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Privacy Policy

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Your confidentiality and privacy are important to Head 2 Toe Wellbeing, and we take the necessary steps to ensure we protect your identity under the General Data Protection Regulations (GDPR), keeping your personal data safe and secure to the best of our ability.

 

This privacy notice sets out how Head 2 Toe Wellbeing collects, handles, stores, uses and shares your personal data and the lawful basis under the Data Protection Act 2018 and GDPR that permits us to do so.

 

By visiting our website, you are agreeing to the contents of this Privacy Notice.

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1.      Data Protection Lead

 

1.1       The Data Protection Lead is the owner of Head 2 Toe Wellbeing – Samantha Doyle. Samantha Doyle is registered with the      Information                       Commissioners Office (ICO) and holds the ICO registration number: ZB621443.

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2.     What Personal Data we collect and why?

 

2.1      Head 2 Toe Wellbeing holds data provided by you at first contact, at assessment and during the treatment process. The data collected includes:

 

  • the information you provided when you made the first contact (whether in person, by telephone, by email, by contact form or by any other means of communication).

  • the information you provided during the initial telephone assessment and the first contracting session (including your name, address, date of birth, gender identity, ethnicity, religion, sex, sexual orientation, phone number, your GP, any disabilities, emergency contact and medical information related to mental and/or physical health).

  • the information provided in any of the assessment measures used in sessions.

  • a record of each contact that we have had with you including short notes about each contact.

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2.2      We collect this information in order to determine your needs from Head 2 Toe Wellbeing, so that we can provide you with a better service, and in            particular for the following reasons:

 

  • internal record keeping.

  • to assist with assessment, to determine the treatment required, and for professional supervision of how we work.    

 

2.3      Another reason for Head 2 Toe Wellbeing to keep client data is to comply with the British Association for Counselling and Psychotherapy Ethical              Framework and is done through the ‘Client Contract’ where we obtain your consent. Having a counselling contract demonstrates to the client the            ethical principle of “Autonomy: respect for the client’s right to be self-governing” (BACP 2018).

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3.     What is our lawful basis for processing your personal data?

 

3.1      The GDPR states that we must have a lawful basis for processing your personal data. There are different lawful bases depending on the stage at            which we are processing your data. These are explained below:

 

  • If you have had counselling with us and it has now ended, we will use legitimate interest as our lawful basis for holding and using your personal information.

  • If you are currently having counselling or if you are in contact with us to consider counselling, we will process your personal data where it is necessary for the performance of our contract.

  • The GDPR also makes sure that we look after any sensitive personal information that you may disclose to us appropriately. This type of information is called ‘special category personal information’. The lawful basis for us processing any special categories of personal information is that it is for provision of health treatment (in this case counselling) and necessary for a contract with a health professional (in this case, a contract between us and you).

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4.     How do we use your personal date?

 

4.1      We will only use your email address and telephone number to contact you about your appointments. Your therapist may also contact you directly            via email or text message in order to share information with you that is pertinent to your therapeutic process. Your phone number and email                  address will also be used to issue appointment reminders via text message and email.

 

4.2      We do not share your personal information with anyone else unless in pursuit of counselling on your behalf and only then if we have your                       permission to do so. In exceptional circumstances we may be required by law and our ethical responsibilities to break our confidentiality with               you. We would discuss this with you first wherever possible, but if you do not give consent, we may still have to disclose information.  This                     relates to situations where you may be at risk of harm, causing harm to others, the safeguarding of children, young people and adults at risk,                 acts of terrorism and unreported road traffic accidents where we are under legal obligations.

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5.     How long will your information be held?

 

5.1      Head 2 Toe Wellbeing will retain your personal data for a period of 7 years after your last year of contact with the service. After 7 years, the                  personal data that we hold will be safely destroyed.

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6.     What are your rights?

 

6.1      Under the Data Protection Legislation, you have the following rights:

 

  • to request access to, and copies of, the personal data that we hold about you; • to request that we cease processing your personal data;

  • to request that we do not send you any marketing communications;

  • to request us to correct the personal data we hold about you if it is incorrect; • to request that we erase your personal data;

  • to request that we restrict our data processing activities (and, where our processing is based on your consent, you may withdraw that consent, without affecting the lawfulness of our processing based on consent before its withdrawal);

  • to receive from us the personal data you have provided to us, in a reasonable format specified by you, to another data controller;

  • to object, on grounds relating to your particular situation, to any of our particular processing activities where you feel this has a disproportionate impact on your rights and freedoms.

 

Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply. Any requests or objections should be made in writing to the Data Protection Officer whose contact details are below.

 

7.         Contact details for the Data Protection Officer and complaints.

 

7.1      If you have any concerns in the way in which Head 2 Toe Wellbeing is processing your personal date, you may contact our Data Protection Officer            at Samantha.doyleH2TW@outlook.com.

 

7.2      If you still remain dissatisfied, then you have the right to apply directly to the Information Commissioner’s Office (ICO) for a decision. The ICO                can be contacted at:

 

          Information Commissioner’s Office,

          Wycliffe House,

          Water Lane,

          Wilmslow Cheshire

          SK9 5AF

 

         Telephone: 0303 123 1113

         Website: www.ico.org.uk

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