Privacy
Your personal information
Your privacy is very important to us. You can be confident that your personal information will be kept safe and secure and will only be used for the purpose it was given to us. We adhere to current data protection legislation, including the General Data Protection Regulation (EU/2016/679) (the GDPR), the Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2003.This privacy notice tells you what we will do with your personal information from initial point of contact through to after your therapy has ended, including:
Why I am able to process your information and what purpose I am processing it for
Whether you have to provide it to me
How long I store it for
Whether there are other recipients of your personal information
Whether I intend to transfer it to another country,
Whether I do automated decision-making or profiling, and
Your data protection rights.
If you have any questions about our data protection policy you can contact us via info@empathco.com
‘Data controller’ is the term used to describe the person/organisation that collects and stores and has responsibility for people’s personal data. In this instance, the data controller is our registered business, empathco ltd, which is registered with the Information Commissioner’s Office.
Lawful basis for holding and using your personal information
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’re processing your data:
If you have made an enquiry via our website we will use consent and legitimate interest as a basis for holding and using your personal information.
If you have had therapy 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 therapy or if you are in contact with us to consider therapy, 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 psychotherapy) and necessary for a contract with a health professional (in this case, a contract between you and your therapist).
How we use your information
When you contact us with an enquiry about our therapeutic services we will collect information to help us satisfy your enquiry. This will include name, contact details, referral source (if applicable). Alternatively, your GP or other health professional may send us your details when making a referral or a parent or trusted individual may give us your details when making an enquiry on your behalf.
If you decide not to proceed we will ensure all your personal data is deleted within 12 months. If you would like us to delete this information sooner, just let us know.
While you are accessing therapy
Rest assured that everything we discuss is confidential. That confidentiality will only be broken if you consent, if required by law (for example in relation to money laundering or terrorism legislation) or if you disclose a risk of significant harm to yourself or others. We will always try to speak to you about this first, unless there are safeguarding issues that prevent this. (Please see ‘Terms and Conditions’ for further details).
We will keep a record of your personal details to help the therapeutic services run smoothly. These details are kept securely on an encrypted, password-protected PC and/or on a secure cloud based system. We will keep brief written notes of each session, these are kept securely as hand-written notes. Hand-written notes are kept separately from, and do not contain your full name and contact details.
Once therapy has ended we will digitise and secure hand-written records, and destroy hardcopies securely. We may choose to switch to digitised notes before the end of your therapy if I decide that this provides a more secure way of keeping your data. Electronic copies will be kept for 7 years from the end of our contact with each other and are then securely destroyed. Once records have been digitised I will continue to keep name and contact details separately from notes. If you want me to delete your information sooner than this, please tell me.
Third Party Recipients of personal data
We sometimes share personal data with third parties, for example, where we have contracted with a supplier to carry out specific tasks, such as secure data storage, or online communication providers. In such cases we have carefully selected which partners we work with. We take great care to ensure that we have a contract with the third party that states what they are allowed to do with the data we share with them. We ensure that they do not use your information in any way other than the task for which they have been contracted.
These third parties currently are:
Google Workspace (for email and digital storage)
Acuity and Stripe/PayPal (for practice management, including secure storage of contact details, appointment scheduling and secure, encrypted payment processing)
Your Rights
We try to be as open as we can be in terms of giving people access to their personal information. You have a right to ask us to delete your personal information, to limit how we use your personal information, or to stop processing your personal information. You also have a right to ask for a copy of any information that we hold about you and to object to the use of your personal data in some circumstances. You can read more about your rights at www.ico.org.uk/your-data-matters.
If we do hold information about you we will (unless an exemption applies):
give you a description of it and where it came from;
tell you why we are holding it, tell you how long we will store your data and how we made this decision;
tell you who it could be disclosed to;
let you have a copy of the information in an intelligible form.
You can also ask us at any time to correct any mistakes there may be in the personal information we hold about you.
To make a request for any personal information we may hold about you, please put the request in writing, using the subject title ‘Personal Data’, via info@empathco.com.
If you have any complaint about how we handle your personal data please do not hesitate to get in touch using the same email address given above.
If you want to make a formal complaint about the way we have processed your personal information you can contact the ICO which is the statutory body that oversees data protection law in the UK. For more information go to www.ico.org.uk/make-a-complaint
Data Security
We take the security of the data we hold about you very seriously and as such, we take every effort to make sure it is kept secure. The PC we use is encrypted and password protected, and data is backed-up using a secure cloud based service. Handwritten notes are anonymised.
Website
When someone visits our website, we use third party services, Squarespace and Google Analytics to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the site, navigation and conversion rates. This information is only processed in a way that does not identify anyone. We do not make, and do not allow Squarespace or Google to make, any attempt to find out the identities of those visiting our website. Our appointment scheduling is managed with a platform called Acuity, and data submitted through our website is processed through them.
We use legitimate interests as our lawful basis for holding and using your personal information in this way when you visit our website.
We use Squarespace and Google Analytics so that we can continually improve our service to you.
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