Privacy Policy

The details of our Privacy Policy are below, please read carefully
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Information Governance Policies and Procedures

This Information Government document is a framework that details the management of information within

Therapy 4 Stress. Information governance balances the use and security of personal information and helps with legal compliance and operational transparency. This document details how Therapy 4 Stress handles electronically stored information and our Privacy Policy is contained herein.

Contents

Section A

  • Introduction
  • Aim and Purpose
  • Information Governance Framework Principles for Therapy4stress

Section B

  • Privacy Notice: Use of Information
  • Retention Schedule
  • Data Processing

Section C

  • Data breach
  • Subject Access Request
  • Right to Erasure
  • Complaints
  • Safeguarding Your Privacy

Section A

Introduction

Data held by Therapy4stress will be held lawfully and for the retention periods set out in Section B of this policy document.

This document refers to:

  • Written Documents
  • Spreadsheets
  • Hardcopy case notes and files
  • Database entries
  • Images
  • Recordings
  • Emails
  • Text messages
  • Supervision notes
  • Visits to the organisations website
  • Social media communication

Aim and Purpose

The purpose of this document is to ensure that Therapy4Stress, has a framework that ensures the rights and freedom of individuals in relation to their personal data (Article 1 of the GDPR) and adheres to best practice in the management of client information and business records.

Information Governance sets out the way in which information collated by an organisation is managed and ensures that any information collected;

  • is the right information
  • is in the right place
  • at the right time
  • with the right people
  • for the right reasons

This is a live document and may be updated at any time to reflect changes in law or growth of the business, and therefore will be revisited regularly to check for any updates. Therapy 4 Stress is fully committed to ensuring clients’ privacy and data protection rights.

For the purpose of this policy Renie Price is the named Data Protection Officer/Controller and Head of Organisation.

Information Governance Framework Principles for Therapy 4 Stress

  1. Assessment needs for Information Governance (IG) Training have been identified and fully met, with a 75 minute GDPR CPD Course provided by the Clinical Hypnotherapy School (www.clinicalhypnotherapyschool.com) completed. Refresher training is completed every two years.
  2. Any changes to the business processes and/or operations will be planned and will comply with the framework to ensure any risks to personal and sensitive information are minimised.
  3. Any data collected is solely for the purpose of providing a person-centred service to an individual client.
  4. The Caldicott Principles are used to provide guidance in best practice when handling personal data, alongside the ICO’s Office Codes of Practice. (https://www.igt.hscic.gov.uk/Caldicott2Principles.aspx)
  5. All technology [Microsoft Office products including Outlook] used to store or facilitate information and communication is maintained according to the Data Retention Policy for Therapy 4 Stress.
  6. All records are identifiable, locatable, retrievable, and intelligible according to regulations set out by GDPR.
  7. It is the responsibility of the Data Controller to ensure sufficient resources are in place to prioritise adhering to Data Protection Legislation in the business.
  8. Any electronic devices where personal or sensitive, confidential information is held will be password protected. Individual documents stored electronically will also contain individual passwords.
  9. Procedures have been put in place to ensure the General Data Protection Regulations are met. These can be found in Section

Section B

Privacy Notice: Use of information

In accordance with this data retention schedule there may be occasions when data is not destroyed due to ongoing investigation, ligation or enquiry. The data will be deleted upon confirmation that it is no longer required. 

On some occasions anonymised personal data will be retained whereby a client has provided a testimonial for use on the organisations website. When data is non-identifiable GDPR law is no longer applicable. [Non-identifiable means that if this data was, for example, left on a bus, no one, including the data subject would be able to identify that this data was relating to them.]

  • Personal information is collated and stored in hardcopy in a locked filing cabinet behind a locked door.  
  • Any document containing personal data will state “Official-sensitive, private and confidential” clearly.
  • All emails will contain a privacy statement.

Under the General Data Protection Regulations (2018), regarding how your personal data is processed, all individuals have;

  • the right to be informed;
  • the right of access;
  • the right to rectification;
  • the right to erasure;
  • the right to restrict processing;
  • the right to data portability;
  • the right to object; and
  • the right not to be subject to automated decision-making including profiling.

Please note that Therapy 4 Stress does not use automated decision-making tools, including profiling.

Website visitors

When an individual visits www.therapy4stress.com  Google analytics are used, this is considered a third party service, to collect information about what visitors do when they click the website, e.g. which page they visit the most. Google analytics only collect non-identifiable data which means neither Therapy4Stress or Google analytic are able to identify who is visiting.

Therapy4stress will always be transparent when it comes to collecting personal data and will be clear about how that data is processed.

JohnLawley.co.uk is a third-party service that hosts the Therapy 4 Stress website. The hosting service also uses anonymised data to collect visitor information such as how long an individual remains on a page of a website. The JohnLawley.co.uk privacy notice can be found here for further information: https://johnlawley.co.uk/privacy-cookies/

Social Media

Therapy 4 Stress uses third-party providers, to manage some of its social media interactions. Any messages sent to the inbox of social media accounts are stored by the social media platform. Their Privacy notices can be found here:

https://www.facebook.com/about/privacy
https://twitter.com/en/privacy
https://twitter.com/en/privacy

Retention Schedule

 Information AssetInformation Owner AssetRetentionTrigger for Disposal
Email (including sent items)Head of organisationAnnual review period every January, any remaining live data untouched until following review period.End of retention period
Contact details held on mobile devicesHead of organisationAll entries to be deleted prior to decommissioning of mobile device or reissue of deviceEnd of retention period
RecordingsHead of organisation5 years or earlier if consent is withdrawnEnd of retention period
Images takenHead of organisation5 years or earlier if consent is withdrawnEnd of retention period
Promotional materialsHead of organisationUntil superseded – Consent to be rechecked prior to reissueEnd of retention period
Paper DiariesHead of organisation3 months from the period in which its use ends.End of retention period
PoliciesHead of organisationUntil new policy has been put into placeEnd of retention period
Client records including session notes, initial consultation notes and client overview formHead of organisationIn accordance with CNHC regulation, 8 years after final treatment session has ended. Child records should be held until after 25th birthday, or 26th birthday if aged 17 when treatment ends.End of retention period
Safeguarding recordsHead of organisationIn accordance with the current organisations insurance policy, 5 years after final treatment session has ended, unless superseded by new insurance policy.End of retention period
Sat Nav recordsHead of organisationAll entries to be deleted prior to decommissioning of mobile device or reissue of deviceEnd of retention period
Waiting listsHead of organisationAnnual review period every January, old waiting list destroyed, and new waiting list developed with any remaining live data transferred to new live document.End of retention period
Continual Professional Development RecordsHead of organisationTo be retained when worker is in service and until 8 years afterwards.End of retention period
Worker supervision recordsHead of organisation and workers supervisorTo be retained when worker is in service and until 8 years afterwards.End of retention period
Service evaluation recordsHead of organisationTransfer to anonymised data within 6 months of collection.End of retention period
Tax returnsHead of organisation6 years from the end of the financial period to which they pertain to.End of retention period
Incident/Accident reportsHead of organisation40 years from date report was closedEnd of retention period
Insurance policiesHead of organisation40 years from date policy ended.End of retention period
ComplaintsHead of organisation2 years from complaint being resolvedEnd of retention period
Right to Erasure RequestHead of Organisation8 years from request being submitted and completed.End of retention period
Subject Access RequestHead of organisation8 years alongside session notes, or plus 2 years from case closure if request is made after 6 years of storing data.End of retention period

Hard copy data will be destroyed via a cross shredding machine owned by the organisation, electronic data will be permanently deleted.

Data Processing

Processing Data at Therapy 4 Stress within the current law:

  • In relation to communicating with my clients, the individual has given clear consent for their data to be processed for the specific purpose(s) detailed in the consent form stored in their personal file.
  • Processing is undertaken in order to protect the vital interests of the data subject or of another natural person.
  • Processing is undertaken for your legitimate interests as specified in Article 9 of the GDPR:

Art.9 GDPR Processing of special categories of personal data

  1. Processing of personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation shall be prohibited.
  2. Paragraph 1 shall not apply if one of the following applies:
  • processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of Union or Member State law or pursuant to contract with a health professional and subject to the conditions and safeguards referred to in paragraph 3;
  • Personal data referred to in paragraph 1 may be processed for the purposes referred to in point (h) of paragraph 2 when those data are processed by or under the responsibility of a professional subject to the obligation of professional secrecy under Union or Member State law or rules established by national competent bodies or by another person also subject to an obligation of secrecy under Union or Member State law or rules established by national competent bodies.

This means that Therapy 4 Stress does not require consent to hold your data to provide a service but does require your consent to contact you for specific purposes. Participating in the service by attending more than one appointment implies that you agree with the Terms and Conditions provided to you at the commencement of service delivery.

Description of processing

The following is a broad description of the way this organisation/data controller processes personal information. Clients wishing to understand how their own personal information is processed may choose to read the Terms and Conditions for treatment document, which compliments the policies detailed here.

Reasons/purposes for processing information

Therapy 4 Stress processes personal information to enable the provision of Hypnotherapy, to advertise services and to maintain accounts and records.

Type/classes of information processed

Therapy 4 Stress processes information relevant to the above reasons/purposes. This information may include:

  • personal details
  • family, lifestyle and social circumstances
  • goods and services
  • financial details
  • employment and education details

Therapy 4 Stress also processes sensitive classes of information that may include:

  • physical or mental health details
  • racial or ethnic origin
  • religious or other beliefs of a similar nature
  • offences and alleged offences

Therapy 4 Stress processes personal information about:

  • clients
  • suppliers
  • business contacts
  • professional advisers
  • supervisors

Section C

Data Breach

All personal and sensitive data held by Therapy 4 Stress is held securely. Electronic data stored on a computer is stored on a password protected computer, in password protected documents held on One Drive. This supports the ability to retrieve data in the event of faults. Hardcopy data is held securely in a locked cabinet behind a locked door.

In the case of a data breach Therapy4Stress shall comply with the regulations set out under Article 33 of the GDPR;

1. In the case of a personal data breach, the data controller shall without undue delay and, where feasible, not later than 72 hours after having become aware of it, notify the personal data breach to the ICO, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of the individual. Where the notification to the ICO is not made within 72 hours, it shall be accompanied by reasons for the delay.

2. The notification referred to in paragraph 1 shall at least:

(a)  describe the nature of the personal data breach including where possible, the approximate number of data subjects concerned and the categories (e.g. sessions notes, phone numbers) and approximate number of personal data records concerned;

(b)  communicate the name and contact details of the data controller where more information can be obtained;

(c)  describe the likely consequences of the personal data breach;

(d)  describe the measures taken or proposed to be taken by the controller to address the personal data breach, including, where appropriate, measures to mitigate its possible adverse effects.

4. Where, and in so far as, it is not possible to provide the information at the same time, the information may be provided in phases without undue further delay.

5. The controller shall document any personal data breaches, comprising the facts relating to the personal data breach, its effects and the remedial action taken. That documentation shall enable the supervisory authority to verify compliance with this Article.

6. In the event that a data breach will likely cause a risk to the rights and freedoms of client data, the data controller must communicate the nature of the breach in clear, concise and plain language, to the client/s involved, without delay.

7. If a breach occurs but the data controller has gone to appropriate lengths to protect the data held on the client (e.g. password encryption of electronic files), or if the data controller has taken subsequent action to prevent the risk (e.g. immediately blocking a mobile device) then notifying the client will not be required.

Subject Access Request

A Subject Access Requests (SAR) permits individuals to request a copy of their personal information.

A SAR must be acted upon within one month, at the most within two months, any longer and reasonable reason must be provided. There are no fees unless there is a disproportionate fee to the organisation for sending out the information. Application for SAR should be held alongside session records unless application was made after six years of the end of treatment. In which case the SAR will be held for a further two years after closure of SAR.

A SAR request will include information we hold about you, Therapy 4 Stress will:

•          provide a description of it;

•          give information as to why we are holding it;

•          supply information as to whom it could be disclosed to; and

•          provide a copy of the information in an intelligible form.

SAR requests should be put in writing to Therapy 4 Stress. A response may be provided informally over the telephone with your agreement, or formally by letter or email. If any information held is noted to be incorrect an individual can request a correction be made to their own personal information. This should be made in writing to Therapy 4 Stress

Right to Erasure

Any person may put in a request for their personal data to be removed (the ‘right to be forgotten’ or the ‘right to erasure’). In this instance hard copy data will be shredded using a cross shredding machine owned by the organisation and any electronic data will be permanently deleted. The client will be notified of the completion. The request for deletion of data and the confirmation of completion will be held securely until eight years after the request was made.

Complaints

Therapy 4 Stress hopes to the meet the highest quality standards when processing personal and sensitive data. Complaints can help identify areas for improvement and therefore Therapy 4 Stress would welcome any comments and concerns you may have.

The Information Governance Policy documents were created to be as transparent and understandable as possible. It is not be completely exhaustive of all aspects of data collection. If you would like further information about a specific process, please contact Therapy 4 Stress.

If you feel you would like to make a complaint about how your personal and sensitive data is handled by Therapy 4 Stress, you can contact Therapy 4 Stress directly. In the event that Therapy 4 Stress cannot resolve your complaint to your satisfaction you can contact the Information Commissioners Office on 0303 123 1113.

Safeguarding your privacy

In the event of Renie Price’s death, (the author of this document), my supervisor will contact existing clients and archive any client files in accordance with General Data Protection Regulations.

Fiona Kiddle

Many people experience anxiety, inability to sleep, lack of self-esteem and confidence especially when they are faced with a diagnosis of cancer. Renie has been instrumental in helping many of our member’s through these difficulties. She is a reliable and trustworthy worker and has become an important part of the team here at Cherry Lodge Cancer Care. I would highly recommend Renie to anyone, or any organisation that is looking to address the psychological needs …

Paula

I wanted to write and thank you, for changing my life. I don’t think you will ever completely understand what you have done for me. I have suffered from a needle phobia all my life and simple blood test would reduce me to panic and tears. I came to see Renie and she talked me through the technique, but I wasn’t convinced that one session would be so life changing. After one session, I went …

A-M Woods

As a doctor, I felt sceptical, even suspicious about the use of complimentary therapies. Unless there was a tablet I could throw at the situation, I wasn’t interested. I started seeing Renie at my local cancer support centre upon the suggestion of a Macmillan nurse. I was highly anxious and felt very bleak at the time. I started hypnotherapy with Renie and the effect was dramatic and immediate. The experience was positive and calming. I …

SaraC-160

Went to see Rene not knowing what to expect, this lady has changed my life for the better. There is homework but that only takes a few minutes. Rene has the ability to make you feel calm and safe. I highly recommend her services, worth every penny. Thank you once again

SilverTelevision91-2

I came to see Renie at possibly one of the hardest times of my life. I had a lot of fear and stress over a recent diagnosis. Renie’s approach was both down to earth and practical. It helped me put everything into perspective and in turn made it all manageable. It felt like a weight had been lifted off me. So much so that some of my physical symptoms abated a little also. With a …

Kerri Lendon

Absolutely brilliant! Renie made me feel so at ease from the very first session, listened, understood me and we agreed the next steps together. The therapy has been so helpful to me, it was made clear to me that I had to invest in my journey, which I did, but Renie was supportive every step of the way. The therapy has made a real difference to my every day life. Can’t speak highly enough of …