Introduction

Welcome to the privacy policy for https://cathyrowlandpsychotherapy.com/

Cathy Rowland takes the privacy rights of all her clients seriously and adopts a high standard of compliance and confidentiality when dealing with your data.   This is a safe place for you to discuss your feelings and concerns and Cathy operates in a highly confidential environment.  This privacy policy sets out the details of how data is collected and processed through the use of her website.

1. Important information and who I am.

 

Purpose of this privacy policy

This privacy policy aims to give you information on how https://cathyrowlandpsychotherapy.com/ collects and processes your personal data through your use of this website, including any data you may provide through this website.  

This website is not intended for children, and I do not knowingly collect data relating to children via this website.

 

Controller

Cathy Rowland is the data controller and is responsible for your personal data and is referred to as ‘I’ or ‘me’ in this privacy notice.     

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). I would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact me in the first instance. 

 

Changes to the privacy policy and your duty to inform us of changes

I keep my privacy policy under regular review. This version was last updated in October 2023

It is important that the personal data I hold about you is accurate and current. Please keep me informed if your personal data changes.  

2. The data I collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

I may collect, use, store and transfer different kinds of personal data about you which I have grouped together as follows:

• Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payment from you. 
• Usage Data includes information about how you use our website, products and services. 

I also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, I may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if I combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, I treat the combined data as personal data which will be used in accordance with this privacy policy.

• Sensitive Data includes information about your health, including information about your existing and previous medical conditions, medication details, psychiatric history and any other relevant health information to enable me to carry out our services to you.  
• I require your explicit consent for processing sensitive data, so if we decide to work together,  I  will include on our contract, request for your consent to this processing. 

I do not collect any other Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership and genetic and biometric data). Nor do I collect any information about criminal convictions and offences.

3. How is your personal data collected?

I use different methods to collect data from and about you including through:

• Direct interactions. You may give me your Identity, Contact and Financial Data by filling in forms before or during an appointment, verbally during discussions at my practice, or by corresponding with me by phone, email or otherwise. 
• Automated technologies or interactions. As you interact with my website, I will automatically collect Technical Data about your equipment, browsing actions and patterns. I will collect this personal data by using cookies and other similar technologies. Please see my cookie policy for further details.
• Third parties or publicly available sources. I will receive personal data about you from various third parties and public sources as set out below: 

Technical Data from the following parties:

1. analytics providers such as Google based outside the EU; 
2. advertising networks such as Facebook based outside the EU; and
3. search information providers such as Google based outside the EU.

• Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe or PayPal based outside the EU.
• Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

4. How I use your personal data

I will only use your personal data when the law allows me to. Most commonly, I will use your personal data in the following circumstances:

• Where I need to perform the contract I am about to enter into or have entered into with you.
• Where it is necessary for my legitimate interests and your interests and fundamental rights do not override those interests.
• Where I need to comply with a legal obligation.

Generally, I do not rely on consent as a legal basis for processing your personal data although I will get your consent when collecting sensitive data (such as health information.) You have the right to withdraw consent to marketing at any time by contacting me.

Purposes for which I will use your personal data

I have set out below, in a table format, a description of all the ways I plan to use your personal data, and which of the legal bases we rely on to do so.  I have also identified what my legitimate interests are where appropriate.

Note that I may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact me if you need details about the specific legal ground I am relying on to process your personal data where more than one ground has been set out in the table below. 

 

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new client	(a) Identity  (b) Contact	Performance of a contract with you
(a) To provide my services to you (b) Manage payments, fees and charges (c) Collect and recover money owed to me	(a) Identity  (b) Contact  (c) Financial  (d) Transaction  (e) Marketing and Communications (f) Sensitive Data	(a) Performance of a contract with you  (b) Necessary for my legitimate interests (to recover debts due to us) (c) Explicit consent (in the case of Sensitive Data).
To manage my relationship with you which will include: (a) Notifying you about changes to my terms or privacy policy	(a) Identity  (b) Contact  (c) Profile  (d) Marketing and Communications	(a) Performance of a contract with you  (b) Necessary to comply with a legal obligation (c) Necessary for my legitimate interests (to keep my records updated and to study how clients use my services)
To administer and protect my business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for my legitimate interests (for running my business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To use data analytics to improve my website, services, client relationships and experiences	(a) Technical  (b) Usage	Necessary for my legitimate interests (to define types of clients for my services, to keep my website updated and relevant, to develop my business.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies I use, please see my Cookie Policy.

Change of purpose

I will only use your personal data for the purposes for which I collected it, unless I reasonably consider that I need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact me. 

If I need to use your personal data for an unrelated purpose, I will notify you and we will explain the legal basis which allows me to do so.

Please note that I may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

I may share your personal data with the parties set out below for the purposes set out in the table ‘Purposes for which we will use your personal data’ above.

• Professional advisers, acting as processors or joint controllers, including healthcare professionals, lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities, acting as processors or joint controllers, based who require reporting of processing activities in certain circumstances.

6. Data security

I have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. I have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. Data retention

How long will you use my personal data for?

I will only retain your personal data for as long as reasonably necessary to fulfil the purposes I collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. I may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, I consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law I have to keep basic information about my clients (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask me to delete your data: see your legal rights below for further information.

In some circumstances I will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. 

8. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.  You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data I hold about you and to check that we are lawfully processing it.

Request correction of the personal data that I hold about you. This enables you to have any incomplete or inaccurate data I hold about you corrected, though I may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask me to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask me to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where you may have processed your information unlawfully or where I am required to erase your personal data to comply with local law. Note, however, that I may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. 

Object to processing of your personal data where I am relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, I may demonstrate that I have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask me to suspend the processing of your personal data in the following scenarios: 

• If you want me to establish the data’s accuracy.
• Where my use of the data is unlawful but you do not want me to erase it.
• Where you need me to hold the data even if I no longer require it as you need it to establish, exercise or defend legal claims. 
• You have objected to my use of your data but I need to verify whether we have overriding legitimate grounds to use it. 

Request the transfer of your personal data to you or to a third party. I will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for me to use or where I used the information to perform a contract with you. 

Withdraw consent at any time where I am relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, I may not be able to provide certain products or services to you. I will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact me. 

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, I may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, I could refuse to comply with your request in these circumstances.

What I may need from you

I may need to request specific information from you to help me confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. I may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

I try to respond to all legitimate requests within one month. Occasionally it could take me longer than a month if your request is particularly complex or you have made a number of requests. In this case, I will notify you and keep you updated.