- About this statement
I need to process data about the people for whom I provide therapeutic services, for those who sign up for my newsletter and for those who continue to access website content, news and events, and for the people who enquire about my services. This privacy statement outlines what data is collected, how it will be used, and what your rights are as a data subject.
This privacy statement is as comprehensive as possible however it is not an exhaustive list of every aspect of data collection and processing. I would be happy to provide further information or explanation about my services, if you have any questions please do get in touch with me.
- Why I collect your data & how I collect it
I will collect the personal data needed in order to communicate with you, to provide information and administer services to you and to conduct my business. The type and amount of data collected will depend on the nature of your interaction with Clear PTSD.
I collect information about you that you give me directly by contacting me directly, filling in forms on my website, requesting further information, attending client sessions or events, by completing surveys or forms, by visiting my website or social media pages or by corresponding with me on social media, by phone, email or otherwise.
- What data I collect
I collect the data required in order to provide an appropriate service to you, this will vary based on the nature of your relationship with Clear PTSD.
For those making enquiries about a client session or attendance at an event:
I may collect any, but not necessarily all, of the following personal data such as:
- Your full name
- Contact details including postal address and address history, mobile and telephone numbers, and email addresses
- Disabilities, allergies and medication
- Your work and education history
- Correspondence or contact you have with me
- Previous client sessions you have taken with me
- Other client sessions or treatment you have received from other therapists, counsellors, medical personnel and the like
- Your purpose and motivation for seeing me
- Social media details
- Occupation or place of work
The filming of client sessions is common at Clear PTSD. The main focus of filming is the therapist, not the participant. I may use a digital video camera/recorder in order to record client sessions which serves to improve the quality of service I offer and helps to maintain my certification in Rapid Resolution Therapy.
Do I process special categories of data?
The EU General Data Protection Regulation (“GDPR”) recognises certain categories of personal information as sensitive and therefore requiring more protection, for example information about your health, ethnicity and religious beliefs.
In certain situations, I may collect and/or use these special categories of data (for example, information on clients’ medical conditions so that I can make arrangements for reasonable adjustments and/or special considerations, etc). I will only process these special categories of data if there is a valid reason for doing so and where the GDPR allows me to do so.
For those visiting my website or social media pages
- Your IP address and related browsing information
I do not see or store card payment details for any purchases made online through my website. Where a payment is made over the phone, I will input the details into the same secure websites on your behalf.
I strongly advise against sending payment details by email. If I receive an email containing any payment information this will be immediately processed and the email deleted.
I keep records of your correspondence and engagement with me which may include details about attendance of client sessions or workshops or events.
Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.
Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.
Your web browser should allow you to delete any you choose. Most browsers allow you to turn off cookies. To do this look at the “help” menu on your browser. Switching off cookies may restrict your use of the website and/or delay or affect the way in which it operates.
- to track how you use my website
- to record whether you have seen specific messages I display on my website
- to keep you signed in to my website
- to record your answers to surveys and questionnaires on my website while you complete them
- to record the conversation thread during a live chat with my support team
- to remarket my services to you via 3rd party websites that can host my adverts.
How I use your data
- The legal basis for processing your data
I will ensure that where I collect and process your data, I will do so in accordance with the lawful bases defined by data protection laws, depending on the purposes for which I use your data, one or more of the lawful bases below may be relevant:
Contract where I have entered into a contractual agreement with you.
Legal obligation where there is a requirement for me to record information for client sessions, accounting and tax purposes.
Legitimate interests such as:
Administration, Marketing and Operational functions – including responding to enquiries, providing information and services.
Delivering services – ensuring high quality services are provided to you as the client.
Where the above reasons have not been satisfied and / or you have provided your consent for me to use your personal information in a certain way.
Where legitimate interests has been identified as the lawful basis for processing data, I will ensure that its use is fair and not intrusive and is only used in a way or for a purpose that you would reasonably expect.
If you do not wish to share your data with me, I will be limited in the support or service that I can offer to you and may not be able to provide such services.
I may use your personal information to inform relevant third parties such as your internet provider or law enforcement agencies in the event that you post or send any content that I believe to be inappropriate, offensive, or in breach of data protection laws.
- Retention of your data
I have an internal procedure which sets out the specified time for which I keep data, I refer to the data retention procedures of national bodies in determining how long I will keep data and take into account any legal requirements, legitimate interests, and guidance issued by regulatory bodies such as the Information Commissioners Office. Once the retention period has expired, I will securely dispose of data either by confidential waste disposal, anonymization, or permanent deletion.
I keep your personal information only for as long as required by me:
To provide you with access to services in line with Legitimate interest.
To comply with other law, including for the period demanded by the tax authorities and my regulatory bodies.
To support a claim or defence in court.
- Security of your data
I have appropriate operational and technical measures in place to protect your personal data and ensure its confidentiality, integrity, and availability. All information provided to Clear PTSD is stored securely and accessible only to those who are authorised to have access to it. I will take all reasonable steps and measures to ensure that the information you give me is protected against loss, misuse, unauthorised access or disclosure.
- Disclosure of your data
I will never sell, share or swap your details with any third parties for the purposes of their own marketing or the monetisation of your data.
Your data will only be shared with third parties where:
It is to a secure data processor carrying out processing activities on my behalf (for example Acuity Scheduling, my scheduling provider, PayPal, my payment processing company, or Mailchimp, my email marketing service).
I am required to do so by law, for example to regulatory bodies or law enforcement, or in order to enforce or apply my rights to protect my business and personal reputation, for example in cases of suspected fraud or defamation.
It is necessary to protect the vital interests of an individual, for example where I believe you or another person might be in danger.
I have obtained your explicit consent to share it.
If I sell the business (data is shared for the purpose of business and service continuity), when you will be notified and are able to opt-out or have your data deleted.
I am required to share some information with my regulatory bodies.
- Transfer of data outside the European Economic Area
In the unlikely event I was required to transfer data outside the EEA this would be done so in a secure manner and only where there is an adequate level of protection for the rights of data subjects in the receiving country, for example the EU-US Privacy Shield.
- Your rights & complaints
Access to your personal information
To obtain a copy of any of your personal information that I hold you may send me a request at email@example.com
After receiving the request, I will tell you when I expect to provide you with the information.
To stop newsletters or any informational or marketing emails you can use the unsubscribe link included in every email or contact firstname.lastname@example.org to request that your email address be removed.
To stop Event and Workshop related communications emails please send your request to email@example.com
If you would like to opt out of Google Analytics monitoring, please use this link:
Verification of your information
When I receive any request to access, edit or delete personal identifiable information I shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
- How you can complain
If a dispute is not settled, then I hope you will agree to attempt to resolve it by engaging in good faith with me in a process of mediation or arbitration.
If you are in any way dissatisfied about how I process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office. This can be done at https://ico.org.uk/concerns/
- Compliance with the law
However, ultimately it is your choice as to whether you wish to use my website.
The terms that apply to you are those posted here on my website on the day you use my website. I advise you to print a copy for your records.
This statement was last updated on 12 September 2019., if any significant changes are made to the way in which I use your data I will update this privacy statement and make you aware in my next communication with you.