What is it?
This privacy policy is about information which Manderlay Therapy uses, maintains and discloses, information collected from clients (people who use my psychotherapy and counselling, also referred to as therapy) using Manderlay Therapy. The policy applies to the practice, website, telephone and services offered by manderlaytherapy.com
The owner and data controller is Anoushka Beazley, ICO registration reference: 00013300516, email: hello@manderlaytherapy.com. 

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What information is collected?
Any information that can be used to identify a living person. Name, marital status, occupation, address, title, date of birth, gender, email, telephone, next of kin, counselling history, GP details, medical conditions, medications, qualifications, education, financials, religion, sexual preferences, philosophical beliefs, ethnic origins.

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How we get the information and why we do we have it?
Information is collected via contracts and agreement forms. Through communication via telephone or email. Any email sent to me, including any attachments, maybe monitored and used by me for reasons of security. SPAM protection. 
Data is collected in order for me to provide the best possible service to my clients as well as for use in communication, responding to enquiries and sending messages.
Data transfers in terms of location will depend on your location at the time. Similarly, it will also depend on my location at the time including if we are in different countries. 

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Who is information shared with?
I share information in clinical supervision to ensure my practice remains safe & ethical for the purposes of my own professional obligations with respect to my professional role.    
Therapeutic Will: Your name & contact details will be shared with my Therapeutic Executor so that in the unlikely event of my sudden death you can be contacted should you still be in therapy with me. My Therapeutic Executor will sign a confidentiality agreement document.
Emergencies: If your health is in jeopardy I may share your details with a healthcare service such as your GP or Mental Health Crisis Team.
Relevant bodies or organisations where I may be legally obliged to do so.

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How the information is stored?
Handwritten notes pertaining to sessional content & personal details are kept separate in a locked cabinet.
Smart phone: My smart phone is locked & is only accessible using a security code. I store your contact number but I do not save any names to numbers, only initials. 
Email /Txts: Email addresses are stored in my iOS/Mail account. Text messages are only assigned to initial, not names.
Website: No personal information is stored on my website other than to momentarily collect & send enquiries to my iOS/Mail account for initial contact purposes.
All electronic enquiries are erased after 3 months. All texts & contact numbers are erased 3 months following the cessation of therapy. 
I hold your written information for up to 7 years following the cessation of therapy. This is so I have a reference should you decide to return to therapy in the future as well adhering to the terms and conditions of my professional indemnity insurance.

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How do I contact the ICO?
If you are not happy with any aspect of how I collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). I would be grateful if you would contact me first if you do have a complaint so that I can try to resolve it for you.

 

Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

Helpline number: 0303 123 1113

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What is the legal bases for processing data?
Users have given their consent for one or more specific purposes;
•    Provision of Data is necessary for the performance of an agreement with the User and any pre-contractual obligations;
•    Processing is necessary for compliance with a legal obligation to which the Owner is subject;
•    Processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party;
Upon request, the Owner will help to clarify the specific legal basis that applies to the processing if there is any concern.

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What are your rights?
Right to Access: You have the right to ask for a copy of your personal information, free of charge, in an electronic or paper format. You also have the right to ask me to amend or change any incorrect information about you.
Right to be Forgotten: You have the right to ask me to erase any information that I hold about you. This includes your personal information that is no longer relevant to original purposes, or if you wish to withdraw consent. In all cases and when considering such requests, these rights are obligatory unless it’s information that I have a legal obligation to retain.
Data Portability: As the client, you have the right to receive your personal information which you previously provided, also you have the right to transfer that information to another party.  
These rights are subject to various legal exceptions. If you make any of the requests above I would inform you if I have relied upon any of these exceptions.
 
August 2020

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