Privacy Policy and Data Retention Statement-Effective from 25th May 2018

I aim to be fully compliant with current GPDR legislation and to let you know how I use and protect the data you’ve given me. GDPR replaces the previous Data Protection Act. I wish to be transparent with regard to the processes I have in place. Identifiable information, if shared, will only be used in accordance with this privacy statement. I follow guidance from my governing bodies the UKCP and my insurers Towergate Insurance.

As a private practitioner, I’m considered the data processor and controller in my practice. As the data controller, I process some of your personal data. During the assessment process information such as next of kin, family members and medication are gathered and held. This is anonymised, coded and securely stored. No one but me can access this information. As a therapist I am registered with the Information Commissioner’s Office (ICO).

Data Processing means obtaining, recording or holding information. The definition is very wide, and most of what I do involves a degree of processing. I process the personal data I have collected as controller. I maintain records of personal data and processing activities and hold responsibility should there be a breach.

Consent.
This is a primary concern and is separate to other terms and conditions. As my client, you can withdraw consent at any time. I hope to offer you choice and control. As a therapist who occasionally uses creative interventions, I want to ensure you know that any drawings or art done in session is yours. I will store this material safely and dispose of it in a timely manner. I will never use any of your data/artworks for writing, publishing, research or training purposes.

I have weekly ongoing supervision to support and ensure my practice is safe. When I share client material or images this is always done confidentially, protecting your identity. Nobody but me has access to any of your data. I will keep this process under review and refresh it if anything changes.

Note keeping.
I do not keep process notes and I keep minimal content notes which I hold for seven years. After this time frame, they’re disposed of securely. You have a right to see the information I hold about you should you wish to. You can also ask me to delete all/any of the information that I hold. There are however some details I need to keep due to legal and professional obligations.

Data Storage.
I promise to keep all sensitive data safely. This involves my anonymising, using passwords and encrypted documents. I keep all sensitive data in a place where only have access. I dispose of data by shedding information. I will dispose of emails with clients on a 6 monthly basis.

While we work together I will store your name and phone number on my smartphone. I only contact you in response to you or concerning appointments. When we discontinue working I will delete your number. I do not engage with clients through any social media.

The ICO
You can contact me directly regarding information I hold regarding our work. And if we cannot resolve this you could then contact the Information Commissioner Office ( ICO). I am registered with them https://ico.org.uk/concerns/handling/ or Guidance for GDPR Compliance.

Clinical will
In the event of a sudden cessation of practice eg through an accident or death, I have appointed a professional executor who manage things on my behalf. This is arranged for your welfare as my client and every step is taken to ensure GDPR standards are met.

Agreement
Having read, understood and discussed the above, both parties are satisfied with regard to consent and the data and privacy policies. We agree on why I have collected and kept specific data and what I do with it. You may withdraw consent at any time without detriment. I will regularly review consent with you to check that the relationship, the processing and the purposes have not changed.

1. WHAT WE COLLECT
We may collect the following information: a) Name, b) Contact information including email address and, in some instances, telephone number, c) Demographic information such as postcode d) recipient names, addresses e) IP address f) details of the device with which you transacted with us g) your browsing history on our website or app.

We use different methods to collect data from and about you including through you using our website, filling in forms or by corresponding with us by post, phone email or otherwise. We may also collect data from you by using cookies. For the exhaustive list of cookies we collect see the ‘How we use Cookies’ section.

To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or fraud detection information, from third party service providers and/or partners, and combine it with information we have about you in order to improve the service and marketing that you receive from RobertCumingTherapy.

2. WHAT WE DO WITH THE INFORMATION WE GATHER
We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:

Where the information is necessary for the adequate performance of the contract between you and us for us to provide our services

For customer service and resolution purposes

Internal record keeping.

We may use the information to improve our products and services.

We may periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided and we may personalise such content based on what we believe may be of interest to you.

From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone or mail.

We may use the information to customise the website or app according to your interests.

We may use the information to send you relevant, personalised communications by post in relation to updates, offers, services and products. We’ll do this on the basis of our legitimate business interest. You are free to opt out of hearing from us by post at any time by writing to or emailing us at contact@robertcumingtherapy .co.uk

From time to time, we may use remarketing and behavioural targeting services. In order to do these, we collect cookies and usage data as described below in the “How We Use Cookies” section. These cookies connect activity on this website or app with select advertising networks.

We may use the information for the purposes of fraud detection and prevention and enhancing safety on our website and app.

We have a legitimate interest in obtaining and using the information as set out above in being able to provide and improve the service and marketing that you receive from Robert Cuming Therapy. You can opt-out of receiving marketing communications from us by following the unsubscribe instructions included in our marketing communications or changing your notification settings within your Account.

3. WHO WE SHARE YOUR INFORMATION WITH

In order to provide our services, we may need to provide your information to our trusted third party partners, for example:

Our supply and fulfilment partners in order to ensure we can process and complete your order;

Our marketing partners in order to offer you services and products that may be of interest to you;

Our technology partners to ensure we can provide a safe and secure site and improve the performance and relevance of our site to you;

Our customer service platform providers so you can interact with our customer service team;

Our professional services partners in order to comply with our legal obligations;

It is possible we could sell our business to a third party or re-organise our business or become insolvent. In that scenario, our database of customers is one of the biggest parts of that business and so we would need to share it with the third-party buyer and their advisers. This is in the legitimate interests of selling our business. We may also expand our group of companies and in this scenario we may share your data within our group in order to improve our products and services and because of some of our internal support services may be shared across the group. This is in our legitimate interests of cost efficiency and growing our business. Where this occurs, we will post a link to all group companies and their locations in this Privacy Policy and they will use it in the ways set out in this Policy;

We will cooperate with all third parties to enforce their intellectual property or other rights. We will also cooperate with law enforcement requests from within or outside your country of residence;

Where you have consented to such, our competition and brand partners

From time to time, we may need to transfer your data to trusted third party partners in countries outside of the EU in order to complete the activities listed above. In such an event, we will ensure that those third party partners comply with all relevant data protection legislation in force in the EU from time to time.

4. SECURITY
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

HOW WE USE COOKIES
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website and app in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website and app, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website and app. The ICO provide an extensive explanation of the ways that you can block cookies, please visit https://ico.org.uk/for-the-public/online/cookies/ for more information on how to block cookies.

Specific cookies that may be used on our site include. The table below lists the cookies we collect and what information they store.

This website uses cookies. We use cookies to provide social media features and to analyse our traffic. We also share information about your use of our site with our social media, advertising and analytics partners who may combine it with other information that you’ve provided to them or that they’ve collected from your use of their services. You consent to our cookies if you continue to use our website.

Cookies are small text files that can be used by websites to make a user’s experience more efficient.

The law states that we can store cookies on your device if they are strictly necessary for the operation of this site. For all other types of cookies we need your permission.

This site uses different types of cookies. Some cookies are placed by third party services that appear on our pages.
This website uses cookies. We use cookies to do things like understanding which sections of the website you find most interesting and useful. If you’re happy with the use of cookies by Robert Cuming Therapy and selected partners, click OK.

Cookies are small text files that can be used by websites to make a user’s experience more efficient.

The law states that we can store cookies on your device if they are strictly necessary for the operation of this site. For all other types of cookies we need your permission.

This site uses different types of cookies. Some cookies are placed by third party services that appear on our pages.

Your consent applies to the following domains: www.robertcumingtherapy.co.uk
This website uses cookies. We use cookies to do things like helping our team to understand which sections of the website you find most interesting and useful. If you’re happy with the use of cookies by RobertCumingTherapy and selected partners, click OK. You consent to our cookies if you continue to use our website.

Cookies are small text files that can be used by websites to make a user’s experience more efficient.

The law states that we can store cookies on your device if they are strictly necessary for the operation of this site. For all other types of cookies we need your permission.

This site uses different types of cookies. Some cookies are placed by third party services that appear on our pages.

You can at any time change or withdraw your consent from the Cookie Declaration on our website.

Learn more about who we are, how you can contact us and how we process personal data in our Privacy Policy.

Your consent applies to the following domains: robertcumingtherapy.co.uk

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