I regard your privacy as very important to me and hold the privacy of your information in the highest regard. By recognising your privacy, our policy is designed to help you to understand how I collect, use and safeguard this information you provide to me and to assist you in making informed decisions when using my sites. When you visit my sites, you may issue me with personal information (a selection of which is detailed below) and this is collected from you as part of a client assessment or for the training company enrolment process and by doing so, you accept this as part of our terms and conditions and knowingly choose to disclose this information. In handling this information, I am bound by three sets of rules, the General Data Protection Regulations (GDPR), insurance company guidelines and my professional body’s code of ethics. This page will explain how these affect the way I work. I do not share any of your details with a third party unless legally required to do so and I indicate reasons for doing so below.
• My company, Piece of Minds Clinical Hypnotherapy & Training School is not registered with the ICO at this time as I do not need to comply with their regulations after taking their on-line assessment. However, although I do not need to comply to the ICO regulations I am putting in place certain policies to improve my business. https://ico.org.uk/ESDWebPages/Entry/ZA230146
• I am both the Data Controller and the Data Protection Officer. My contact details are as follows: Susan May Lawrence, e-mail address is: [email protected], phone 07943728851.
• The information about you that I collect, comes from you, via an email, phone call, or enrolment form (any downloads will be stored in paper format). I have created this policy in order to demonstrate my firm and continuous commitment to the privacy of personal information provided by those visiting and interacting with my sites.
• You have no legal requirement to share information with me but if you choose not to, I will be unable to treat you in my sessions or if you are a potential student, unable to offer you a place on any of my courses.
• The purpose of collecting personal information from you is to provide services or products, process payment, for marketing and promotional efforts in the future, improve the service and also:
o to answer your enquiries via telephone or e-mail;
o to make an appointment for a consultation or provide you with items you have purchased if I decide to do so in the future;
o to request a place on one of my courses, or as a supervisee;
o to provide ongoing support and supervision;
o to enable me to invoice you and receive payment, and to keep proper records and accounts;
o to sign you up for a newsletter in the future if I develop this process, where I can inform you of any new services or special offers I think may be of value to you. You will always have an ‘opt-in’ (subscribe) option on my sites to participate in receiving such information and also an ‘opt-out’ (unsubscribe) option if you no longer wish to receive my mail and this will enable your details to be erased from the marketing database. You therefore are not legally bound to my receive my marketing material and have the right to withdraw at any time by pressing the ‘opt-out’ option.
• The categories of data/information I collect are directly from my application form or from an e-mail request and may include: your name and contact details, your education/employment, and details of any criminal convictions.
• As part of the admission process, you give me permission to hold and use this information in line with these guidelines when you apply to come on any of my courses, or to answer your request for information.
• I keep the information you give me in paperwork format only, for the length of time suggested by my professional body and insurance company for client records- seven years. All paperwork is stored in a safe locked cabinet and I am the only person with access to it. The exception to this rule is for a request for an appointment by clients. I do not keep e-mails and remove them from my inbox/deleted box and these are deleted after three months of receiving them unless there is any particular reason it may be beneficial to hold on to them. My computer has a secure password. Information stored in paperwork format will never have your surname/telephone number on it e.g. my notes or ever booked in my diary with a surname to prevent any person being able to identify you.
• Sharing your information:
o I do not share, sell, lend or lease any information about you to anybody and will at all costs maintain confidentiality. I do my own accounts and therefore your name is not traceable by any other person.
o Legally I would have to share information with an insurance company, governing body or the police that is required for court purposes or when there is good cause to believe that if I do not disclose information, you or others would be exposed to a serious risk of harm.
o However, if I need consent to treat you from your medical practitioner, I would ask for permission before I send any request for consent or information but this has only occurred on a rare occasion.
• My professional body’s code of ethics also allows me to share anonymous case histories verbally or in hypnotherapy publications for the purposes of continuous professional development, supervision or training. Anonymous means your personal details are removed and no information that might identify you is used. If you do not wish your information to be included, please contact me.
• You have rights over the information I hold about you. These are:
o Portability – you can ask me to send your information to someone else;
o Rectification – if you think my records are wrong you can ask me to change them;
o Erasure – in some circumstances you can ask me to remove your details from my records (this is sometimes called ‘the right to be forgotten’);
o Fair profiling – you can ask that any processes I automate are done by a person instead of a computer. I don’t currently automate any information processing, although I may use online forms to collect information about a purchase in the future;
o Right of access – you can have a copy of the information I hold at any time, by requesting it in writing. If you do this it will be provided within 30 days and free of charge. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive and in certain circumstances refuse to comply. To confirm your identity before releasing information we may ask you for certain details as a security measure to prevent any information being given to any person who has no right to receive it. Occasionally it may take longer to comply to a request if it is complex but we will notify you and keep you updated;
o Restricting processing – in some circumstances you can request that I stop processing your information;
o Objection – you can object to the way I process information e.g .I currently do not market via e-mails but if I did in the future, you can ask me to stop using it in this way;
o Information – you have the right to understand how I collect and process your information (hence this privacy notice).
• You can learn more about these rights on https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/ or www.knowyourrights.co.uk
• You can withdraw your permission for me to use your information at any time, although if you are a student, you would be discontinuing your course as I need to keep information about you for the required time set by insurance companies and my governing body.
• If in the future I decide to do any research projects to improve the service I give or for statistical purposes, I will anonymise your personal data to ensure there is no longer any association with yourself. In the future I may also e-mail you to ask if you could participate in a survey. This survey is for the purpose of monitoring and improve the service I give. Participation in these surveys is completely voluntary and therefore it is your choice whether you disclose information but I would be grateful for any input. All disclosure is confidential and stored/used for the purpose it is intended and will not be shared with any third party.
• If you have any problem with the way I store or use your data, or if you do not think your rights are being respected please inform me and we can discuss this in more depth.
• I may need to change this policy from time to time as the business develops or for legal requirements. I will update information in this policy so please check it periodically. If the policy changes in the future, we will in no way use personal data submitted to myself in a manner that is materially inconsistent with this policy and without prior consent.
• From May 25th 2018 the new GDPR regulations become legislation and I will be adding an ‘opt-in’ and ‘opt-out’ option to my e-mails. If you wish to receive any updates/special offers/freebies from me, please click the ‘opt-in’ option.
I hope you have understood this policy but if you require further clarity over anything included here, please contact me and I will be happy to discuss this with you.