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CBT for Dublin's Privacy Policy - GDPR

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GDPR Privacy Notice

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Overview

This document refers to personal data, which is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain.

The General Data Protection Regulation (GDPR) which is EU wide and far more extensive than its predecessor the Data Protection Act, along with the Privacy and Electronic Communications Regulations (PECR), seek to protect and enhance the rights of EU data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU and its storage within the EEA.

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1 – CBT for Cancer, www.cbtforcancer.com, which hereafter for the purposes of this Privacy Notice will be referred to as CBT for Cancer, is pleased to provide the following information:

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2 – Who we are
The practitioner at CBT for Cancer provides therapy for Cancer related mind health conditions using cognitive behavioural therapy.

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3 – Personal Data
a) For the purposes of providing treatment, the Practitioner may require detailed medical information. We will only collect what is relevant and necessary for your therapy. When you visit CBT for Cancer, we will make notes which may include details concerning your medication, treatment and other issues affecting your health. This data is always held securely, is not shared with anyone not involved in your therapy, although for data storage purposes it may be handled by an external party which is our application software called Coach Accountable which is signed up to the very rigorous Privacy Shield Framework, see their privacy policy privacy policy and is GDPR compliant. To be able to process your personal data it is a condition of your therapy that you give your explicit consent to allow the Practitioner to document and process your personal medical data. Contact details provided by you such as telephone numbers, email addresses, postal addresses may be used to remind you of future appointments and provide reports or other information concerning your therapy as you so request.

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We use an online booking system run by Acuity Scheduling Inc.  Here is their Privacy Policy.  They are GDPR compliant.


b) For marketing purposes, CBT for Cancer may also use the contact details provided by you to respond to your enquiries, including calling and emailing information to you which CBT for Cancer believes may be of interest to you, including our practice newsletter.  Our practice newsletter is managed by Mailchimp which is GDPR compliant see their privacy policy


c) In making initial contact with CBT for Cancer you consent to CBT for Cancer  maintaining a marketing dialogue with you until you either opt out (which you can do at any time) or we decide to desist in promoting our services. Our Practitioner does not broker your data and you can ask to be removed from our marketing database by emailing CBT for Cancer using the contact details provided at the end of this Privacy Notice.


d) Some basic personal data may be collected about you from any marketing forms and/or surveys you complete, from records of our correspondence and phone calls and details of your visits to our website, including but not limited to, personally identifying information like Internet Protocol (IP) addresses.


e) CBT for Cancer’s website uses cookies. A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Cookies to help CBT for Cancer to identify and track visitors and their website access preferences. Website visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using CBT for Cancer website.


f) CBT for Cancer will only collect the information needed so that we can provide you with the services you require, the business does not sell or broker your data. We use Google Analytics for our Cookie management who are GDPR compliant.

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4 – Legal basis for processing any personal data
To meet our contractual obligations obtained from explicit client Consent and legitimate interest to respond to enquiries concerning the services provided.

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5 – Legitimate interests pursued by CBT for Cancer

To promote therapy for clients with specific health problems.

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6 – Consent
Through agreeing to this privacy notice you are consenting to CBT for Cancer processing your personal data for the purposes outlined. You can withdraw consent at any time by using the email address provided at the end of this Privacy Notice.

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7 – Disclosure
CBT for Cancer will keep your personal information safe and secure, and our Practitioner engaged in providing your therapy will be the only person to have access to your client records. Our practitioner will not disclose your Personal Information unless compelled to, in order to meet legal obligations, regulations or valid governmental requests. CBT for Cancer may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of its business.

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8 – Retention Policy
CBT for Cancer will process personal data during the duration of any treatment and will continue to store only the personal data needed for eight years after the contract has expired to meet any legal obligations. After eight years all personal data will be deleted, unless basic information needs to be retained by us to meet our future obligations to you, such as erasure details.

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9 – Data storage
Data is held in Europe and in America for those using the applications software. All data storage services used by CBT for Cancer are fully GDPR compliant and available on request.

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10 – Your rights as a data subject
At any point whilst CBT for Cancer is in possession of, or processing your personal data, all data subjects have the following rights:

  • Right of access – you have the right to request a copy of the information that we hold about you.

  • Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.

  • Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.

  • Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.

  • Right of portability – you have the right to have the data we hold about you transferred to another organisation.

  • Right to object – you have the right to object to certain types of processing such as direct marketing.

  • Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.


In the event that CBT for Cancer refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge. At your request CBT for Cancer can confirm what information it holds about you and how it is processed.

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11 – You can request the following information:

  • Identity and the contact details of the person or organisation (CBT for Cancer) that has determined how and why to process your data.

  • Contact details of the data protection officer, where applicable.

  • The purpose of the processing as well as the legal basis for processing.

  • If the processing is based on the legitimate interests of CBT for Cancer and information about these interests.

  • The categories of personal data collected, stored and processed.

  • Recipient(s) or categories of recipients that the data is/will be disclosed to.

  • How long the data will be stored.

  • Details of your rights to correct, erasure, restrict or object to such processing.

  • Information about your right to withdraw consent at any time.

  • How to lodge a complaint with the supervisory authority (ICO).

  • Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.

  • The source of personal data if it wasn’t collected directly from you.

  • Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

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12 – To access what personal data is held, identification will be required
CBT for Cancer will accept the following forms of identification (ID) when information on your personal data is requested: a copy of your driving licence, passport or birth certificate, together with a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If CBT for Cancer is dissatisfied with the quality, further information may be sought before personal data can be released. All requests should be made to clare@cbtforcancer.com.

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13 Complaints
In the event that you wish to make a complaint about how your personal data is being processed by CBT for Cancer you have the right to complain to us. If you do not get a response within 30 days, you can complain to the ICO.

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The details for each of these contacts are:

Clare Reed, Clinic Director, CBT for Cancer

Email: clare@cbtforcancer.com

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ICO
Wycliffe House, Water Lane, Wilmslow, SK9 5AF Telephone +44 (0) 303 123 1113 https://ico.org.uk

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