Privacy Policy
Personal data and information GDPR Privacy Notice
Privacy Notice
This Privacy Policy describes how Circle Therapy Ltd gathers and uses personal information submitted on our website www.circletherapy.co.uk and clinical management system. It also describes the choices available to you regarding our use of your personal information and how you can access and update this information.
Registration of your details on our clinical management system Write Upp allows us to book appointments for you and complete assessment forms as part of your support with us.
When you directly give us information We may collect and store information about you when you interact with us. For example, this could be when you:
get in touch with us via phone, website or other method of communication
submit an enquiry
register for or use our services
participate in any training or courses we deliver
give us feedback
apply for a job
If you are under 16 you must seek parental consent before providing any information to Circle Therapy Ltd.
When you indirectly give us information
When you interact with us on social media platforms such as Facebook, Instagram or LinkedIn we may also obtain some personal information about you. The information we receive will depend on the privacy preferences you have set on each platform and the privacy policies of each platform. To change your settings on these platforms, please refer to their privacy notices. You should be aware that Circle Therapy Ltd has no ownership over these websites who may process your data for their own purposes if you choose to use them.
What Information we may Collect
When you engage with us by phone, mail, in person or online, we may collect information about you (referred to in this Privacy Notice as 'personal information'). This may include:
name
address
email address
telephone number
date of birth
job title and details of your education and career
why you are contacting Circle Therapy Ltd
other information relating to you personally which you may choose to provide to us such as diversity information.
We may process your personal information where we reasonably think that there is a risk of serious harm or abuse to you or someone else.
NHS Track & Trace - Under the health and safety public guidelines due to Covid and possible transmission, under the interests of public health and welfare, we may be required to share your name and contact details as part of track and trace if it is in the public interest based on the common law, where it is essential to prevent a serious and imminent threat to public health, national security or the life of another individual or third party in preventing a serious crime. Under this law we may need to share your name and contact details with the NHS if I or another client or colleague contract the virus. This means that in the interests of public health confidentiality will be broken in this regard.
Please note that the above list of categories of personal information we may collect is not exhaustive. Any personal information collected will be processed in accordance with the approach outlined in this Privacy Policy.
Data protection recognises that certain types of personal information are more sensitive. This is known as 'sensitive' or 'special category' personal information and covers information revealing racial or ethnic origin, religion, philosophical beliefs and political opinions, trade union membership, genetics, biometrics (where it is used for ID purposes), information concerning health or data concerning a person's sexual orientation, or sex life.
Sensitive information will only be collected where necessary, for example, we may need to collect health information from you to support any referrals required in support of your care. Clear notices will be provided at the time we collect this information, stating what information is needed, and why.
We may also collect information about whether or not clients are disabled to make reasonable adjustments for clients who have a disability. We process such information to carry out our obligations and exercise specific rights in relation to our service.
With your explicit consent, we may also collect sensitive personal information if you choose to tell us about your experiences relating to our services and relevant to your support.
We are allowed to use your personal information where it is in our interests to do so, and those interests are not outweighed by any potential prejudice to you.
We don't think that any of the following activities prejudice individuals in any way. However, you do have the right to object to us at any time about processing your personal information on this basis. Please also be aware that this may mean we cannot proceed with support as certain information is essential in order for us to meet our obligations as counsellors to support you.
1. Gathering personal data to assess suitability for counselling
2. Obtaining information to support any counselling agreed
3. Obtaining relevant information and your consent to contact other professionals in support of you or your child's care
Where we have sought your consent, we will only process for the purposes we specified at the time you provided your data. However, in the future we may wish to process your data for a different purpose as long as the new purpose is one you might reasonably expect and we will notify you of it beforehand, seeking fresh consent if required.
You have the right to withdraw your consent to these activities. You can do so at any time, and details of how to do so can be found below in the section on your rights to your data.
We seek your consent for:
Necessary processing for the fulfilment of your financial interactions with Circle Therapy Ltd (when you donate to any fundraising, attend our training courses or procure our clinical services). Your decision to engage with these financial interactions is taken as affirmative action that you consent to our processing your personal information for this purpose, including the sharing of your payment details with our payment suppliers.
We do not think that any of the above activities prejudice you in any way. However, you do have the right to object to us processing your personal information in certain circumstances. If you would like to know more about these circumstances and how to object to our processing activities, please see the "Right to object" section below.
Where processing is necessary for us to carry out our legal obligations
As well as our obligations to you under our contract, we also have other legal obligations that we need to comply with and we are allowed to use your personal data when we need to in order to comply with those other legal obligations.
An example of a legal obligation that we need to comply with is our obligation to cooperate with tax authorities.
Where processing is necessary for the performance of a contract between you and us
We may have a contract or other agreement in place with you. In order for us to complete our obligations under this contract, we are permitted to process your personal information in furtherance of this contract. If we are discussing matters with a view to enter into an agreement, then the GDPR permits us to process your personal information in this instance also.
Who will we share your information with?
We will only use your information for the purposes for which it was obtained. We will not, under any circumstances, sell or share your personal information with any third party for their own purposes, and you will not receive marketing from any other companies, charities or other organisations as a result of giving your details to us.
We will only share your data for the following purposes:
Third party suppliers: We may need to share your information with data hosting providers or service providers who help us to deliver our services. These providers will only act under our instruction and are subject to pre-contract scrutiny and contractual obligations containing strict data protection clauses.
Third parties who hold information related to your financial record such as financial organisations, credit reference agencies and debt collection and tracing agencies.
Where legally required: We will comply with requests where disclosure is required by law, for example, we may disclose your personal information to the government for tax investigation purposes, or to law enforcement agencies for the prevention and detection of crime. We may also share your information with the emergency services if we reasonably think there is a risk of serious harm or abuse to you or someone else.
We always aim to ensure that personal information is only used by those third parties for lawful purposes in accordance with this Privacy Notice.
All, or substantially all the assets of an entity within Circle Therapy Ltd are merged with or acquired by a third party, or we expand or re-organise our business, in which case your personal information may form part of the transferred or merged assets or we may need to transfer your information to new entities or third parties through which our business will be carried out.
Your family and personal representatives with your consent
Medical professionals such as your GP or an occupational health specialist or other professionals as required
Tax, audit, or other authorities, when we believe in good faith that the law or other regulation requires us to share this data (for example, because of a request by a tax authority or in connection with any anticipated
Payment Processors:
To process your payments to Circle Therapy Ltd, we need to pass some of your personal information to one or more of the following suppliers. Please follow the suppliers guidance for information on these company’s privacy policies:
Our Clinical System Write Upp processes payment through Stripe, however we also use other providers depending on how you pay us.
Freeagent Invoice System
Direct Debits through - Go Cardless
Stripe
Square
Sum Up
Clinical Information
We are required to store your name, address, date of birth, next of kin and GP details. We may also store any clinical notes as part of your support. We must hold any notes for a period of 7 years. The only persons whom have access are your therapist and Gayle Hammill Circle Therapy Director, unless otherwise requested by law.
Information We Collect
If you enter your details into the Contact Us/Subscribe form at the www.circletherapy.co.uk website, you will be asked to provide certain personally identifiable information (“PII”) such as your name, email address, telephone number and possibly payment details. If you decide to provide PII, you are telling us that this information is both true and accurate, and that you are authorised to provide it to us. We also collect information relating to previous support you have received in respect of your mental health, you can choose what information you disclose to us.
Use of personal information
We will treat your personal information as confidential, and we will not share your personal information with third parties without your permission. The only exception to this is if you are at serious risk of harm or a child is at risk of harm. In this instance we reserve the right to break confidentiality. We may also be asked to share information as part of any legal matters or investigation or complaints procedure.
Information provided through the Contact Us page of our website will be stored in our clinical management system Write upp. This system complies with GDPR.
Control of personal information - Rights to data
You can confirm, request, change, delete or update personal information you have provided to us at anytime by contacting us by email at circletherapy0@gmail.com
Security of personal information
The security of your personal information is important to us. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. However, no method of transmission over the internet, or method of electronic storage is one hundred percent secure and we cannot guarantee its absolute security. Please contact us, if you have any questions about security on our site.
Enforcement of this policy
If you have questions about the policies described in this policy, please contact us directly.
Social Media Features and Widgets
Our website may include social media features, such as the Facebook Like button and widgets. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our site. Your interactions with these features are governed by the privacy policy of the company providing it.
Changes to this policy
We may from time to time update this privacy policy. When we make these updates, we will change the “last updated” date listed below. If we make a material change to this policy in how we use your personal information, we will update users of the the change.
Last updated January 2021
Contact information
Circle Therapy Ltd
Unit 27, Silk Mill Business Park
Brook Street
Tring
HP23 5EF
Email: circletherapy0@gmail.com
Website: www.circletherapy.co.uk
