The Therapy Clinic Privacy Notice

The Therapy Clinic is committed to preserving the privacy and security of your personal information.
This Privacy Notice provides you with important information on:
• your rights and obligations
• how we collect and use your personal information
• who we share your personal information with
• what we do to keep it secure
• how to contact The Therapy Clinic Data Protection Officer
This Privacy Notice applies to you if you access or apply for any of our services over the phone, by post or online via our websites and online services.
You may access certain areas of our site without providing any data at all. However, to use our services you will be required to provide information.
By visiting our website you are agreeing to the contents of this Privacy Notice.

1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:  “Our site” means the website: and “We/Us/Our” means The Therapy Clinic.

2. Information About Us
Our site, is owned and maintained by:
• The Westbourne Therapy Clinic Ltd t/a The Therapy Clinic, 175 Westbourne St Hove, Bn3 5FB
• We are a registered company 11535456

3. Collection of Data
The Therapy Clinic may collect the following data :-
• Your name
• Date of birth
• Contact information including your email address
• Geographic information from your postcode
• Other information relevant to you engaging in counselling with us, e.g. the name of your medical practice
• Information about any disability or communication difficulty you may have
• Information about your education or employment status
• Clinical information via our assessment form
• Invoice and Payment information – note we do not store your card details on our systems.
• Additional information i.e. clinical notes as required to provide a therapeutic service

4. Data from 3rd parties
• Additional information as required to provide a therapeutic service i.e. clinical notes and referral information if referred by a 3rd party

5. How We Use Your Data

• The lawful basis and purpose of holding this data is to ensure we can meet the terms for providing a contract for counselling and psychotherapy with you
• We will also use your personal data to meet any legal obligations placed upon us – for instance when you exercise your rights to see what data we hold under data protection law or in order to meet any legal compliance placed on us; or occasions where we may be obliged to disclose information related to safeguarding children, young people and adults at risk.
• Your written consent will be sought at initial consultation for the need to meet possible disclosure to other bodies and for when we process any special categories of sensitive personal data about you, such as gender and sexual orientation

6. Transfer of data outside of the EEA
• The Therapy Clinic uses 3rd Party systems that may store some of your data outside the European Economic Area. If this is the case, we will ensure that the information is transferred in accordance with this Privacy Notice and as permitted by the applicable laws on data protection.

7. Protection of Data

Personal information is held securely and will only be used in accordance with data protection principles, our data protection and confidentiality policies and our professional ethical requirements.
• Only your therapist or in exceptional circumstances, i.e. in order to protect you or your therapist, the Clinical Director is authorised to access your notes
• We only keep your data for as long as we need to in order to use it as described above in section 4, and/or for as long as we have your permission to keep it.
• The Therapy Clinic has appropriate policies and procedures to prevent
• unauthorised access or disclosure,
• There are suitable and appropriate physical, electronic and managerial procedures to safeguard and secure the information we collect online.

8. Use of Cookies
• As well as collecting data for online bookings and donations, this website also uses cookies to collect data during your visit. Please see our Cookie Policy for information on the cookies we use.

9. Sharing of Data
• We do not sell, trade, or otherwise transfer to outside parties any personally identifiable information excepting the following: –
• With trusted subcontractors to perform functions on our behalf. Examples include companies that:-
• Provide us with systems and services that support the administration of our online booking service
• Provide banking and payment services to support or enable online payments
• With therapists working at The Therapy Clinic
• In exceptional circumstances we may be required by law and our ethical responsibilities to break our confidentiality with you.
• We would discuss this with you first wherever possible but if you do not give consent we may still have to disclose information.  This relates to situations where you may be at risk of harm, causing harm to others, the safeguarding of children, young people and adults at risk, acts of terrorism and unreported road traffic accidents where we are under legal obligations

10. Links to other websites 
• Our website may have links to other websites, but these websites are not under our control. Therefore, we will not be liable to you for any issues arising in connection with their use of your information, the website content or the services offered to you by these websites. We advise you to consult the privacy notice and terms and conditions on each website to see how each supplier may process your information.

11. Your Rights
Right to Access:
• You can request a copy of the personal information that we hold about you. This is generally known as a ‘Data Subject Access Request’ and we normally have 1 month to respond.
Right to rectification
• If your information changes and we are informed we will update your information. Please remember that it is your responsibility to tell us about any updates to this information.
Right to erasure or to be forgotten
• You have the right to ask us to erase your personal information. However, this right is balanced against other factors. Legal and regulatory obligations may mean we cannot comply with your request.
Right to restriction of processing
• If you put a restriction in place we can continue to store your information and only process it with your consent or for the establishment, exercise or defence of legal claims, for the protection of another individual’s rights or for important public interest reasons
Right to be informed
• The Therapy Clinic must provide you with fair processing information.  This information is contained in this Privacy Notice
Right to data portability
• In certain circumstances, you have the right to ask that we transfer any personal information you have provided to us to another third party of your choice.
Right to object to processing
• You can object to The Therapy Clinic processing your data . We can continue to process your information for the establishment, exercise or defence of legal claims and if we demonstrate compelling legitimate grounds that over-ride your interests, rights or freedoms.

12. Changes to our Privacy Policy
• If we decide to change our privacy policy, we will post those changes on this page, and/or update the Privacy Policy modification date below.
This policy was last modified on November 11th, 2018.

13. Contacting us (GDPR Data Officer)
• If there are any questions regarding this privacy policy you may contact our GDPR Data Officer using the information below.
 Write to: GDPR Data Officer, The Therapy Clinic, 175 Westbourne Street, Hove BN3 5FB
Telephone: 01273 068175