1. North Hampshire Clinic is committed to safeguarding the privacy of its clients, website visitors and service users. We respect and value the privacy of clients and everyone who visits Our Site and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.
2. North Hampshire Clinic is to be considered a data controller for the purposes of this policy and in compliance with the General Data Protection Regulation, effective from 25 May 2018 (“GDPR”)
3. North Hampshire Clinic is registered with the Information Commissioners Office
DATA PROTECTION OFFICER
4. North Hampshire Clinic has decided that a Data Protection Officer is not required, in order to be compliant with GDPR.
GDPR DATA PROCESSING
5. North Hampshire Clinic hold and process data under varying legal basis (see Appendix One; legal basis). Our most common processes are detailed as follows:
6. North Hampshire Clinic also process data in terms of;
- Testimonials - see clauses 16-19
- Photographs at events; we reserve the right to use pictures taken at events for promotion and social media as part of a contractual basis on attendance, subject to your rights to opt out
7. Data will only be collected through North Hampshire Clinic’s website and booking function if you voluntarily submit it and consent to Us using it for the purposes of providing our Services and/or marketing (such as newsletters). Depending on the use of Our Site, We may collect some or all of the following data:
- Gender, Sexuality and Religion;
- Contact details of your GP and/or other Health Care Professionals
- Job Title and Profession;
- Contact information such as email addresses and telephone numbers;
- Demographic information such as post code, preferences and interests;
- A list of URLs starting with a referring site, your activity on Our Site, and the site you exit to (automatically collected through tracking software eg Google Analytics and Google Search Console). The information gathered relating to our website is used to create reports about the use of our website and to understand usage for further development.
8. North Hampshire Clinic’s website has an SSL certificate to add a greater level of security.
10. North Hampshire Clinic does not store or process data directly on the website. The website does not contain logins for staff or members of the public to use.
- identify you when you visit our website and as you navigate our website
- secure our website and services generally
- help us to analyse the use and performance of our website and services; and
- store your website use preferences.
13. Website users are able to refuse, to accept or block cookies through their browser security settings at any time. Blocking cookies may reduce usability or the number of features available on our website.
14. North Hampshire Clinic does not store, save or collect personal information from the website through cookies.
HOW WE USE YOUR DATA
15. Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
- you have given consent to the processing of your personal data for one or more specific purposes;
- processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
- processing is necessary for compliance with a legal obligation to which we are subject;
- processing is necessary to protect the vital interests of you or of another natural person;
- processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
- processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
16. North Hampshire Clinic may process testimonials on an anonymised basis
17. North Hampshire Clinic reserve the right to copy, screen shot and use comments made about North Hampshire Clinic in a public arena, such as on social media
18. Testimonials may be shared on North Hampshire Clinic’s website, social media, paper and/or digital marketing.
19. North Hampshire Clinic reserve the right to use anonymised testimonials or testimonials without use of identifiable data, where consent is not recorded following provision of a testimonial
23. Communication, engagement and actions taken through external social media platforms that this website and its owners participate on are subject to the terms and conditions as well as the privacy policies held with each social media platform respectively
24. Users are advised to use social media platforms wisely and communicate / engage upon them with due care and caution regarding their own privacy and personal details. Neither this website nor its owners will ever ask for personal or sensitive information through social media platforms. Users wishing to discuss sensitive details should do so through primary communication channels such as by telephone or email
25. North Hampshire Clinic’s website may use social sharing buttons which help share web content directly from web pages to the social media platform in question. Users are advised before using such social sharing buttons that they do so at their own discretion and note that the social media platform may track and save your request to share a web page through your social media platform account
26. North Hampshire Clinic reserves the right to publish comments, testimonials and posts made on social media in unedited form. We use automated social media walls and social share functions on our website to reflect up to date social media engagement. Website users are reminded that engagement with these functions is at their own risk
27. Users are advised to take caution and use good judgement before clicking any shortened URLs published on social media platforms by North Hampshire Clinic. Despite the best efforts to ensure only genuine URLs are published, many social media platforms are prone to spam and hacking and therefore this website and its owners cannot be held liable for any damages or implications caused by visiting any shortened links.
28. North Hampshire Clinic operates an email newsletter program, used to inform clients and interested parties about the latest information, products and services. Users can subscribe through an online automated process should they wish to do so at their own discretion. Some subscriptions may be manually processed through prior written agreement with the user
29. Subscriptions are taken in compliance with UK Spam Laws detailed in the Privacy and Electronic Communications Regulations 2003 as well as GDPR
30. Email marketing campaigns published by North Hampshire Clinic may contain tracking facilities within the actual email, linked to our website tracking. This information is used to refine future email campaigns and supply the user with more relevant content based around their activity
31. In compliance with UK Spam Laws and the Privacy and Electronic Communications Regulations 2003, subscribers are given the opportunity to un-subscribe at any time through an automated system. This process is detailed at the footer of each email campaign. If an automated un-subscription system is unavailable, clear instructions on how to un-subscribe will be detailed instead.
PROVIDING YOUR DATA TO OTHERS
32. From time to time North Hampshire Clinic may contact your GP and/or other healthcare professionals about the status of your care. North Hampshire Clinic will, in the first instance, gain consent from you that it is satisfactory for us to do this, however we reserve the right to do so should it be considered that there is a legal or vital interest to do so
33. North Hampshire Clinic reserve the right to breach confidentiality and share personal data ONLY where there is a public safety issue, legal obligation or vital interest to do so
34. North Hampshire Clinic may process any personal data identified in this policy for the establishment, exercise or defence of legal claims (whether administrative or out of court) and for the purposes of obtaining or maintaining insurance coverage, managing risks or obtaining professional advice
35. North Hampshire Clinic will disclose personal data, at your request, to your GP and/or other practitioners for referral
36. North Hampshire Clinic seek regular supervision consultations with other therapists qualified in this process. The consultation process is for the practice (rather than seeking instruction on working with you). In order to protect your privacy, our supervisor will not know you personally nor professionally. We may refer to you by your first name, and we may refer to your information verbally when it's helpful to our professional processes.
37. Your name and contact details will be shared with our Therapeutic Executor. This is so that you will be contacted in the event of your therapists death, should you still be in therapy with us.
YOUR RIGHTS: RETAINING AND DELETING INFORMATION
38. Personal data that we process, for any purpose, shall not be kept for longer than is necessary for that purpose or those purposes
39. Data security is of great importance to North Hampshire Clinic and we take steps to secure and protect your data, including:
- Password protected cloud-based database management
- Password protected third party applications
- Secure locked on-site document cabinets
40. Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.
41. North Hampshire Clinic respect your rights under GDPR (See definitions, Your rights). Please contact firstname.lastname@example.org at any time to instruct us should you feel that your rights are being infringed or for requests for further information
42. You have the right to confirmation as to whether we process your personal data, purposes of the processing, the categories of personal data concerned and the recipients of the personal data
43. You have the right to request copies of data held by North Hampshire Clinic, providing the rights and freedoms of others are unaffected
44. Requests for copies of data should be made to email@example.com. North Hampshire Clinic will confirm receipt of your request.
45. The first copy will be provided free of charge. Additional copies may be subject to a reasonable fee. Pursuant to GDPR, North Hampshire Clinic reserve the right to charge for requests that are vexatious or require additional administration.
YOUR RIGHTS TO CORRECT, ERASE, OBJECT TO, RESTRICT DATA AND WITHDRAW CONSENT
46. You have the right to have any inaccurate personal data about you rectified and, considering the purposes of the processing, to have any incomplete personal data about you completed
47. In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data which is no longer necessary in relation to the purposes for which it was collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data has been unlawfully processed.
However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims
48. In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful, but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest
49. You have the right to object to our processing of your personal data on grounds relating to your situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims
50. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose
51. You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest
52. If you consider that our processing of your personal information infringes data protection laws, You have the right to challenge such decisions under GDPR, requesting human intervention, express own point of view, and obtaining an explanation of the decision from Us.
53. You have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal
SUMMARY OF YOUR RIGHTS UNDER GDPR
54. Under the GDPR, you have:
- the right to request access to, deletion of or correction of, your personal data held by Us;
- the right to complain to a supervisory authority;
- be informed of what data processing is taking place;
- the right to restrict processing;
- the right to data portability;
- object to processing of your personal data;
- rights with respect to automated decision-making and profiling
55. North Hampshire Clinic reserve the right to change and/or vary our website, services and/or policies at any time. Please check our website to see any latest variation
56. North Hampshire Clinic is owned and operated by North Hampshire Clinic, Arena Business Centre, The Square, Basingstoke, Hampshire. RG21 4EB
57. Please contact us via firstname.lastname@example.org or telephone 01256 638111 or by post at the above address should you need to contact us about anything within this policy.
Policy last updated January 2019 - Version 1.2