Invest CBT provides psychological treatment services to Ashford, Kent, London and the UK.
This privacy notice provides information about the personal information we process about you as a data controller, in compliance with the General Data Protection Regulation (GDPR).
Appendix I and II below also contains information regarding the cookies our website might store about you and our use of Google Analytics to help monitor volumes of traffic to our website.
Our ICO registration number is ZA325969.
Carl Rees, Lead CBT Psychotherapist, Clinical Supervisor and EMDR Therapist is the data controller. Please contact Carl at carl.rees@investcbt.com (secure mail) with any questions or requests about the personal information we process.
Your Rights
We are committed to protecting your rights to privacy. They include:
· Right to be informed about what we do with your personal data;
· Right to have a copy of all the personal information we process about you;
· Right to rectification of any inaccurate data we process, and to add to the information we hold about you if it is incomplete;
· Right to be forgotten and your personal data destroyed;
· Right to restrict the processing of your personal data;
· Right to object to the processing we carry out based on our legitimate interest.
The personal data we process, why we process it, where it comes from and the legal basis for doing so
Assessment/Therapy cases
We process the personal data of individuals who are therapy clients. This might include:
· Names, contact details and dates of birth;
· IP address (if via the website contact box)
· Health information (including GP details);
· Information about race, ethnic origin and gender;
· Information about criminal offences.
Some personal data are provided by health insurance providers. This includes basic contact information, referral information, and health insurance policy number and authorisation for psychological treatment. Some personal data will be collected directly from you and might be via email, contact box on the website, telephone or face to face.
Associate psychotherapists, psychologists and counsellors receiving referrals from Invest CBT will be additional data controllers for the clients they work with directly and be solely responsible for safeguarding client details and maintaining compliance with GDPR.
Invest CBT processes this personal data because it is in our legitimate interests as CBT and EMDR Therapists to do so (our 'lawful basis'). We need to see and use this information to provide psychological therapy to clients.
In relation to any special category personal data, such as health records or information concerning race, ethnic origin, or gender, we rely on this being necessary for the purposes of the provision of health or social care or treatment, in addition to our legitimate interest. This might also include assessment questionnaires, reports and their associated data.In many cases, an individual has consented to the transfer of their personal data to us from referring healthcare providers or insurers. Where an individual has consented, he or she may easily withdraw it by notifying Carl Rees, Data Controller, at carl.rees@investcbt.com
Remote therapy
Invest CBT operates a remote therapy service using a secure video-link platform. As a client of Invest CBT this platform will request your name on log in so that your practitioner may be easily able to identify you. This platform does not store personal information, record video-calls or keep a record of any messages between client and therapist following a video-call. More information about Doxy.me and GDPR compliance can be found here:
https://help.doxy.me/en/articles/1621447-is-doxy-me-gdpr-compliant
Other personal data
We also process personal data pursuant to our legitimate interests in running our business such as:
· Invoices and receipts;
· Accounts and tax returns;
· Information to help with our marketing (such as how you heard about our service)
Retention period
We will only store your personal information for as long as it is required.
For assessment and therapy cases, basic contact information held on a therapist’s mobile phone is deleted six months following the end of therapy. This allows us to provide better service for returning clients.
Some personal data is retained, where necessary, for a minimum of seven years in compliance with our professional guidelines, accountancy and indemnity obligations. Your information is kept for the time necessary to provide the therapy service requested, however outside of this I will hold your details for as long as is necessary to comply with legal and policy obligations that are placed upon me by my insurers and / or your referring agency as a processor of sensitive data. After this all electronically stored data will be securely deleted.
For therapy cases, this personal data might include referral information and therapy records. For assessment cases, this might include psychometric questionnaires, data and reports. Where it is not necessary to retain personal data, this is destroyed at the end of assessment/therapy for such cases.
Administrative data is retained for up to seven years as necessary, in the event there are queries from HMRC. Where it is not necessary to retain the data for seven years, it is destroyed as soon as possible.
Whom do we share personal data with?
Here at Invest CBT we take your privacy seriously. We share personal data internally and with associate therapists on a strictly need to know and minimum information required basis. This information may include your email address, telephone number and details about the nature of your enquiry provided via the 'book an appointment' submission on our website.
Special category data held electronically is encrypted with restricted access. Hard copy special category and other personal data is transferred to secure and encrypted electronic storage within 24hrs of a session and held in a locked filing cabinet in a secret location away from the clinic without access to others.
We do not share personal data with anyone external to the organisation, without your consent, other than with:
· Referring health and insurance providers for the purposes of billing and to provide treatment updates where necessary;
· Counsellors, psychotherapists and psychologists working with Invest CBT on an associate basis;
· Those who have instructed us to provide psychological treatment, such as a solicitor. In these cases, relevant clinical information from therapy records will be shared with legal services as required and with your written consent;
· Relevant authorities when the information concerns risk of harm to the client, or risk of harm to another adult or a child, acts of terrorism or serious undisclosed offences. We will discuss such a proposed disclosure with you unless we believe that to do so could increase the level of risk to you or to someone else;
· HMRC and VAT Commissioner as they require;
· With others pursuant to a court order.
· My professional executor who has authorisation to access to current client names, phone numbers and associated GP surgery / referrer contact details in electronic format, stored on a passcode protected encrypted memory stick within a locked filing cabinet if I am suddenly incapacitated through poor health or in the case of an emergency, as detailed in my clinical will.
Your rights
You have rights relating to the information we hold to verify the accuracy or to ask for them to be supplemented, deleted, updated or corrected.
You have the right to request a copy of the information that we hold about you.
If you would like a copy of some or all of your personal information, please email Carl Rees, Data Controller, via the contact details stated in this agreement.
Information will be provided to you within 30 days.
We want to make sure that your information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate. You have a right to request the transfer of your data to another individual or company.
Information Commissioner’s Office
If you have any concerns about the way your personal information has been processed, please contact Carl Rees (below). Alternatively, you may contact the Information Commissioner’s Office on 0303 123 1113.
You are providing your personal data to Invest CBT and associated therapists with whom you work. The data controller for Invest CBT can be contacted at:
Email:
Telephone:
07340 918 114
In cases where other data controllers are involved (such as associate psychotherapists, psychologists or counsellors), they can be contacted via their own details provided at your request.
Appendix I: Website Cookies
1 What is a cookie?
A cookie is a small amount of data stored on a computer that contains information about the internet pages that have been viewed from that computer. They are commonplace on the internet and are used by websites to improve the user’s online experience by storing information about how the user navigated around and interacted with it. This information is then read by the website on the next occasion that the user visits.
Cookies are sent automatically by websites as they are viewed, but in order to protect a user’s privacy, a computer will only permit a website to access the cookies it has sent, and not the cookies sent by other sites. Furthermore, users can adjust the settings on their computer to restrict the number of cookies that it accepts, or notify them each time a cookie is sent. This should improve privacy and security but will generally meant that certain personalised services cannot be provided, and it may therefore prevent the user from taking full advantage of a website’s features.
For further information about cookies please visit aboutcookies.org.
2. What sort of cookies do we use on our website?
We use two types of cookies: session cookies and stored cookies.
Session cookies expire at the end of the user’s browser session and can also expire after the session has been inactive for a specified length or time, usually 20 minutes. Session cookies are stored in the computer’s memory and are automatically deleted from the user’s computer when the browser is closed.
Stored cookies are stored on the user’s computer and are not deleted when the browser is closed. Stored cookies can retain user preferences for a particular website, allowing those preferences to be used in future browsing sessions.
3. How do we use cookies?
They gather information regarding the visitors to our website on our behalf using cookies, allowing us to understand the amount of traffic to the website and whether they are returning visitors. We do not pass any information to a third party.
4. Can I browse your website without receiving any cookies?
Yes, if you have set your computer to reject cookies, you can still browse the website. However, certain functions may not be available to you unless you enable cookies.
5. How can I find and control cookies?
You can usually adjust for yourself the number of cookies that your computer (or other device, such as a mobile phone) receives. How this is done, however, varies according to which device and what browser software you are using.
As a general rule, the more commonly used web browser software packages ten to have a drop-down menu entitled ‘Tools’. One of the options on this menu is usually ‘Options’ – and if this is selected, ‘Privacy’ is usually one of the settings that may be adjusted by the user. In the case of any device other than a PC (egg and mobile phone) you should always refer to the manufacturer’s instructions.
Alternatively, you may wish to opt-out from only the cookies used by third-party companies (acting on our behalf) to measure the traffic to our site. This has the advantage of leaving other cookies in place, thereby minimising the loss of functionality associated with blocking all cookies.
You may find the following websites useful for information on how to change cookie settings in a range of commonly used browsers: aboutcookies.org
Please note that we only use cookies for the purpose of enhancing your online experience and no personal data is collected from you through this process.
Appendix II: Google Analytics
1.What is Google Analytics?
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
2 Opting out of Google Analytics
You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy
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