Joe Rigby - Cognitive Hypnotherapist, Leicestershire
1.1 We are committed to safeguarding the privacy of [our website visitors and service users]; in this policy we explain how we will handle your personal data.
2.1 This document was created using a template from SEQ Legal (http://www.seqlegal.com).
3. How we use your personal data
3.1 In this Section 3 we have set out:
(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data; and
(c) 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 geographical location, browser type and version. This usage data may be processed for the purposes of analysing the use of the website and services.
3.3 We may process your account data ("account data"). The account data may include your name and email address. The legal basis for this processing is namely 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 any enquiry you submit to us regarding services ("enquiry data"). The enquiry data may be processed for the purposes of offering and selling relevant services to you. The legal basis for this processing is consent
3.5 We may process information relating to transactions, including purchases of services, that you enter into with us and/or through our website ("transaction data"). The transaction data may be processed for the purpose of supplying the purchased services and keeping proper records of those transactions]. 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 and our legitimate interests, namely Cognitive Hypnotherapy sessions
3.6 We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is the proper administration of our website and business and communications with users.
3.7 We may process any of your personal data identified in the other provisions of 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].
3.8 We may process personal data. This data may include your name, email address, phone number, enquiry information, medical information, notes and recordings taken in sessions. The source of this data is you. This data may be processed for providing the services, maintaining my database and communicating with 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.
3.9 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.
4. Providing your personal data to others
4.1 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.
5. Retaining and deleting personal data
5.1 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 personal data.
5.2 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.
5.3 We will retain and delete your personal data as follows:
(a) personal data will be retained for a minimum of 8 years following our last session/contact, at the end of which period it will be deleted from our systems.
5.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
(a) the period of retention of Personal data will be determined based on CNHC Code of Conduct and therapeutic best practice.
5.5 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention 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.
6.1 We may update this policy from time to time by publishing a new version on our website.
6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
6.3 We may notify you of changes to this policy by email.
7. Your rights
7.1 You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:
(a) the payment of a fee (currently fixed at GBP 10); and
(b) the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).
7.2 We may withhold personal information that you request to the extent permitted by law.
7.3 You may instruct us at any time not to process your personal information for marketing purposes.
7.4 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. However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
7.5 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.
7.6 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 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.
7.7 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.
7.8 To the extent that the legal basis for our processing of your personal data is consent, 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.
7.9 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.
7.10 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.
7.11 You may exercise any of your rights in relation to your personal data by written notice to me.
8. Our details
8.1 This website is owned and operated by Cognitive Transformations.
8.2 You can contact us:
(a) using our website contact form;
(b) by telephone, on the contact number published on our website from time to time or
(c) by email, using[the email address published on our website from time to time.