1.IMPORTANT INFORMATION AND WHO WE ARE
This privacy notice aims to give you information on how Urmston Hypnotherapy, Andrea Szentgyorgyi, Registered Hypnotherapist collects and processes your personal data through your use of this website. This website is not intended for children, and we do not work with children; therefore, we do not collect data from children.
It is important that you are fully aware of how and why we are using your data.
This privacy notice supplements the other notices and is not intended to override them.
Our full details are:
Urmston Hypnotherapy, Andrea Szentgyorgyi, Registered Hypno-psychotherapist
Email address: firstname.lastname@example.org
Postal address: 66 Irlam Road, Urmston, Manchester M41 6GS
Urmston Hypnotherapy practice, Andrea Szentgyorgyi hypno-psychotherapist is a member of IAHT (International Alliance of Holistic Therapists), the National Society of Talking Therapies and a trainee member of UKCP.
Andrea Szentgyorgyi is registered as a data controller with the Information Commissioner (UK) and adhere to all requirements of this body and the Data Protection Act 1998. We operate under the jurisdiction of England. In case of online therapy with clients living in the EU, the REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural people concerning the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC applies. For further information, please see https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32016R0679&from=EN
Please note Urmston Hypnotherapy does not practice online outside the EEA area. Our website is hosted in the EU.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 25/7/2020. It is important that the personal data we hold about you is accurate and current.
Please keep us informed if your personal data changes during your relationship with us.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. THE DATA WE COLLECT ABOUT YOU
- Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
- We may collect, use, store and transfer different kinds of personal data about you, which we have grouped as follows:
- Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data email address, home address and telephone numbers.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Profile Data includes your username and password, your interests, preferences, skills, connections, feedback and survey responses,
- Usage Data includes information about how you use our website, products and services.
- The image includes your face and appearance.
If you fail to provide personal data where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel the service you have with us, but we will notify you if this is the case at the time.
3.HOW IS YOUR PERSONAL DATA COLLECTED
We use different methods to collect data from and about you including through:
Direct interactions. You may give us data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- Request to see a therapist; email or call us, receive personal, online or phone therapy, give us some feedback, or reply to our blog.
- Automated technologies or interactions.
- As you interact with our website, we may receive automatically Technical Data about you.
- Third parties or publicly available sources.
- We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties: analytics providers such as Yell or Google that are based outside the EU.
We only use your personal data when the law allows us to. Most commonly, we use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you. Note that, in this context, a contract does not have to be a formally signed document, or even written down, as long as there is an agreement which meets the requirements of contract law. Broadly speaking, this refers to your request to access therapy services via our platform and need to be contacted as part of this service that you require and for which there is a fee payable.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
- Generally, we do not rely on consent as a legal basis for processing your personal. You have the right to withdraw consent to marketing at any time by contacting us.
- PURPOSES OF USING YOUR DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of Data||Lawful basis for processing|
|To register you as a new client Identity and contact details||Identity, contact||Performance of a contract with you.|
|To process your request for therapy service||Identity, contact, medical, demographic, legal and payment information||Performance of a contract with you.|
|To manage our relationship with you which include||Identity, contact||Performance of a contract with you.|
|Notifying you about changes to our terms and conditions, services or subscription.||Identity, contact||Performance of a contract with you.|
|Marketing and communications||Identity, contact||Necessary to comply with a legal obligation|
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting data)||Technical||Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)Necessary to comply with a legal obligation|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||Technical Usage||Usage Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||Identity Contact Technical||Necessary for our legitimate interests (to develop our products/services and grow our business)|
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you in our marketing activities.
You will receive marketing communications from us if you have requested information from us through other websites for example BARK or Hypnotherapy Directory.
You can ask us to stop contacting you by writing us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, even registration, product/service experience or other transactions as we may still need to communicate with you about these products or services.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you, and we will explain the legal basis which allows us to do so, of course, you entitled to object to this new use of your data.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
∙ Service providers acting as processors based in the EEA who provide IT and system administration, accounting, invoicing and payment services.
∙ Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the EEA who provide consultancy, banking, legal, insurance and accounting services.
∙ HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA such as Google.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the European Union and the US. For further details, see European Commission: EU-US Privacy Shield.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
This means that Andrea Szentgyorgyi, registered hypnotherapist promise to:
- ·value the personal information entrusted to me and go further than just the letter of the law when it comes to handling personal information by adopting high practice standards
- ·consider and address privacy/confidentiality issues at every stage of contact with clients
- ·be open with clients about the extent of confidentiality (see below) and its exceptions
- ·keep personal information to the minimum necessary and delete it when it is no longer needed
- Specifically, this means:
- ·any financial information (e.g. credit card information) is shredded as soon as processed
- ·client notes are kept in a handwritten form or on a computer locked with a password and written contracts are held in a locked filing cabinet
- ·a coding system enables the therapist to know whose notes are whose but a stranger seeing the notes would not be able to identify whom they referred to
- ·little is written about the client, but instead, a record is kept of the interventions and progress
- ·emails are kept on a password
–protected computer or mobile phone for as long as the client/therapist relationship is active and permanently deleted after that
- ·any therapy conducted by email will be by way of a password protected word document, not within the email body itself
- ·clients are encouraged to use text or email to discuss appointment times, not for communication of therapeutic material
- ·we do not collect your data for direct marketing purposes
- ·see also social media policy
8. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
We keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for 7 years after they cease being customers, for tax purposes.
In some circumstances you can ask us to delete your data: see “Request erasure” below for further information. In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
You have a right to access your personal data, request correction or erasure of your personal data, and you have a right to object to the processing of your personal data.
If you wish to exercise any of the rights set out above, please contact us at email@example.com, and we will fulfil your request within 4 weeks.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights).
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
It’s important that you know that the law may forbid our standard confidentiality in the following circumstances:
- ·If we become aware or have good reason to suspect, that you have knowledge of:
- ·A past or future incident/situation that may be dangerous or harmful to a child, you or another adult, and that is not known to the relevant authorities.
- ·Future or past criminal activity that has not been resolved in law. This means any criminal activity, of which the relevant authorities are either unaware of or a case they know about which they consider not to be closed (provided you do not present information in therapy which would reasonably re-open the case). This does not include parking or traffic offences unless there is an intent, by you or anyone else, to cause danger to yourself or others, or that it is deemed to be a “serious offence”. For our purposes, a serious offence is something for which you could be imprisoned and for which the sentence (not necessarily imprisonment) hasn’t yet been served.
- In these circumstances, we will work with you to make appropriate disclosures.
- It is also compulsory to report terrorism, potential radicalisation, money laundering and female genital mutilation to the appropriate authorities.
- Other than as required by law, Andrea Szentgyorgyi therapist will routinely discuss your case with her supervisor in order to ensure that you get the best service. The supervisor will have access to your details in order to contact you and offer you ongoing care if Andrea Szentgyorgyi becomes suddenly unavailable. We may talk or write to your GP (but we will not give any personal details beyond what you are working on).
Also, note that we reserve the right to record sessions where it is deemed appropriate, however, we do not give you permission to record the therapy sessions.
Your electronic device may store your messages, back-up files or visited internet sites and that can lead to a history of use being kept on the computer. Make sure you delete your browsing history if you are using a shared device!
11.PAYMENT FOR OUR SERVICES
We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors).
Cancellation and missed session policy
If for any reason you are unable to attend your appointment, please let me know as soon as possible. The required notice for cancellation is forty-eight hours. Where there is less notice of cancellation or if you do not attend your appointment you will be charged the full fee, and we will contact you with the invoice. In certain circumstances, the charging of the total fee can be waived at the discretion of Andrea Szentgyorgyi. With adequate advanced notice, where possible, you will be offered an alternative appointment.
If, for any reason, we need to cancel your appointment, we will endeavour to provide you with as much advance notice as possible.
- DEATH OR INCAPACITY OF THE THERAPIST
If a psychotherapist dies suddenly leaving potentially vulnerable clients, then it is necessary to liaise with and inform outstanding clients of the therapist’s demise.
Therefore, we have arrangements in place to allow an experienced psychotherapist (currently the clinical supervisor) access to our clients` contact details, and he will make contact with outstanding clients and offer the appropriate support and advice. This person would not need access to any confidential client notes.
13. CHANGES TO THIS POLICY