Holden Place Therapy Customer Privacy Notice
This privacy notice tells you what to expect us to do with your personal information.
Contact details
What information we collect, use, and why
Lawful bases and data protection rights
Where we get personal information from
How long we keep information
Who we share information with
Sharing information outside the UK
How to complain
Contact details
Email: support@holdenplacetherapy.co.uk
What information we collect, use, and why
We collect or use the following information to provide patient care, services, pharmaceutical products and other goods:
Name, address and contact details
Date of birth
Health information (including medical conditions, allergies, medical requirements and medical history)
Records of meetings and decisions
We also collect the following special category information to provide patient care, services, pharmaceutical products and other goods. This information is subject to additional protection due to its sensitive nature:
Health information
We collect or use the following personal information for information updates, marketing or market research purposes:
Names and contact details
Addresses
Marketing preferences
Lawful bases and data protection rights
Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:
Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for.
Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete.
Your right to erasure - You have the right to ask us to delete your personal information.
Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information.
Your right to object to processing - You have the right to object to the processing of your personal data.
Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you.
Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time.
If you make a request, we must respond to you without undue delay and in any event within one month.
To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.
Our lawful bases for the collection and use of your data
Our lawful bases for collecting or using personal information to provide patient care, services, pharmaceutical products and other goods are:
Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Our lawful bases for collecting or using personal information for information updates, marketing or market research purposes are:
Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Where we get personal information from
Directly from you
How long we keep information
Data retention
We keep personal information, including therapy records and contact details, for 7 years after the end of therapy in line with professional and insurance requirements.
Records are stored securely and are securely deleted or destroyed once this period ends.
Marketing contact details are kept only while consent is in place and are removed immediately if consent is withdrawn.
For more information on how long we store your personal information or the criteria we use to determine this please contact us using the details provided above.
Who we share information with
Data processors
Squarespace
This data processor does the following activities for us: I use Squarespace to manage online bookings. Squarespace acts as a data processor and only processes personal information on my behalf in line with data protection law.
Others we share personal information with
Organisations we need to share information with for safeguarding reasons
Organisations we’re legally obliged to share personal information with
Duty of confidentiality
We are subject to a common law duty of confidentiality. However, there are circumstances where we will share relevant health and care information. These are where:
you’ve provided us with your consent (we have taken it as implied to provide you with care, or you have given it explicitly for other uses);
we have a legal requirement (including court orders) to collect, share or use the data;
on a case-by-case basis, the public interest to collect, share and use the data overrides the public interest served by protecting the duty of confidentiality (for example sharing information with the police to support the detection or prevention of serious crime);
If in England or Wales – the requirements of The Health Service (Control of Patient Information) Regulations 2002 are satisfied; or
If in Scotland – we have the authority to share provided by the Chief Medical Officer for Scotland, the Chief Executive of NHS Scotland, the Public Benefit and Privacy Panel for Health and Social Care or other similar governance and scrutiny process.
Sharing information outside the UK
Where necessary, we will transfer personal information outside of the UK. When doing so, we comply with the UK GDPR, making sure appropriate safeguards are in place.
For further information or to obtain a copy of the appropriate safeguard for any of the transfers below, please contact us using the contact information provided above.
Organisation name: Squarespace, inc
Category of recipient: Website hosting and online booking platform (data processor)
Country the personal information is sent to: USA
How the transfer complies with UK data protection law: Addendum to the EU Standard Contractual Clauses (SCCs)
How to complain
If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.
If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
