Privacy Policy – Your Privacy Matters
Website Privacy Notice
We respect the importance of your privacy. This privacy policy is intended to provide clarity on what personal information we collect in order to market and provide our services. It also tells you how we securely store this when you visit or contact us via our website. It additionally outlines how this information is collected, how it is used, and the nature of our legal responsibilities/your rights in relation to these.
This notice should be read in conjunction with other policies and terms provided to you when contracting our services. It is not intended to override any other policy.
General Data Protection Regulation (GDPR):
For users in the United Kingdom, we adhere to the GDPR as enshrined in the Data Protection Act 2018. For users in the European Union, we adhere to the regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, also known as the GDPR.
Privacy Consent:
By viewing our website, users consent to the conditions set out in this privacy notice. When the legal basis for us processing your personal information is that you have provided your consent, users can withdraw their consent to processing of their personal data at any time. They can do this by contacting the data controller. If you withdraw your consent, it will not make processing of information which we completed before you withdrew your consent unlawful.
Data Controller and Contact Information:
Flourishing Futures Psychology is owned and run by Dr Emily Fletcher. Dr Fletcher is registered with the Information Commissioner’s Office (ICO), as the official data controller. Queries about data control should be directed to emily@flourishingfuturespsychology.co.uk.
Legal Basis for Processing Your Personal Information:
We only collect and process personal data about users in the EU when we have a legal basis for doing so under Article 6 of the GDPR.
We rely on the following legal bases to collect/use personal data of users in the EU.
1. Where users have provided their consent to the processing of their data for one or more specific purposes.
2. Where processing of personal data is necessary for us to take, at the request of the user, steps before entering a contract or for the performance of a contract for which the user is a party. If a user does not provide the personal data necessary to perform a contract, we may not be able to provide our services.
3. Where processing is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
4. Where processing of personal data is necessary for us to comply with a legal obligation. If a user does not provide the personal data necessary to perform this obligation, we may not be able to provide our services.
How We Use Your Personal Information:
Data collected on our site will only be used for the purposes of: marketing; communicating about; providing; and accepting/processing payment for our services. If we reasonably consider that we need to use your data for any other purpose, we will make thorough attempts to contact you to explain the legal basis which allows us to do this. Please note that we may process your personal data without your knowledge or consent, in compliance with the general principles outlined in this notice, where it is required or permitted by law. Examples of how we use your data are provided below.
1. To register you as a new client;
2. To provide you with the information and services that you request from us;
3. To fulfil our obligations arising from any contracts entered into between you and us, relating to psychological or other services;
4. To arrange appointments and payment as per our contract;
5. To collect and recover money owed to us;
6. To provide you with information about other goods or services which may interest you;
7. To let you know in the event of any changes to our services;
8. To improve our website, services, data analytics and marketing;
9. To improve your user experience of our website;
10. For our legitimate interest; and/or
11. To comply with any legal obligations.
Use By Children:
We do not knowingly collect or use personal data from children under the age of 16 on our website. We politely ask that young people under the age of 16 seek the help of a parent or guardian before contacting us via this website. If we learn that we have collected personal data from a child under 16 years of age, the personal data will be deleted as soon as possible. If a child under 16 years of age has provided us with personal data, their parent or guardian may contact our data controller.
Personal Data We Collect:
We only collect data that helps us achieve the purpose set out in this privacy notice.
When you visit our site, we may automatically collect and store technical and behavioural information about how you reach and interact with its content. This will be used for the purpose of streamlining your website experience and providing an understanding of site traffic. It will also be used to inform future marketing of our services. Information may be collected via Google analytics, cookies and similar technologies like pixels, tags and other identifiers that can store your preferences. Example information that may be collected includes your IP address; location; hardware and software details; time-zone setting; URL click-stream to, through and from our site; searches carried out and content viewed.
We may also collect and store information you provide us when you contact us via our website contact form, phone number/voicemail, email or otherwise. This information may include your first and last name, your email address or telephone number, your payment information and any other information that you chose to provide. We may additionally receive personal information from third party providers with whom we work closely, such as school teachers or other healthcare professionals.
Who We Share Your Personal Data With:
We won’t share your data with third parties for any purpose other than those stated here. Where relevant data is disclosed to third parties for a specific purpose, we require that your data be treated in accordance with the law. Third parties will not be able to access user data beyond what is reasonably necessary to achieve the given purpose. We may disclose your personal data to third parties as detailed below.
1. Where required by law, court order, competent public authority or for the purpose of law enforcement;
2. To professional advisors for the purpose of receiving consultancy, legal, insurance, banking and accounting services;
3. To GDPR compliant software that carries out functions on our behalf, such as email, text message, voicemail, calendar, booking, billing, payment, accounting, statistical analysis, analytics, marketing, security, and data storage;
4. To providers of IT and system administration support;
5. To third parties in the event of any merger, sale, joint venture, assignment, transfer or other disposition of Flourishing Futures Psychology; and/or
6. To HMRC, or other regulators and authorities who may require us to report to them, for example for the purpose of audit.
We may also disclose your personal data to third parties when you have specifically given written consent for additional sharing. For example, we may share information with school teachers, family members and other health professionals for the purpose of furthering your care under the contract agreed between us. We may also use anonymised data for the purpose of research in circumstances where you have given consent for us to do so.
This website is hosted by third party servers which are compliant with EU GDPR. Please note that if you follow any links, applications or plug-ins from our site to another site, we are not responsible for and have no control over their privacy policies and practices.
Cookies:
Our website may use cookies and similar technologies like pixels, tags and other identifiers. A cookie is a small file stored on a user’s hard drive by a website. Its purpose is to collect data related to a user’s browsing habits for the purpose of customised marketing. Cookies enable us to do things such as improve the design and functionality of our site, by collecting data on things such as how you access our site, what you access while there and how long you remain on the site. They may also be used to remember the selections you make on the site, so that they can be saved for your next visit.
To manage the cookies and similar technologies used (tracking pixels, web beacons, etc.) and related consents, we use the consent tool “Real Cookie Banner”. Details on how “Real Cookie Banner” works can be found at https://devowl.io/rcb/data-processing/. You can opt out of browser cookies by clicking the opt-out option on the cookies banner pop-up. You can also change your own computer settings to inform you when a cookie is being set or updated, or to block them altogether. However, by doing so, the functionality and usability of our site may be reduced.
Data Security:
We are committed to ensuring the privacy of your information. We have therefore put security measures in place to prevent your personally identifiable information from being accidentally lost, accessed, altered, or used in any unauthorised way. All personal information is stored in compliance with EU GDPR rules. Further details about this are provided prior to your first appointment.
Please note that while we take all reasonable precautions to ensure that user data is secure and that users are protected, there always remains the risk of harm. The internet as a whole can be unsecure at times and we are therefore unable to guarantee the security of user data beyond what is reasonably practical.
How Long We Store Your Personal Data:
We will not keep you data for longer than reasonably necessary to achieve the purpose for which it was collected. In accordance with The British Psychological Society’s best practice guidelines, if you are under the age of 18 on the date of our first new contact, we retain your personal information and health record until you turn 26. If you are over 18 on this date, we will hold your information for a period of 7 years. All information will be deleted after these time periods, by the end of the calendar year.
Data may be kept for longer periods in cases where you have given consent for your anonymised data to be used for research or statistical purposes.
Your Rights:
Under data protection law, you have rights, including those outlined below.
Your right of access – You have the right to ask us for copies of your personal information.
Your right to rectification – You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing – You have the right to ask us to restrict the processing of your information in certain circumstances.
Your right to object to processing – You have the right to object to the processing of your personal data in certain circumstances.
Your right to data portability – You have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances.
You are not usually required to pay any charge for exercising your rights. If you make a request, we will usually respond to you within one month. However, we may charge a reasonable fee or refuse to comply with your request if it is clearly unfounded, repetitive or excessive. We may also require some specific information from you in order to process your request, for example to confirm your identity or ensure your right to access. If your request is especially complex, or you have made a number of requests, it may take us longer than a month to respond.
Please contact us at emily@flourishingfuturespsychology.co.uk if you wish to make a request.
You also have the right to complain to the ICO (www.ico.org.uk) at any time. However, please let us know in the first instance if you think we’re doing something that’s not right. This will give us the opportunity to rectify it for you.
Modifications To This Privacy Policy:
This privacy policy may be amended periodically to maintain compliance with the law and reflect any changes to our data collection process. We recommend that our users periodically review our privacy policy to ensure they are notified of any updates.