Positive Change Hypnotherapy (“we,” “us,” “our”) is committed to protecting and respecting your privacy.
We reserve the right to change this policy at any time by updating this page. Please ensure you check this page from time to time to ensure that you are happy with any changes.
Should you have any questions regarding any aspect of this policy or how it affects you, please contact us.
This policy was last updated on and is effective from 21 May 2018.
2. Information About Us
We are Positive Change Hypnotherapy, a trading name of Stuart Rose. We operate the website https://www.positivechangehypnotherapy.co.uk. Our practice address where you can contact us is: 3 Bromley Cross Road, Bromley Cross, Bolton, BL7 9LS. You can also contact us by telephone: 01204 794776; email: email@example.com.; or using the contact form on our website.
3. Personal Information We Collect
(a) [electronic and manual]
Name; date off birth; age; address; telephone number(s); email address(es); appointment dates; payment amount; method of payment and payment dates; presenting issue; referral source; relevant information and details relating to your presenting issue and treatment you choose to provide to us as part of your via electronic means (for example, email or text message) between sessions
Relevant information and details relating to your presenting issue and treatment you choose to provide to us as part of your clinical hypnotherapy treatment within your sessions or via other electronic means between sessions
4. Lawful Basis For Storing Information
We will hold data about you and process this according to data protection laws, on the following basis:
We collect information where you have consented for us to do so.
This will include information relevant for the provision of clinical hypnotherapy services to you.
Your data we collect on the basis of consent is as follows:
All information from 3. (a) and (b) above.
(b) Legitimate Interests
(i) We collect information process this where this is necessary for our legitimate business interests.
Your data we collect for this purpose is as follows:
From 3 (a) above: name, date off birth, age, address, free consultation and initial consultation appointment dates, payment amount, method of payment and payment dates, presenting issue, and referral source
(ii) We process data where this is necessary for the provision of healthcare — clinical hypnotherapy services.
Your data we collect for this purpose is as follows:
All included under 3 (a) and (b) above.
5. How We Collect Your Data
When you contact us using the website contact form:
we may collect your email address and name and any other relevant information you have provided in your message.
When you contact us using the Free Consultation Request form on our website:
Name, email address, telephone number if provided (not required), presenting issue details.
When we provide a free consultation appointment to you:
In person at your free consultation appointment or introductory consultation:
Name, appointment date, relevant information relating to your presenting issue you provide to us, referral source.
In person at your clinical hypnotherapy sessions:
Name, appointment date, relevant information relating to your presenting issue, progress and treatment, payment amount, method of payment and payment dates.
When you contact us by email, phone or text whilst you are actively engaged in clinical hypnotherapy treatment:
Relevant information relating to your presenting issue, progress and treatment.
When you contact us by email, phone or text whilst you are not actively engaged in clinical hypnotherapy treatment:
Name, email address, telephone number, relevant information relating to your presenting issue that you choose to provide and appointment date and time.
6. How We Use Your Personal Information
(a) Information collected on the basis of your consent (see 4 (a) above) is used for:
(i) Identifying you if you contact us by telephone
(ii) Contacting you (we will only contact you where necessary or appropriate for the provision of clinical hypnotherapy services to you, to arrange appointments or very occasional communications to mark occasions, request feedback/reviews or marketing)
(iii) Arranging appointments
(iv) Providing a clinical hypnotherapy treatment service to you
(b) Information collected on the basis of legitimate interests (see 4 (b) above) is used for:
(ii) Internal business analytic purposes to improve our website, to monitor our performance, to better understand the needs of potential clients, to improve our service, to target general marketing methods, content and locations
(iii) Complying with the requirements of professional association memberships for the purposes of client redress and professional standards
7. How Long We Keep Your Personal Information
(b) Where information is processed based on legitimate interests:
For the purposes of 6(b) (i) and (ii) above, we will continue to store and process this information for as long as is necessary for the original purposes for which it was collected
For the purposes of 6(b) (iii) above, we will continue to store and process this information for eight years from the date of the client’s last contact, or of the client is a child, until his/her 25th birthday or 26th birthday if the client was seventeen years old when the treatment ended
8. Where Your Personal Information Is Processed
Your personal information is only stored and processed by us within the United Kingdom.
9. How We Protect Your Personal Information
We can assure you that we take protection of all personal information you provide as a matter of the utmost importance.
In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure your personal information.
Our website is secured using https technology. This means that all communication between your browser and our website is encrypted.
Information stored electronically is protected by password.
Information stored manually is treated with the care it deserves and all appropriate measures are taken to ensure that this is not available to any other person and is stored securely.
We do not store any of your credit/debit card details.
10. Who We Share Your Personal Information With
We do not usually share your personal information with any third parties.
The only circumstance where this would be required is through legal order or where a client seeks redress through a professional organisation and the professional organisation seeks information to be able to resolve this.
Anonymised information (i.e. not your name but your payment date, amount and method of payment) is shared with our accountant who is a trusted third party.
11. Your Rights Regarding Your Personal Information
(a) For information processed on the basis of your consent (see 6 (a) above):
You can withdraw your consent at any time for us to hold and process the above data relating to you. To do so, please inform us in writing, including by email.
(b) For information processed on the basis of your legitimate interests (see 6 (a) above):
We can no longer process your personal information where you object to the processing of your data, and there is no overriding legitimate interest to continue this processing.
You also have the right to request erasure of personal information where we are processing the personal data for direct marketing purposes and you object to that processing.
Specifically, under the GDPR, you have the following rights:
The right to be informed
This is the purpose of the Privacy Notice.
The right of access
This is usually free of charge
The right to rectification
If we hold any incorrect or incomplete personal information you have a right to have this corrected or rectified.
The right to erasure
This is also known as the ‘right to be forgotten’ and applies in certain circumstances (see above).
The right to restrict processing
This applies under certain circumstances as specified by the GDPR and outlined by the Information Commissioners Office (please see: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-restrict-processing/)
The right to data portability
This gives you the right to receive personal data you have provided in a structured, commonly used and machine readable format. It also gives you the right to request that a data controller transmits this data directly to another controller.
The right to object
You have the right to object to:
(i) processing based on legitimate interests
(ii) direct marketing
(iii) processing for purposes of scientific/historical research and statistics
We will comply with (i) above unless we have legitimate overriding grounds for continuing the processing or the processing is for the establishment, exercise or defence of legal claims.
We will comply with (ii) above when we receive an objection.
We do no process your personal information for the purposes as outlined in (iii) above.
Rights in relation to automated decision making and profiling.
We do not process your personal information in automated decision making or profiling.
You have the right to request a copy of any information about you that we hold, and also to have that information corrected if it is inaccurate. Please contact us at: 3 Bromley Cross Road, Bromley Cross, Bolton, BL7 9LS; or email: firstname.lastname@example.org.
If we make a decision not to action any such request, we will explain to you the reasons for this.
If you are not satisfied with the way any complaint you make in relation to your personal information is processed by us then you may be able to refer your complaint to the relevant data protection regulator. In the UK, this is the Information Commissioner's Office.
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