operate, troubleshoot and improve digital services;

  • To understand how digital services are used including by generating and analysing statistics;

  • For business purposes, including data analysis; submitting invoices; detecting, preventing and responding to actual or potential fraud, illegal activities or intellectual property infringement;

  • To assess the effectiveness of promotional work and publications; and

  • As I believe reasonably necessary or appropriate to comply with legal obligations, respond to legal process or requests for information issued by government authorities or other third parties; or to protect your, my, or others’ rights.

  • As set out in my Client Privacy Notice which each client receives prior to commencing therapy

How I share the information 
I may share information with other service providers for administration, billing, promotional services and to provide you or your organisation with services. I do not sell, rent, or otherwise share information that reasonably identifies you or your organisation with unaffiliated entities for their independent use except as expressly described in this Privacy Policy or with your prior permission. I may share information that does not reasonably identify you or your organisation as permitted by applicable law. 

I may also disclose information collected:

  • To our third-party service providers that perform services on my behalf, such as web-hosting companies, mailing vendors, analytics providers, event hosting services, and information technology providers.

  • To law enforcement, other government authorities or third parties (within or outside the jurisdiction in which you reside) as may be permitted or required by law. 

Grounds for using your personal information 
I rely on the following lawful basis for processing your personal information:

  • Performance of a contract – I collect and use your personal information to enter into a contract with you or to perform a contract that you have with me.

  • Consent - Where your clear consent is given for me to process your personal data for therapeutic and associated services as set out in this privacy policy.

  • Legitimate interests – I may use your personal information for legitimate interests to improve my services and the content of my digital services.

 

Third-party services and content 
My digital services may include integrated content or links to content provided by third parties (such as video materials). This Privacy Policy does not address the privacy, security, or other practices of the third parties that provide such content. 

Protection and storage of the information 
I use administrative, technical and physical safeguards designed to comply with applicable legal requirements and safeguard the information that I collect. This includes, when required or appropriate and feasible, obtaining written assurances from third parties that may access your data that they will protect the data with safeguards designed to provide an effective level of protection.  
However, no information system can be 100% secure therefore, I cannot guarantee the absolute security of your information. Moreover, I am not responsible for the security of information you transmit to me over networks that I do not control, including the Internet and wireless networks. 

My digital services are controlled and operated by the firms from the UK. I may transfer information to countries outside of your country of residence, which may have data protection laws and regulations that differ from those in your country. 

I retain the information I collect no longer than as reasonably necessary to fulfil the purposes for which I collect the information and to comply with my legal obligations. 

Your choices and rights 
Subject to applicable laws, you may have certain rights regarding information that I have collected and that is related to you. You may contact me to update or correct your information if it changes or if you believe that any information that I have collected about you is inaccurate. You can also ask to see what personal information I hold about you, to erase your personal information and you may also tell me if you object to the use of your personal information. In the UK, you have a right to complain to the Information Commissioner’s Office (ICO). If you would like to discuss or exercise the rights you may have, send me an email via the contact page

Changes to this privacy policy 
I may update this privacy policy from time to time, in line with the ICO's guidance. I therefore encourage you to periodically review this page. If I make any material changes in the way I collect, use, and/or share the personal information that you have provided, I will notify you by posting notice of the changes in a clear and conspicuous manner on the this website.

The Duke Street Practice

3-5 Duke Street

London, W1U 3ED

07423 057 075

anna@annarobinsontherapy.com

© Anna Robinson 2019