Privacy Notice (April 2020)

This is the privacy notice of Ruth Hickinbotham MFHT MNCH (Reg.) HPD IIHHT Trading as Promoting Wellbeing.  In this document, "we", "our", or "us" refer to Promoting Wellbeing.

Introduction

  1. This is a notice to inform you of our policy about all information that we record about you. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.
  2. We regret that if there are one or more points below with which you are not happy, your only recourse is to leave our website immediately.
  3. We take seriously the protection of your privacy and confidentiality. We understand that all visitors to our website are entitled to know that their personal data will not be used for any purpose unintended by them, and will not accidentally fall into the hands of a third party.
  4. We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.
  5. Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).
  6. The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. We do this now, by requesting that you read the information provided at knowyourprivacyrights.org
  7. Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.

Data Control

Ruth Hickinbotham is the data controller for ‘Promoting Wellbeing’ services provided as a sole trader.

Privacy Notice

This is the privacy notice of Ruth Hickinbotham MFHT MNCH (Reg.) HPD IIHHT Trading as Promoting Wellbeing as a sole trader.  In this document, "we", "our", or "us" refer to Promoting Wellbeing

Introduction

This privacy notice aims to inform you about how we collect and process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information. It tells you about your privacy rights and how the law protects you.

We are committed to protecting your privacy and the confidentiality of your personal information. Our policy is not just an exercise in complying with the law, but a continuation of our respect for you and your personal information.

We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.

Our policy complies with the Data Protection Act 2018 (Act) accordingly incorporating the EU General Data Protection Regulation (GDPR).

The law requires us to tell you about your rights and our obligations to you in regard to the processing and control of your personal data. We do this now, by requesting that you read the information provided at http://www.knowyourprivacyrights.org

Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.

What personal data is processed

Personal data: basic contact information: name, address, email, contact number and GP contact details.

Sensitive personal data: signed therapy client agreement, medical declaration, therapy records.

If you complete a web-based enquiry form, we will also collect any information you provide to us as well as your internet protocol (IP) address.  This is automatically supplied by the website software used to offer the form.  All web services used by Promoting Wellbeing are verified by themselves as GDPR compliant.

For further information regarding how visitor information is used if you have found me via Hypnotherapy Directory: https://www.hypnotherapy-directory.org.uk/privacy.html, NCH website https://www.hypnotherapists.org.uk/privacy-policy/, FHT https://www.fht.org.uk/privacy

The lawful basis for processing personal data

Promoting Wellbeing has a legitimate interest in using the personal data and sensitive personal data collected to provide coaching and complementary therapies. It is necessary in order to provide safe therapy and coaching to clients.

As part of processing data, you may also be asked for information on how you found out about the service provided for the purpose of marketing research.

What is done with your personal information

Promoting Wellbeing will only use your personal information to provide the services you have requested and agreed to. No information you provide is passed on without your consent, Promoting Wellbeing will never sell your information to others.

If you do not provide the personal information requested, then Promoting Wellbeing may be unable to provide a therapy service to you.

How long personal information is stored

The sensitive personal data defined above is stored for a minimum of 7 years, or 25 years for treatment undertaken during pregnancy after the last session of therapy or coaching. After this time, this data is destroyed confidentially and securely. This is in line with professional guidance from the FHT and NCH.

How your personal information is used

Promoting Wellbeing will use the information collected to:

Provide therapy services to you.

Send you information and information about services that might be of interest to you (and relevant to the work undertaken). This would only take place with your verbal or written consent.

Promoting Wellbeing holds information about each client and the therapy they receive in confidence. This means that this information is not shared with anyone else. However, there are exceptions to this when there may be need for liaison with other parties:

When the client informs us of any illegal activity.

When the information concerns risk of harm to the client, or risk of harm to another adult or a child for the purpose of safeguarding.  Where possible, how this will be progressed will be discussed with the client.

When the client has given permission verbally or in writing to share information with another health provider, such as a GP for their benefit of their health or treatment.

What will NOT be done with your personal information

Your personal information will not be shared with third-parties for marketing purposes.

How the security of personal information is ensured

Personal and sensitive information is minimised in phone and email communication. Should the client send such information over the webpage enquiry or email, this information will be noted for its purpose and deleted and removed from any online reply to the client.

Email applications use private (SSL) settings, which encrypts email traffic so that it cannot be read at any point between our computing devices and our mail server. Promoting Wellbeing will never use open or unsecure Wi-Fi networks to send any personal data.

Personal information will be stored on hard copies and filed securely.  Personal computers and mobile devices are protected with a passcode.

For online therapy and coaching, we use encrypted communications channels unless you chose otherwise and confirm this in writing.  Our guide to how you can keep online appointments safe will be provided to you in writing prior to your appointment.

Your right to access the personal information held about you

You have a right to access the information that is held about you.

If a request is received, information will be shared with you within 30 days of receiving a request.

There may be an admin fee of up to £50 for supplying the information to you.

A hard-copy of your personal information will usually be sent to you.

You have a right to get your personal information corrected if it is inaccurate.

You can complain to a regulator. If you think that Promoting Wellbeing hasn’t complied with data protection laws, you have a right to lodge a complaint with the Information Commissioner’s Office.

Promoting Wellbeing reserves the right to refuse a request to delete a client’s personal information where this relates to therapy records. Therapy records are retained for a minimum period of 7 years or 25 years for treatments undertaken during pregnancy. This falls within professional guidance provided by The NCH, FHT and insurance provider.

Media

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Contact forms

Personal data, name and email address is captured when submitting a contact form from our website, www.promotingwellbeing.co.uk, this data is kept for customer service information and customer newsletters.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

Cookies

There are essential wordpress cookies that are required for the site to work and google analytics.

If you leave a comment on our site you may opt in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

Communicating with us

When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need.

We record your request and our reply in order to increase the efficiency of our business.

We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.

Complaints regarding content on our website

Our website is a publishing medium.   If you complain about any of the content on our website, we shall investigate your complaint.

If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate.

If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.

Complaining

When we receive a complaint, we record all the information you have given to us.

We use that information to resolve your complaint.  If the complaint can not be resolved we will be required to share that information with a professional organisation or our insurers to resolve the complaint.

Compliance with the law

Our privacy policy has been compiled so as to comply with the law of every country or legal jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your jurisdiction, we should like to hear from you.

However, ultimately it is your choice as to whether you wish to use our website.

Review of this privacy policy

We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.

If you have any question regarding our privacy policy, please contact us.

Ruth Hickinbotham, Therapist

April 2020.