Privacy Notice
Company mobile – 07534 687 937
Email Address – info@openroadpsychotherapy.com
Website – www.openroadpsychotherapy.com
The basis on which I keep client data is that of “Legitimate Interests”. This means that the data is necessary for me to fulfil the contract that we have together (ie to provide therapy) and that it is data that you would reasonably expect me to hold and use.
For those who enquire about therapy, the data I hold includes any information you have sent me by email/text/message.
For those who book and attend at least one session, the data I hold includes:
• Basic information such as name, email address, phone number
• Information that you give me as part of the work we do together
• Audio recordings of each session
• Records of what interventions that I use (or potentially do not use) in our sessions
• Emails, texts and/or messages that are sent between us
• Information sent from any third party, eg GP, insurance company, EAP
Some of the information that you give me may fall under the definition of special category of data as defined by the General Data Protection Regulation. Processing is necessary for medical diagnosis, the provision of health care or treatment pursuant to contract with a health professional
Other than this, data is not shared with anyone, except possibly your GP (also my accountants), and for any reasons covered by the Requirements for Disclosure which are detailed and discussed when we first meet. My accountants will see your first/last or company payment, from where bank transfers are made.
The data is primarily used to enable me to provide therapy for you and for my capacity as a therapist to be assessed. It may also be used for scientific research purposes and statistical purposes.
Details of where data is held:
• Any emails sent between us are held securely on my password protected computer and biometric protected mobile phone.
• Any texts or WhatsApp messages sent between us are held securely behind biometric security on my mobile phone.
• Your notes are held secure on Dropbox, which is protected by two-way verification.
• Audio recordings will be held protected in the same way on Dropbox.
Your data is kept for 7 years. The length of time is based on the requirements of my insurance company. After this time any paper records are shredded and computer records permanently deleted. Audio recordings will also be deleted after this time.
I take the security of data seriously and as such:
• Give details of all security measures including how any systems you use are secure (including payment systems)
If there is any breach of data security, I will give full details to the Information Commissioners Office and any person affected within 72 hours of the breach and do all possible to minimise any potential impact.
You have rights with regards to the data held:
• The right of access. I will provide you with all data I hold on you as soon as I can following a request (and definitely within 30 days, unless this is impossible due to holidays or illness).
• The right to rectification. If any data I hold is incorrect, do let me know and I will correct it as soon as I can following a request (and definitely within 30 days, unless this is impossible due to holidays or illness).
• The right to erasure. If you wish me to erase your data do let me know and I will delete any computer records and shred any paper records as soon as I can following a request (and definitely within 30 days, unless this is impossible due to holidays or illness). NB: data may be retained for scientific research, historical research or statistical purposes where erasure is likely to render impossible or seriously impair the achievement of that processing, but this would never include case notes or data such as address/email/phone
• The right to restrict processing. This would usually be a stop-gap measure before correction of any errors or before erasure
• The right to data portability. This might apply if you want your notes sent to another therapist for example, but it is likely that the easiest solution would come under the right to access, ie I would send the data to you.
• The right to object to:
o processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling). I do not engage in these matters.
o direct marketing – Any circular emailer
o processing for purposes of scientific/historical research and statistics. For this, you must provide grounds for your objection.
o automated decision making and profiling. I do not engage in automated decision making or profiling.
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