Privacy Policy 1 — Maddy Harris Psychology

Privacy Policy

1. Important Information

Purpose of this Privacy Policy

This privacy policy aims to give you information on how I collect and process your personal data. It is important that you read this privacy policy when I am collecting or processing personal data about you so that you are fully aware of how and why I am using your data.

This privacy policy supplements other notices and privacy policies and is not intended to override them.

Contact Information & Updates

I (Dr Madeline Harris) am the data controller and I am responsible for your personal data.

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact me using the details set out below.

Full name of legal entity: Dr Madeline Harris

Email address: maddyharrispsychology@protonmail.com

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 & your duty to inform me of changes

I keep my privacy policy under regular review. This version was last updated in February 2024.

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

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 are grouped together as follows:

Identity Data. This includes first name, last name, marital status, title, date of birth and gender.

Contact Data. This includes billing address, email address and telephone numbers.

Financial Data. This includes bank account and payment card details.

Transaction Data. This includes details about payments to and from you and details of services you have purchased from me.

Technical Data. This includes internet protocol (IP) address, your login data, browser type and version, previously visited websites, 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. This includes information about how you use this website, including clicks, internal links, pages visited, scrolling, searches, and timestamps.

Special Categories of Personal Data. This includes sensitive data, such as 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 deliver services to you.

I require your explicit consent for processing sensitive data, so when you submit your details, I will ask you to confirm your consent to this processing via the consent tick boxes on my registration form.

I am not required to 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, gender identity, political opinions, trade union membership and genetic and biometric data). Nor do I routinely collect any information about criminal convictions and offences. However, you may choose to share certain additional types of special category data about you during your assessment and/or therapy sessions or in any correspondence with me, and any information shared may then be recorded in your clinical notes. As such, I will ask you to confirm your consent to this processing on my registration form.

I may 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 would treat the combined data as personal data, which will be used in accordance with this privacy policy.

If you fail to provide personal data

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

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 or in writing during appointments, or by corresponding with me by post, phone, email or otherwise. This includes personal data you provide when you:

enquire about my services
enter into a contract with me; or
give me feedback or contact me.

Automated technologies or interactions. As you interact with this website, I will automatically collect Technical Data about your equipment, browsing actions and patterns. I 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:

Personal Data from any referrers or professionals involved in your care, for the purposes of providing services to you.
Technical Data from analytics providers such as Squarespace.
Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
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 (or those of a third party) and your interests and fundamental rights do not override those interests.
Where it is necessary to protect your vital interests or those of another individual.
To help me establish, exercise or defend legal claims.
Where I need to comply with a legal obligation.
Where I am processing special categories of sensitive data for reasons of health and social care.

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) via consent form, email or text message.

Purposes for which I will use your personal data

Below is a description of all the ways I plan to use your personal data, and which of the legal bases I rely on to do so. I have also identified what my legitimate interests are. Please note I may process your personal data for more than one lawful ground depending on the specific purpose for which I am 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 below.

To respond to enquiries or register you as a new client

Type(s) of data:

(a) Identity

(b) Contact

Lawful basis for processing, including basis of legitimate interest:

(a) Performance of a contract with you

To provide my services to you, including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to me

(c) To respond to your enquiries, contact, or communicate with you

(d) To assess your needs and goals

(e) To prepare a quote of delivering services

(f) Notifying you about changes to my terms or privacy policy

(g) Asking you to provide feedback

(h) Investigating and responding to a complaint

Type(s) of data:

(a) Identity

(b) Contact

(d) Transaction

(e) Sensitive Data

Lawful basis for processing, including basis of legitimate interest:

(a) The provision of health and social care in relation to special categories of data (sensitive data)

(b) Performance of a contract with you

(d) In more unusual circumstances, I may use your personal data to help us to establish, exercise or defend legal claims

(e) To comply with a legal obligation

(f) Necessary to protect your vital interests or those of another individual

To administer and protect my business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Type(s) of data:

(a) Identity

(b) Contact

Lawful basis for processing, including basis of legitimate interest:

(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)

(b) Necessary to comply with a legal obligation

To use data analytics to improve my website, products/services, customer relationships and experiences

Type(s) of data:

(a) Technical

(b) Usage

Lawful basis for processing, including basis of legitimate interest:

(a) Necessary for my legitimate interests (to define types of customers for services, to keep my website updated and relevant, to develop my business and to inform my marketing strategy)

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 I will explain the legal basis which allows us 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 section 4 of this policy.

Service providers acting as processors and who provide IT and system administration services including providers of cloud based technology systems.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, surveyors, architects, service agents, experts, transport and distribution suppliers, technical support functions and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
Healthcare providers and professionals acting as processors or joint controllers, including clinical supervisors based in the UK.
Relatives or other third parties who have responsibility for your care.
Referrers for example case managers, solicitors, employers, social workers, local authorities, charities;
HM Revenue & Customs, health care regulators, HCPC and other health care registration and regulatory bodies other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
Marketing technology platforms and suppliers.

I require all third parties to respect the security of your personal data and to treat it in accordance with the law. I do not allow 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 my instructions.

6. International Transfers

Whenever I transfer your personal data out of the EEA, I ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

I will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
Where I use certain service providers, I may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
Where I use providers based in the US, I may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
Where it is necessary for the conclusion or performance of a contract between me and a third party. and the transfer is in your interests for the purposes of that contract (for example, if I need to transfer data outside the EEA in order to meet my obligations under that contract if you are a client); or
Where you have consented to the data transfer.

Please contact me if you want further information on the specific mechanism used when transferring your personal data out of the EEA.

7. 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. In addition, I limit access to your personal data to those agents, contractors and other third parties who have a business need to know. They will only process your personal data on my instructions and they are subject to a duty of confidentiality.

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 I am legally required to do so.

8. Data Retention

I will only retain your personal data for as long as reasonably necessary to fulfil the purposes it was collected 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 I 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 I process your personal data and whether I 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 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 me to delete your data. Please 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 I may use this information indefinitely without further notice to you.

9. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. To find out more about these rights, please visit the ICO website: https://ico.org.uk/

These rights include:

Right to be informed

You have the right to be informed about what data is collected about you, how this is collected and stored, and why it is collected. In line with UK GDPR guidelines, this privacy policy has been designed to ensure this information is available to you at the point at which your personal data is collected.

Right of access

You have the right to receive a copy of the personal data I hold about you and to check I am lawfully processing it. This is commonly known as a “data subject access request”.

Right to rectification

You have the right to request correction of the personal data I hold about you if it is incomplete or inaccurate. I may need to verify the accuracy of the new data provided.

Right to erasure

You have the right to ask me to delete or remove personal data where there is no good reason for me 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 I may have processed your information unlawfully or where I am required to erase your personal data to comply with local law. Please 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.

Right to object

You have the right to 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 meaning 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 I am processing your personal data for direct marketing purposes. In some cases, I may demonstrate I have compelling legitimate grounds to process your information which override your rights and freedoms.

Right to restrict processing

You have the right to 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 I have overriding legitimate grounds to use it.

Right to data portability

You have the right to 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.

Right to withdraw consent

You have the right to 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 at maddyharrispsychology@protonmail.com.

You will not have to pay a fee to exercise your rights as outlined above. However, I may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, I may refuse to comply with your request under these circumstances.

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.

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.