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Jane Rowland CBT

 

PRIVACY POLICY

 

INTRODUCTION​

This Privacy Policy provides you with important information about the collection and processing of your personal information (data) through your use of the therapy services of Jane Rowland CBT. Every effort will be made to ensure that your privacy is protected at all times.

If you have any questions or concerns about this policy, please contact Jane Rowland CBT/your therapist in the first instance to discuss them further.

If you are not satisfied with any aspect of how your data is collected and used, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (email www.ico.org.uk or call 0303 123 1113). Jane Rowland CBT would be grateful if you would discuss the matter first with your therapist so that she can try to resolve it for you.

 

THE LAW

The Data Protection Act (1998) and the General Data Protection Regulation (2018) stipulate that an individual’s information must

  • be collected and used fairly

  • stored safely and not disclosed unlawfully

  • obtained for specific lawful purposes

  • adequate, relevant and not excessive

  • accurate and kept up to date

  • not held for longer than is necessary

  • processed according to an individual’s rights

  • protected in appropriate ways

  • not be transferred outside the European Economic Area (EEA) without an adequate level of protection

 

 

WHAT PERSONAL INFORMATION IS COLLECTED?

There are different categories of data that your information falls into:

  • Identity Data includes your first name, last name, date of birth.

  • Contact Data includes your address, email address and telephone numbers

  • Special Category Data includes information you provide during assessment and thereafter that is necessary for the purposes of providing CBT therapy treatment. This may also include insurer details, GP details, medical records, treatment plans, letters, documentation and communications with other healthcare professionals.

 

HOW IS PERSONAL INFORMATION COLLECTED?

Personal information is collected from you when:

• you communicate with Jane Rowland CBT /your therapist in person, online (via Zoom or Teams), by email, phone or post.

• you request resources be sent to you

• provide feedback

If applicable, personal information will be provided and/or sought from the agency that referred you for therapy.

Personal information about you will not be obtained by any other means, unless that information is needed to protect you or somebody else from harm, or has been deemed necessary in the delivery of your treatment plan with your full knowledge and agreement.

Personal information may be obtained through audio and video recordings of therapy sessions. This will only happen with your explicit consent. Recording sessions, or part thereof, will always be discussed with you beforehand and your verbal consent will be recorded at the beginning of each audio or video recording. Such recordings will be held with the same security measures and procedures as your written records

 

WHY IS PERSONAL INFORMATION COLLECTED?

Data privacy laws allow for the collection and retention of your personal information in a healthcare setting such as that provided by Jane Rowland CBT. This is an important part of the legitimate interest in understanding your needs and delivering the best possible service. Your personal information is confidential and will only be used for the following reasons:

  • to provide and operate the therapy services of Jane Rowland CBT

  • to facilitate communication with you (by phone, email, text or telephone) that you have fully consented to

  • to provide you with ongoing assistance and support

  • to comply with any applicable laws and regulations

  • so that evidence exists about what happened while you were receiving treatment with Jane Rowland CBT

With your consent, you may be contacted once therapy has ended with any follow up information or updates relating to your treatment plan, or services of Jane Rowland CBT.

Your Personal Information may be shared with other organisations if it is decided that not sharing that information may place you, or anybody else at risk of harm.  For example, if you advise that you are a risk to yourself or others, you disclose a child or adult safeguarding concern, or a serious crime.  Information may also be shared if it is demanded by a court of law.

Your Personal Information will not be shared routinely with anybody connected to you (unless explicitly agreed by you), and nobody will be informed routinely that you are attending therapy except for the referring agency (if applicable).

Anonymised information will be shared routinely when discussing casework in regular therapist Clinical Supervision.  No patient-identifiable information will ever be shared as part of this process.

 

HOW LONG WILL YOUR PERSONAL INFORMATION BE KEPT?

Your personal information and therapy records will be kept for 7 years from the date the last record was made.

By law, personal information must be kept about clients (including Special Category, Contact, Identity, Financial and Transaction Data) for six years after they cease being users of Jane Rowland CBT for legal and tax purposes.

Any written notes completed in sessions are anonymised and kept in a folder in a locked cabinet outside of therapy sessions. Other therapy paperwork such as handouts and outcome questionnaires are stored in the same way. Your personal information is also recorded electronically and is held securely on an external hard drive which is kept in a locked cabinet. Any therapy paperwork you complete and send electronically is stored in the same way. The laptop used for online sessions and generating electronic records uses biometric security software that is only accessed by Jane Rowland CBT.

Once the retention period expires, personal information will be safely deleted and destroyed.

 

WHAT ARE MY RIGHTS?

You may exercise certain rights regarding the processing of Personal Information by the Data Controller:

  • Right to withdraw your consent at any time. You have the right to withdraw consent where you have previously given your consent to the processing of your Personal Information.

  • Right to object to the processing of your Personal Information. You have the right to object to the processing of your Personal Information if the processing is carried out on a legal basis other than consent.

  • Right to access your Personal Information. You have the right to learn if Personal Information is being processed by the Data Controller and obtain a copy of the Personal Information being processed.

  • Right to verify and seek rectification. You have the right to verify the accuracy of your Personal Information and ask for it to be updated or corrected.

  • Right to restrict the processing of your Personal Information. You have the right, under certain circumstances, to restrict the processing of your Personal Information. In this case, the Data Controller will not process your Personal Information for any purpose other than storing it.

  • Right to have your Personal Information deleted. You have the right, under certain circumstances, to obtain the erasure of your Personal Information from the Data Controller. However, this does not apply to medical records.

  • Right to receive your Personal Information and have it transferred to another Data Controller. You have the right to receive your Personal Information and, if technically feasible, to have it transmitted to another Data Controller without any hindrance.

  • Right to object. You have the right to bring a claim before your competent data protection authority.

 

DETAILS ABOUT THE RIGHT TO OBJECT

Where Personal Information is processed for the legitimate interests pursued by the Jane Rowland CBT, you may object to such processing by providing a ground related to your particular situation to justify the objection.

You must know that, however, should your Personal Information be processed for direct marketing purposes, you can object to that processing at any time without providing any justification.

 

HOW TO EXERCISE YOUR RIGHTS

Any requests to exercise your rights can be directed to Jane Rowland CBT through the contact details provided in this document. These requests can be free of charge and will be addressed by Jane Rowland CBT within one month.

 

CHANGES TO THIS PRIVACY POLICY

This privacy policy may be modified at any time, so please review it frequently. Changes and clarifications will take effect immediately upon being modified. If material changes are made to this policy, you will be notified that it has been updated, so that you are aware of what information is collected, how it is used, and under what circumstances, if any, it is used and/or disclosed.

 

INFORMATION NOT CONTAINED IN THIS POLICY

More details concerning the collection or processing of Personal Information may be requested from Jane Rowland CBT at any time. Please see the contact information at the end of this document.

 

QUESTIONS AND CONTACT INFORMATION

If you would like to:

  • access, correct, amend or delete any personal information kept by Jane Rowland CBT

  • register a complaint

  • want more information

then please contact Jane Rowland CBT as below.

Name of DATA CONTROLLER:        Jane Rowland

Contact details:

email therapy@janerowlandcbt.co.uk,

or phone 07305 006438

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