Privacy Policy

 


What this Privacy Policy covers

This Privacy Policy gives you information about how I, Catherine Keightley, treat personal information I receive about you from the following sources:

  1. contacts and enquiries submitted through my website (http://theanchorage.london/)
  2. telephone calls or email;

Please read the following sections carefully to understand how your personal information will be used and handled by me.

I collect and use your data in accordance with current data protection law (which includes, from 25 May 2018, the General Data Protection Regulation (Regulation (EU) 2016/679)) (” data protection law “).

Who I am

The data controller with control of your personal information is Catherine Keightley, Parkshot House, Kew Road, Richmond, TW9 2PR.

The Data Protection Officer is Catherine Keightley of Parkshot House, Kew Road, Richmond, TW9 2PR.

My Website may, from time to time, contain links to and from other websites. Please note that those websites will have their own privacy policies and I do not accept any responsibility or liability for such policies / websites. Please check these other policies before submitting any personal information to those websites.

Intermediaries

If you are an intermediary acting for an individual and you provide that individual’s personal information to me via my Website, over the phone or by other means, then you warrant and confirm that you are supplying their information in accordance with the data protection law and that you have first drawn their attention to this Privacy Policy. Please refer to your Intermediary Terms of Business for further information concerning your data protection obligations.

If you are an individual and a third party is authorised to supply your personal information to me in accordance with data protection law, then this Privacy Policy refers to that third party as an ”authorised intermediary “.

For the avoidance of doubt, the terms of this Privacy Policy concern the relationship between me and you, not the relationship between your authorised intermediary and you. If you have any questions about how your authorised intermediary processes your personal information, please speak to them directly. 

Information: Collection, Use and Grounds for Processing / Storage

I collect, process and store information about you from a variety of sources. These are summarised below:

i. Information you give to me:

This includes information about yourself which you provide to me by written contract, email, phone call, text message, face to face meetings.

The information you give me may include (but is not limited to) your name, address, email address, phone number, date of birth, gender and personal descriptions.

Information you give me face to face might also include more sensitive personal information, which helps determine whether I can offer suitable support for you.

I process / store this information to:

(a) supply you with details of services you have contacted me about;

(b) check your eligibility and suitability for services I offer and to notify you of what services I can offer you.

(c) manage your contact with me (including session bookings, payment handling and any other relevant communication relating to any service/s you have contacted me about) and to respond to you when you contact me;

(d) notify you of any changes to services, procedures and terms (including material changes to this Privacy Policy) from time to time;

(e) comply with record keeping and regulatory compliance obligations; and

I process / store this information on the following grounds:

(i) because the processing is necessary for me to provide you with service you have requested;

(ii) because, in certain cases, the processing is necessary for me to comply with my legal obligations, for example where regulations oblige me to keep records of my clients’ details or the details supplied by potential clients;

(iii) because, in certain circumstances, I have a legitimate business interest in doing so and that interest is not overridden by your interests or fundamental rights and freedoms (for example because you can opt-out of such materials at any time);

(iv) additionally, in the case of special categories of information where there is a dispute or potential for a dispute between us, because the processing is necessary for the establishment, exercise or defence of a legal claim.

ii. Information provided by third parties:

This relates to circumstances where a third party sends me information about you. Examples of when this might occur include (but are not limited to) where:

  1. you consent to your employer, relative, doctor or another medical professional providing me with your medical records or information from them;
  2. your authorised intermediary contacts me on your behalf and provides me with information about you as part of any enquiry regards services I am be able to offer;

The information I may receive about you from third parties may include your name, address, email address, phone number, date of birth, gender and personal description.

I may also receive more sensitive personal information about you. This could include information about your health which I need to consider when determining whether I can offer suitable services for you.

I process this information to:

(a) supply you with details of services you have contacted me about;

(b) check your eligibility and suitability for services I offer and to notify you of what services I can offer you.

(c) manage your contact with me (including session bookings, payment handling and any other relevant communication relating to any service/s you have contacted me about) and to respond to you when you contact me;

(d) notify you of any changes to services, procedures and terms (including material changes to this Privacy Policy) from time to time;

(e) comply with record keeping and regulatory compliance obligations; and

I process this information on the following grounds:

(i) because the processing is necessary for me to provide you with service you have requested;

(ii) because, in certain cases, the processing is necessary for me to comply with my legal obligations, for example where regulations oblige me to keep records of my customers’ details or the details supplied by potential customers;

(iii) because, in certain circumstances, I have a legitimate business interest in doing so and that interest is not overridden by your interests or fundamental rights and freedoms (for example because you can opt – out of such materials at any time);

(iv) additionally, in the case of special categories of information where there is a dispute or potential for a dispute between us, because the processing is necessary for the establishment, exercise or defence of a legal claim.

iii. Information I collect about you:

The information I may receive directly from you or about you from third parties may include your name, address, email address, phone number, date of birth, gender and personal description. Where you attend an initial therapy session with me in person, online or via any other media the information you choose to provide me with is determined by you, and you can decline to such information provision at any time. Depending on the nature of the information you decline to provide, this may impact the service and assistance I can provide you with.

I process this information to:

(a) to allow me to administer any service you agree to receive from me;

(b) any notes I take at any sessions are taken by hand only and not transferred to any online storage;

(c) any notes I take are not identifiable;

(d) any notes I take are stored safely with no access by any other parties;

(e) any email, or telephone communications are kept safely and are not accessible by other parties;

How long we keep your Information for

I only keep your information for so long as it is reasonably necessary. Generally speaking, I retain your information for the following periods of time:

(a) if you (or a third party acting on your behalf) makes an enquiry but you do not proceed with obtaining a service from me, 1 year from the date of the enquiry;

(b) if you (or a third party acting on your behalf) makes an enquiry and I advise you that I do not offer suitable services or support for you, 1 year following the date the enquiry;

(c) if you have cancelled any (paid) services you have agreed to receive from me (by whatever means), 7 years after the date of cancellation; and

(d) where any paid services you receive reach their agreed end, 7 years after that  date.

How I share your Information

Your personal information is not shared with anyone except where I am required to do so to comply with the law (eg in case of the threat of life of your own or another, suspected acts of terrorism or money laundering), to protect my rights or to properly administer the service you agree to receive from me.

To the best of my knowledge, understanding and belief, your information will not be transferred outside of the European Economic Area (EEA) or to any country which is not approved by the European Commission. If this changes then I will let you know

Your Rights

Under data protection law you have the following rights:

(a) the right to be informed as to what I do with your information. This includes, but is not limited to, the right to know what information I gather, process and store, what I do with it, who I share it with and how long I keep it for;

(b) where I am keeping your information on the grounds of your consent, you have the right to withdraw that consent at any time. Depending on the circumstances on this decision, this may mean changes or the ending of the service you may be receiving from me.

(i) any payments due under the terms of agreed may still need to be paid and you will not usually be entitled to a refund of monies already paid; and

(c) the right to access a copy of your information which I hold. This is called a ‘subject access request’. Additional details on how to exercise this right are set out in the ‘Access to Information’ section, below;

(d) in certain circumstances, the rights to request that I erase, rectify, cease to store and/or delete your information where the original purpose for which the data was collected has expired;

(e) the right to prevent me processing your information for direct marketing purposes. I will usually inform you (before collecting your information) if I intend to use your information for such purposes or if I intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by contacting me using the details set out in the ‘Contact’ section, below;

(f) the right, in certain circumstances, to have your information rectified, blocked, erased or destroyed if it is inaccurate; and

You also have the general right to complain to me (in the first instance) and to the Information Commissioner’s Office (if you are not satisfied by my response) if you have any concerns about how I hold and process your information. My contact details are set out at the end of the Privacy Policy. The Information Commissioner’s Office website is www.ico.org.uk.

For further information on your right s under data protection law and how to exercise them, you can contact Citizens Advice Bureau (www.citizensadvice.org.uk) or the Information Commissioner’s Office (www.ico.org.uk).

Access to Information

Under data protection law you can exercise your right of access by making a written request to receive copies of some of the information I hold on you. You must send me proof of your identity, or proof of authority if making the request on behalf of someone else, before I can supply the information to you.

From 25 May 2018:

(a) I will be allowed to charge you for my reasonable administrative costs in collating and providing you with details of the information I hold about you if your request is clearly unfounded or excessive; and

(b) in certain circumstances, be entitled to receive the information in a structured, commonly used and machine readable form.

Changes to this Privacy Policy

Any changes made to this Privacy Policy in the future will be posted on the Website and, where appropriate, notified to you by email. It is recommended that you visit this page from time to time to review any changes. This Privacy Policy was last updated in May 2018.

Contact

For questions, comments and requests regarding this Privacy Policy please contact me by email catherine@theanchorage.london