1. Introduction

1.1 We are committed to safeguarding the privacy of the Psychology Solutions website visitors, clients and other service users.

1.2 This policy applies where we are acting as a data controller or processor, with respect to the personal data that is collected or provided by our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data or process it on behalf of another.

1.3 Psychology Solutions will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website

1.4 In this policy, "we", "us" and "our" refer to Psychology Solutions. For more information about us, see Section 13.

2. Credit

2.1 This document was created using a template from SEQ Legal (https://seqlegal.com).

3. How we use your personal data

Psychology Solutions adopts the definition of personal data as defined under the General Data Protection Regulations (as applied and enforced in the UK), namely “any information relating to an individual or identifiable natural person (data subject), an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

For the avoidance of doubt, Psychology Solutions also adopts the GDPR (as applied and enforced in the UK) definition of special categories of personal data, although the provision of such data on this website is actively discouraged, and such data will at no time ever be posted onto the website by Psychology Solutions. Any person disclosing special categories of personal data on the website should be aware that such data will be deleted from the records of Psychology Solutions and not responded to.

The purpose of this website is for the provision of information about Psychology Solutions and the services offered by such. The only personal data that should be provided to the website, is that required by the use of the Contact Me section, i.e. the name and contact details of a person making legitimate enquiries of Psychology Solutions, and possibly a brief description of the services that such an enquirer may be interested in

All further personal or special category of personal data that may be required and exchanged as a result of Psychology Services fulfilling our professional services for which we have been engaged by you, or engaged on your behalf, will be covered under our Data Protection Policy, which will be made available to you at our first consultation/meeting/treatment session, or again at any time thereafter if you so request. 

3.1 In this Section 3 we have set out:

(a) the general categories of personal data that we may process;

(b) in the case of personal data that we may not obtain directly from you, the source and specific categories of that data;

(c) the purposes for which we may process personal data; and

(d) the legal bases of the processing.

3.2 We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data will only be processed for the purposes of analysing the use of the website and services and will not be shared with any external third party. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

3.3 We may process information contained in any enquiry you submit to us regarding our services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant services to you. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract. 

3.4 We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include your name, address and contact details (email address). Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users. 

3.5 We may process your personal data. This data may include your name, address and email address. The source of this data is you and this data may be processed for establishing contact with you once you have submitted an enquiry via the Contact Me section of the website.  The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3.6 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

3.7 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

3.8 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

3.9 Please do not supply any other person's personal data to us, unless in exceptional circumstances, we specifically request or prompt you to do so, we provide you with a valid reason for our request, and you have the other party’s consent to pass their information to us, or you are doing so without their consent but in order that we may act in their vital interests.

3.10 Where any enquiry you make of our professional services relates to a minor, you should be aware that for the purposes of GDPR, the UK has set the age of a minor as under 13 years of age. Whilst parental/guardian consent for medical therapy or treatment of a minor is still required, for the purposes of processing of personal or special categories of personal data, consent may still be required by anyone over the age of 13, unless parental/guardian consent is deemed to override, and/or processing is conducted in the vital interests of the minor or another individual.

4. Providing your personal data to others

4.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4.2 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

5. International transfers of your personal data

5.1 All Psychology Solutions clinics, data processing and data storage facilities are located within the UK and under no circumstances, other than under compulsion of law, would any data be transferred outside of the UK. 

6. Retaining and deleting personal data

6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of your personal data as collected and processed by this website.

6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

6.3 We will retain your personal data as collected by this website as follows:

(a) your name, address and contact details (phone number and/or email address)  will be retained for a minimum period of 24 hours  following the date and time of your initial enquiry, and for a maximum period of time as is necessary for the purposes for which the data is provided, for example, in the event that your original contact leads to a course of therapy, your original data and reason for contacting Psychology Solutions may be retained for an indefinite period of time, and at least for the ongoing period of therapy, in order that Psychology Solutions can maintain contact with you, and if appropriate use your reason for referral as a measure at some period in the future, to help determine if your therapy has been successful.

6.4 All personal and special categories of personal data that may be collected and processed in order for therapy to be provided to you, will be retained in accordance with the requirements of our Data Protection Policy, which you will have an opportunity to view at your first consultation/therapy session, and at any point thereafter at your request. 

7. Amendments

7.1 We may update this policy from time to time by publishing a new version on our website.

7.2 You should check this page occasionally to ensure you are happy with any changes made to this policy.

7.3 We may notify you of changes to this policy from time to time.

8. Your rights

8.1 In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities if you require a fuller explanation of these rights, or alternatively, you may seek your own independent legal advice.

8.2 Your principal rights under data protection law are:

(a) the right to access;

(b) the right to rectification;

(c) the right to erasure;

(d) the right to restrict processing;

(e) the right to object to processing;

(f) the right to data portability;

(g) the right to complain to a supervisory authority; and

(h) the right to withdraw consent.

8.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. 8.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

8.4 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims]

8.5 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

8.6 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is not that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

8.7 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

8.8 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

8.9 To the extent that the legal basis for our processing of your personal data is:

(a) consent; or

(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,

and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

8.10 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

8.11 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

8.12 You may exercise any of your rights in relation to your personal data by written notice to us.

9. About cookies

9.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

9.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

9.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

10. Cookies that we use

10.1 We use cookies for the following purposes:

(a) status - we use cookies to help us to determine if you whether your browser has JavaScript enabled. The cookie used for this purpose is: has_js and is a session cookie;

(b) cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally, cookies used for this purpose are: Cookie_Policy_Agreement and is a session cookie.

11. Cookies used by our service providers

11.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

11.2 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy/. The relevant cookies are: _ga which identifies unique users and is a persistent cookie being valid for 2 years and, _gid -which is used to distinguish users is a persistent cookie and has an expiration of 24-hours and _gat which is used to throttle the request rate limiting the collection of data on high traffic sites is a session cookie and expires after 10 minutes.

12. Managing cookies

12.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);

(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e) https://support.apple.com/kb/PH21411 (Safari); and

(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

12.2 Blocking all cookies will have a negative impact upon the usability of many websites.

12.3 If you block cookies, you will not be able to use all the features on our website.

13. Our details

13.1 This website is owned and operated by Psychology Solutions.

13.2 We are registered in England and Wales with the Information Commissioner under registration number Z1839266 and our registered office is at Lynton, 159 Banstead Road, Banstead, Surrey. SM7 1QH.

13.3 Our principal place of business is at Lynton, 159 Banstead Road, Banstead, Surrey. SM7 1QH, with other clinics located in Essex and Kent.

13.4 You can contact us:

(a) by post, to Lynton, 159 Banstead Road, Banstead, Surrey. SM7 1QH;

(b) using our website contact form;

(c) by telephone, on the contact number published on our website from time to time; or

(d) by email, using the email address published on our website from time to time.

14. Data protection officer

14.1 Our data protection officer's contact details are: Martin Schofield, Lynton, 159 Banstead Road, Banstead, Surrey. SM7 1QH