Customer privacy notice
This privacy notice tells you what to expect me to do with your personal information.
· Contact details
· What information I collect, use, and why
· Lawful bases and data protection rights
· Where I get personal information from
· How long I keep information
· Who I share information with
· Sharing information outside the UK
· How to complain
Contact details
brooklawsontherapy@protonmail.com
What information I collect, use, and why
I collect or use the following information to provide patient care, services, pharmaceutical products and other goods:
· Name, address and contact details
· Gender
· Pronoun preferences
· Date of birth
· NHS/HSC/CHI number
· Next of Kin details including any support networks
· Emergency contact details
· Health information (including medical conditions, allergies, medical requirements and medical history)
· Information about care needs (including disabilities, home conditions, medication and dietary requirements and general care provisions)
· Test results (including psychological evaluations, scans, bloods, x-rays, tissue tests and genetic tests)
· Payment details (including card or bank information for transfers and direct debits)
· Insurance policy details
· Credit reference information
· Records of meetings and decisions
· Information about income and financial needs for funding or personal budget support
I also collect the following information to provide patient care, services, pharmaceutical products and other goods:
· Racial or ethnic origin
· Religious or philosophical beliefs
· Health information
· Sex life information
· Sexual orientation information
If you decide to use the contact form on my website, your message will be passed on through the Squarespace website directly to my email address. My email address provider is Proton, who have a reputation of being especially data secure. However, please bear in mind that communication via the internet is not 100% safe.
My website collects personal data to power my site analytics, including:
· Information about your browser, network, and device
· Web pages you visited prior to coming to this website
· Web pages you view while on my website
· Your IP address
· This information may also include details about your use of this website, including:
Clicks
Internal links
Pages visited
Scrolling
Searches
Timestamps
We share this information with Squarespace, our website analytics provider, to learn about site traffic and activity. Squarespace needs the data to run my website, and to protect and improve its platform and services. Squarespace analyses the data in a de-personalised form.
My website uses cookies and similar technologies, which are small files or pieces of text that download to a device when a visitor accesses a website or app. The necessary and required cookies are always used, which allow Squarespace, my hosting platform, to securely serve this website to you. The analytics and performance cookies are only used on this website when you acknowledge my cookie banner. My website uses analytics and performance cookies to view site traffic, activity, and other data.
Lawful bases and data protection rights
Under UK data protection law, I 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 I rely on may affect your data protection rights which are in brief set out 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 me for copies of your personal information. You can request other information such as details about where I get personal information from and who I 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 me to correct or delete personal information you think is inaccurate or incomplete.
- Your right to erasure - You have the right to ask me to delete your personal information.
- Your right to restriction of processing - You have the right to ask me to limit how I 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 I transfer the personal information you gave me to another organisation, or to you.
- Your right to withdraw consent – When I use consent as my lawful basis you have the right to withdraw your consent at any time.
If you make a request, I must respond to you without undue delay and in any event within one month.
To make a data protection rights request, please contact me using the contact details at the top of this privacy notice.
My lawful bases for the collection and use of your data
My lawful bases for collecting or using personal information to provide patient care, services, pharmaceutical products and other goods are:
· Consent – I have permission from you after I 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 – I have to collect or use the information so I can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
My lawful bases for collecting or using personal information for analytical purposes on my website are:
· Consent - I have permission from you after I 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.
Where I get personal information from
· Directly from you
· Regulatory authorities
· Family members or carers
· Other health and care providers
· Social services
I will only inquire about personal information about you from other parties than yourself, after we have discussed this and with your permission. For example, this could be related to a discharge summary from your most recent hospital stay, allowing us to continue where your previous treatment left off.
How long I keep information
At the end of our therapy contract your data (e.g. email exchanges, my notes on our process, etc.) will be stored securely for a period of 5 years and then destroyed or deleted after this time.
Who I share information with
Data processors
Squarespace, Inc.
This data processor does the following activities for me: They are an American website building and hosting company and host my website.
Proton AG
This data processor does the following activities for me: They are a Swiss email address provider and I use their service for professional communication via email.
Others I share personal information with
· Other health providers (e.g. GPs and consultants)
· Insurance companies, brokers and other intermediaries
· Organisations I need to share information with for safeguarding reasons
· Emergency services
· Legal bodies or authorities
Duty of confidentiality
I am subject to a common law duty of confidentiality. However, there are circumstances where I will share relevant health and care information. These are where:
· you’ve provided me with your consent (I have taken it as implied to provide you with care, or you have given it explicitly for other uses);
· I 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);
· the requirements of The Health Service (Control of Patient Information) Regulations 2002 are satisfied.
Sharing information outside the UK
Where necessary, my data processors may share personal information outside of the UK. When doing so, they 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 me using the contact information provided above.
Organisation name: Squarespace, Inc.
Category of recipient: Website building and hosting company
Country the personal information is sent to: USA
How the transfer complies with UK data protection law: The country or sector has a UK data bridge (also known as Adequacy Regulations)
Organisation name: Proton AG
Category of recipient: Email address provider
Country the personal information is sent to: Switzerland
How the transfer complies with UK data protection law: The country or sector has a UK data bridge (also known as Adequacy Regulations)
How to complain
If you have any concerns about my use of your personal data, you can make a complaint to me using the contact details at the top of this privacy notice.
If you remain unhappy with how I have used your data after raising a complaint with me, 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
Website: https://www.ico.org.uk/make-a-complaint
Last updated
20 August 2024