DATA PROTECTION POLICY
1. PURPOSE OF THIS NOTICE
This notice describes how and why we collect and use personal data about you, in accordance with the General Data Protection Regulation (GDPR), the Data Protection Acts and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time in the UK (‘Data Protection Legislation’).
2. ABOUT US
Mark Boyden Associates is registered in England and Wales as a limited company under number: 06070779 and our registered office is at Chebbard Farm, Dorchester, DT2 7LW.
Mark Boyden is the ‘data controller’. This means that he is responsible for deciding how we hold and use personal data about you. We are required under the Data Protection Legislation to notify you of the information contained in this privacy notice.
We have appointed a Data Protection Officer, Kate King. She is responsible for assisting with enquiries in relation to this privacy notice or our treatment of your personal data. Should you wish to contact our Data Protection Officer you can do so using the contact details noted at paragraph 10 (Contact Us), below.
3. HOW WE MAY COLLECT YOUR PERSONAL DATA
We obtain personal data about you, for example, when:
~ you request a proposal from us in respect of the services we provide;
~ you engage us to provide our services;
~ you contact us by email or telephone; or
~ provided by third parties (eg a referral from a relative or GP).
4. THE KIND OF INFORMATION WE HOLD ABOUT YOU
The information we hold about you may include the following:
~ your personal details (such as your name and/or address);
~ details of contact we have had with you in relation to the provision of our services;
~ our correspondence and communications with you;
~ clinical notes made by therapists;
~ clinical notes passed by or to your GP or other professionals involved with your care.
5. HOW WE USE PERSONAL DATA WE HOLD ABOUT YOU
We will hold and use your personal data only for the purposes necessary for the provision of our services to you. That is to say the provision of therapy and for the maintenance of your account. Such data will be held securely and only used within MBA and other directly-connected professionals. It will never be shared or used for other purposes. Therapy notes are kept during the therapy to enable the Therapist to reflect and understand the issues. This includes: history of the Patient, identifying symptoms, issues and Patient concerns, psychological formulations and appointment attendance. Therapists may discuss anonymised individual cases with their supervisors. Supervision is a formal process in which a qualified psychotherapist or psychotherapeutic counsellor regularly presents their client work to a supervisor. The main purpose of supervision is to ensure the efficacy of the therapist’s psychotherapy practice which, in turn, will enable a therapist to work towards the best possible psychotherapy practice for their clients.
We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected. Once the therapy ends, personal data is kept up to a period of 5 years.
6. DATA SHARING
Why might you share my personal data?
Therapy is confidential. We will only ever share your personal data with other professionals directly involved in your therapy. Unless there is risk of harm to self or others, a Patient’s GP will be NOT be contacted. Any reports released to other professionals or a court will only be with the Patient’s consent who will receive a copy of those reports. If a Patient requests reports for court a separate fee is charged.
Which third-party service providers process my personal data?
“Third parties” includes third-party service providers and other entities within our company. The following activities are carried out by third-party service providers: IT and cloud services, professional advisory services, administration services. All of our third-party service providers use proprietary industry-standard and appropriate security measures to protect your personal data. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.
7. DATA SECURITY
We have put in place commercially available and appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an un-authorised way, altered or disclosed. In addition, we limit access to your personal data only to those employees and other third parties who have a need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
8. RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Should your personal information change, please notify us of any changes of which we need to be made aware by contacting us, using the contact details below.
Your rights in connection with personal data
You have the right to:
~ request a copy of the personal data we hold about you;
~ request correction of the personal data that we hold about you;
~ request erasure of your personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below);
~ object to processing of your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this basis;
~ request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
Any Subject Access Request in exercise of any of the above rights should be directed to our data protection point of contact at the email/telephone number listed below.
You will not have to pay a fee to access your personal data. However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information. This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
9. RIGHT TO WITHDRAW CONSENT
Where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose you have the right to withdraw your consent at any time. To withdraw your consent, please email our data protection point of contact. Once we have received notification that you have withdrawn your consent, we will no longer process your personal information for the purpose you originally agreed to.
10. CHANGES TO THIS NOTICE
Any changes we may make to our privacy notice in the future will be updated on our website at: www.markboyden.com. This privacy notice was last updated on 6th June 2018.
11. CONTACT US
If you have any questions regarding this notice or the way we process your personal data, please email firstname.lastname@example.org or telephone 02071014300.
You also have the right to make a complaint to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues, at any time. The ICO’s contact details are as follows:
Information Commissioner's Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF
Telephone - 0303 123 1113 (local rate) or 01625 545 745
Website - https://ico.org.uk/concerns