Policy key definitions:
- “I”, “our”, “us”, or “we” refer to the business, [Business name & other trading names].
- “you”, “the user” refer to the person(s) using this website.
- GDPR means General Data Protection Act.
- PECR means Privacy & Electronic Communications Regulation.
- ICO means Information Commissioner’s Office.
- Cookies mean small files stored on a users computer or device.
Processing of your personal data
Under the GDPR (General Data Protection Regulation) we control and / or process any personal information about you electronically using the following lawful bases.
Your individual rights
Under the GDPR your rights are as follows. You can read more about your rights in details here;
- the right to be informed;
- the right of access;
- the right to rectification;
- the right to erasure;
- the right to restrict processing;
- the right to data portability;
- the right to object; and
- the right not to be subject to automated decision-making including profiling.
You also have the right to complain to the ICO [www.ico.org.uk] if you feel there is a problem with the way we are handling your data.
We handle subject access requests in accordance with the GDPR.
Some cookies are required to enjoy and use the full functionality of this website.
Data security and protection
We ensure the security of any personal information we hold by using secure data storage technologies and precise procedures in how we store, access and manage that information. Our methods meet the GDPR compliance requirement.
Fair & Transparent Privacy Explained
We have provided some further explanations about user privacy and the way we use this website to help promote a transparent and honest user privacy methodology.
Email marketing messages & subscription
Under the GDPR we use the consent lawful basis for anyone subscribing to our newsletter or marketing mailing list. We only collect certain data about you, as detailed in the “Processing of your personal data” above. Any email marketing messages we send are done so through an EMS, email marketing service provider. An EMS is a third party service provider of software / applications that allows marketers to send out email marketing campaigns to a list of users.
Email marketing messages that we send may contain tracking beacons / tracked clickable links or similar server technologies in order to track subscriber activity within email marketing messages. Where used, such marketing messages may record a range of data such as; times, dates, I.P addresses, opens, clicks, forwards, geographic and demographic data. Such data, within its limitations will show the activity each subscriber made for that email campaign.
Any email marketing messages we send are in accordance with the GDPR and the PECR. We provide you with an easy method to withdraw your consent (unsubscribe) or manage your preferences / the information we hold about you at any time.
PRIVACY NOTICE (Data Processing)
Who we are and how we process your personal data
Elliott Henderson complies with his obligations under the General Data Protection Regulation (GDPR) by keeping personal data up to date; by storing (and destroying it) securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.
We use your personal data for the following purposes
To deliver the services that clients have requested;
To contact those clients as necessary in accordance with the services they have requested;
To contact clients via surveys to ascertain their opinions on the service they received from us;
To maintain our own accounts and records.
N.B. In the event that our recorded data is utilised for research purposes, our own supervision or for the instruction or tuition of students, all such data will be sufficiently anonymised to the extent that individual clients cannot be identified. Should a client indicate that their data should not be used for these purposes, we would refrain from using that data.
Individual client data will never be passed to a third party without the express consent of the respective client, always provided that such confidentiality is neither inconsistent with the therapist’s own safety or that of the client, the client’s family members or other members of the public, nor in contravention of any legal action or legal requirement.
In accordance with my need to maintain the possibility of access to client data as a result of returning clients or those who may wish to lodge a complaint in respect of our professional services to either our professional body or our insurers (i.e. in all cases perhaps after a long period of time has elapsed), we retain client data for a minimum period of 1 year.
Our Lawful Basis for processing client personal data
The client has given clear consent for me to process their personal data for a specific purpose. Further, the processing is necessary for both my client’s and my own legitimate interests.
Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
The right to request a copy of your personal data which Elliott Henderson holds about you;
The right to request that Elliott Henderson corrects any personal data if it is found to be inaccurate or out of date;
The right to request your personal data is erased where it is no longer necessary Elliott Henderson to retain such data;
The right to withdraw your consent to the processing at any time;
The right to request that the data controller provide the data subject with his/her personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable) [N.B. This only applies where the processing is based on consent or is necessary for the performance of a contract with the data subject and in either case the data controller processes the data by automated means].
The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
The right to object to the processing of personal data, (where applicable) [N.B. This only applies where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics]
The right to lodge a complaint with the Information Commissioners Office.
The client has the right to complain to the Independent Commissioner’s Office (ICO) if they think there is a problem with the way we are handling their data (see https://ico.org.uk/concerns/handling/).