Question 1

GDPR Data Policy

Accepted Answer

General Data Protection Regulation (GDPR) Policy for Nurture & Growth Psychology Ltd October 2024

1. How we use your personal data

We take the privacy rights of all our clients seriously and we adopt a high standard of compliance and confidentiality when dealing with your data.  We want you to understand that this is a safe place for you to discuss your feelings and concerns and we operate in a highly confidential environment.  This privacy notice sets out the details of how we collect and process your personal and sensitive data when using our services.

We will use your sensitive personal data for the purposes of providing our services to you or if we need to comply with a legal obligation. Our legal ground of processing this data is your explicit consent.

We will use your non-sensitive personal data to (i) register you as a new client, (ii) manage payment, (iii) collect and recover monies owed to us and, (iv) to manage our relationship with you.

Our legal grounds for processing your data are in relation to points (i) to (iv) above are for performance of a contract with you and in relation to (iii), necessary for our legitimate interests to develop our services and grow our business and to recover monies owed.
We will not share your details with third parties for marketing purposes.

2. Disclosure of your personal data

We may have to share your personal and sensitive data with (i) service providers who provide IT and system administration support including software providers for accounting, marketing and practice management solutions, (ii) professional advisors including other healthcare professionals, lawyers, accountants, bankers, auditors and insurers (iii) HMRC and other regulatory authorities (iv) third parties to whom we sell, transfer or merge parts of our business or our assets and/or (v) to other professionals for the purposes of discussing your treatment.

We require all of these third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. They are only allowed to process your personal data on our instructions.

3. International transfers

Some of our third-party providers are businesses outside of the UK and EEA in countries which do not always offer the same levels of protection for your personal data. We do our best to ensure a similar degree of security by ensuring that contracts, code of conduct or certification are in place which give your personal data the same protection it has within the UK and  Europe. If we are not able to do so, we will request your explicit consent to the transfer and you can withdraw this consent at any time.

4. Data security

We have put in place security measures to prevent your personal and sensitive data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We also limit access to your personal and sensitive data to those employees, agents, contractors and other third parties who have a business need to know such data.

They will only process your personal and sensitive data on our instructions and are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breaches and will notify you and any applicable regulator where we are legally required to do so.

In certain circumstances you can ask us to delete your data. See section 6 below.

We may anonymise your personal and sensitive data (so that you can no longer be identified from such data) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

5. Data retention

We will only keep your personal and sensitive data for as long as is necessary to fulfil the purposes for which we collected it. We may retain your data to satisfy any legal, accounting, or reporting requirements so for example we need to keep certain information about you for 6 years after you cease to be a client for tax purposes.

Mental health records are subject to special legislation e.g. adult records are kept for 8 years after the last contact with the service.  This benchmark will be applied to all clinical records made in the process of engagement with our therapy.  For any children we treat we are obliged to retain medical information until 7 years after the child’s 18th birthday.

You have the right to ask us to delete the personal and sensitive data we hold about you in certain circumstances. See section 6 below.

6. Your rights
You are able to exercise certain rights in relation to your personal and sensitive data that we process. These are set out in more detail at 
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/(https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/)
You may request that we inform you of the data we hold about you and how we process it (your ‘Subject Access Right’). We will not charge a fee for responding to this request unless your request is clearly unfounded, repetitive or excessive in which case we may charge a reasonable fee or decline to respond.
We will, in most cases, reply within one month of the date of the request unless your request is complex or you have made a large number of requests, in which case we will notify you of any delay and will in any event reply within 3 months.
If you wish to make a Subject Access Request, please email the request to admin@nurtureandgrowthpsychology.co.uk marked for the attention of the Data Compliance Officer.

7. Keeping your data up to date
We have a duty to keep your personal and sensitive data up to date and accurate so from time to time we will contact you to ask you to confirm that your personal data is still accurate and up to date.

If there are any changes to your personal data (such as a change of address) please let us know as soon as possible by writing to or emailing the addresses set out in section 6 above.

8. Complaints 
We are committed to protecting your personal data but if for some reason you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk)(http://www.ico.org.uk/).  
We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

Question 2

Website Privacy & Cookie Policy

Accepted Answer

Nurture & Growth Psychology Ltd's Website Privacy & Cookie Policy
Nurture & Growth Psychology take the privacy rights of all its clients seriously and adopts a high standard of compliance and confidentiality when dealing with your data. Nurture & Growth Psychology wants you to understand that this is a safe place for you to discuss your feelings and concerns and Nurture & Growth Psychology operates in a highly confidential environment.  This privacy policy sets out the details of how data is collected and processed through the use of our website.

1.	Important information and who we are
Purpose of this privacy policy
This privacy policy aims to give you information on how Nurture & Growth Psychology 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 we do not knowingly collect data relating to children via our website.
It is important that you read this privacy policy together with any other privacy policy we may provide on specific occasions when we are collecting or processing personal or sensitive data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller
Nurture & Growth Psychology Ltd is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details
If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:
Dr Elisabeth Rothaug-Smith
Nurture & Growth Psychology Ltd
4 Nelson Road, Nelson Arcade, Greenwich SE10 9J

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). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last updated in October 2024. 
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

2.	The data we 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).
We may collect, use, store and transfer different kinds of personal data about you which we 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, delivery address, email address and telephone numbers.
•	Financial Data includes bank account and payment card details.
•	Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
•	Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website. 
•	Usage Data includes information about how you use our website. 
We 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, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we 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 us to carry out our services to you. 
We require your explicit consent for processing sensitive data, so when you submit your details, we will send you a further communication  asking for you to confirm your consent to this processing.

If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services or goods). In this case, we may have to cancel a service or product you have with us but we will notify you if this is the case at the time.

3.	How is your personal data collected? 
We use different methods to collect data from and about you including through:
•	Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms before or during an appointment, verbally during discussions at our practice, or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
•	apply for our services; or
•	give us feedback or contact us. 
•	Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
•	Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below: 
Technical Data  from the following parties:
(a)	analytics providers such as [Google] based outside the EU; 
(b)	search information providers such as [Google] based outside the EU.

4.	How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
•	Where we need to perform the contract we are about to enter into or have entered into with you.
•	Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
•	Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent when collecting sensitive data (such as health information).

Cookies
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.
We use the following cookies:
•	Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
•	Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
•	Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
•	Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests.

Change of purpose 
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we 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 us. 
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we 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
We 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.
•	Service providers, acting as processors who provide IT and system administration services.
•	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. 
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6.	Data security 
We 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. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. 
We 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?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We 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, we 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 we have to keep medical information about patients for 7 years after treatment has finished.  For any children we treat we are obliged to retain the medical information until 7 years after the child’s 18th birthday.  By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we 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 we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we 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 us 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 us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we 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 we are 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. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we 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 us to suspend the processing of your personal data in the following scenarios: 
•	If you want us to establish the data's accuracy.
•	Where our use of the data is unlawful but you do not want us to erase it.
•	Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims. 
•	You have objected to our use of your data but we 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. We 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 us to use or where we used the information to perform a contract with you. 
Withdraw consent at any time where we are 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, we may not be able to provide certain products or services to you. We 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 us. 
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, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us 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. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

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