RJT Psychology is the Trading Name of Dr Rachel Jane Toole. We aim to be as clear as possible about how and why we use information about you so that you can be confident that your privacy is protected. This Privacy Notice describes the information that RJT Psychology collects when you use our services. This information includes personal and special category personal data.  When we do this we are subject to the UK General Data Protection Regulation (UK GDPR). This Privacy Notice describes how we manage your information when you use our services, if you contact us or when we contact you.  As per these laws, RJT Psychology is the data controller.

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If your questions are not fully answered by this Privacy Notice, please contact our Data Protection Officer (Dr Rachel Toole at rachel@rjtpsychology.co.uk. If you are not satisfied with the answers from the Data Protection Officer, you can contact the Information Commissioner's Office (ICO) https://ico.org.uk.

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In this Privacy Notice:

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“Personal data” means any information relating to an identified or identifiable individual, this may include special category personal data.

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“Special category personal data” means personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership; genetic data; biometric data (where used for identification purposes; data concerning health, sex life or sexual orientation).

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1. Why do we need to collect your personal data?

We need to collect information about you so that we can:

• Know who you are so that we can communicate with you in a personal way.

• Deliver goods and services to you.

• Process your payment for the services.

• Verify your identity so that we can be sure we are dealing with right person.

 

2. What personal information do we collect and when do we collect it?

The data we collect from you is as submitted directly by you via letter, email, text, when you provide information over the telephone, contact us via our website and during consultations (in person or on-line) and that which you will be asked to provide when completing our client details form before your first appointment. You will be asked to submit this via the practice management software.

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We also collect information about you when you interact with our website – please see section 7 below for further details.

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For us to provide you with services, we need to collect the following information:

• Your full name

• Your Date of Birth

• Your contact details including a postal address, telephone number(s) and electronic contact such as email address

• Your Next of Kin/Emergency Contact

• Your GP name, address and contact number

 

What is our legal basis for collecting personal data? – Legitimate interests

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Consent is only one lawful basis for processing data. We have identified the following lawful basis for processing your data. Anything outside of this scope we will actively seek your permission prior to the activity.

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• Legitimate interests – When you or a third party provide your personal details to us we use your information for our legitimate business interests to carry out our services.

 

In order for us to carry out our services we will also require more sensitive personal data (special category personal data).

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We will only collect and process special category personal data with your consent, and in such circumstances consent is the legal basis for processing. You can withdraw your consent at any time by contacting us at rachel@rjtpsychology.co.uk or by writing to us at Room 31, Haling Dene Centre, Cannock Road, Penkridge, Stafford, ST19 5DT.

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We have a duty to keep your personal data up to date and accurate so from time to time we will contact you to ask you to confirm that this is the case.  If there are any changes to your personal data (such as a change of address) please let us know as soon as possible.

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We may anonymise your personal 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.

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We may also collect information about you from the following third parties;

• Your GP or other healthcare professionals;

• Charities, organisations or healthcare providers who may be funding your treatment sessions.

• If people call or otherwise contact us on your behalf.

 

Where accessing our services via a third-party website you may also be subject to that providers privacy policies, and you should review these in addition to the Privacy Notice of RJT Psychology.

 

3. How do we use the information that we collect?

To provide you with effective and safe clinical services we will need to know personal and sensitive information about you. Whenever any personal data is provided to us in connection to our service, legally we have to use it in accordance with the terms of various privacy laws, including UK GDPR and The Data Protection Act 2018.

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We use the personal data we collect from you in the following ways:

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• To register you as a new client

• To manage payment

• To collect and recover monies owed to us

• To manage our relationship with you

• To communicate with you so that we can inform you about your appointments

• To deliver the correct service to you

• To create invoices for any organisation, charity or private healthcare provider that may be funding your sessions

• To produce clinical notes and other documents such as, but not limited to, letters and reports

 

We will not share your details with third parties for marketing purposes.

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4. Where do we keep the information?

We take the security of your personal information very seriously. We have put in place security measures which are designed to protect the personal data we hold about you to prevent it from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We also follow the strict security procedures that privacy laws require. These cover storing, using, transmitting and releasing any information you have provided, and preventing unauthorised access or use.

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We keep your information stored as described below.

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4.1  On our company computers

We use company devices including laptops, mobile phones and tablet devices to store and access your data:

• Notes will be made on paper during your sessions. These will be typed up and stored electronically with your client records on our practice management software (which is a password protected and secure cloud-based practice management system) on a password protected device. Your client record will include information we hold about you – as outlined in point 2 above and other documents produced in relation to our contact with you such as letters and reports. The paper notes will be destroyed using a cross cutting shredder at the time of destruction. A cloud-powered productivity platform, Microsoft 365, on a password protected device is also utilised.

• Our electronic equipment is regularly backed-up and is secured with up-to-date security software.

 

4.2 As a paper copy

Notes taken when we meet you are sometimes used to create letters and reports that will be provided to you by hand where possible or by post. When posted these will be marked as 'private and confidential' and registered where appropriate. Any further paper records of personal data are stored securely in a locked filing cabinet and a locked room at the offices of RJT Psychology.

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5. Who do we send the information to?

5.1 Third Parties

We will ensure that any personal information you disclose to us shall not be disclosed to any person except as detailed below. Should we be required to disclose personal information, we will endeavour, where possible, to discuss this with you first. We will not record or allow anyone to listen to any part of a session unless with your explicit consent.

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We may disclose confidential information relating to you in the following ways:-

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• When you give your consent for us to share your personal data

• To our advisers who need to know such information for the purposes of carrying out our services to you for example, Clinical Supervisors - (It is a requirement for a Clinical Psychologist to engage in supervision when working therapeutically with clients to ensure that the work provided is as clinically appropriate as possible, working with the aim of achieving the best outcome for you in the time available), and a Therapeutic Executor (This is another therapist who can access your personal data in order to contact you should anything happen that prevents your Psychologist from continuing with your therapy and contacting you themselves. The Therapeutic Executor will not access your file at any other time)

• If we need to contact another professional or healthcare provider (for example, we may need to contact your GP, usually by letter, to inform them that you are being seen by the service, why and give them any other pertinent information and then to update them on closing your case) as part of your care

• To a Third Party who is funding your sessions – private healthcare or other organisations/charities who may require details of the work undertaken with you such as updates and reports

• To third parties who provide services to us, which allow us to operate our business and provide the Services, such as IT support, hosting and software providers (including videocall hosting providers), banking and payment processors and other professionals such as our accountants, insurers or lawyers

• We may share or disclose information collected via our website or contained on our server logs or databases to third parties where necessary to protect the security or integrity of our website/server logs/databases (as applicable)

• As may be required by law, a court of competent jurisdiction or any governmental or regulatory authority

• For reasons of public interest in the area of public health

• To HMRC and any other regulatory bodies to the extent necessary to comply with law

• If information disclosed during a session is of such a serious nature that confidentiality cannot reasonably be expected to be maintained such as;  If we believe that you are at risk of harming yourself or others, or you or others are at serious risk of harm, in which case we will report this to the relevant organisation(s), Your GP and/or emergency contact/next of kin as necessary and, information such as that relating to Child Protection, Safeguarding, crime, fraud, acts of terrorism and drug trafficking.

 

Where your personal information is shared with a third party partner such as our professional advisers or someone providing IT support we will ensure that such persons operate under appropriate contractual restrictions to protect your confidentiality and security of your personal data.

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5.2 International transfers

Some of our third party IT providers are businesses outside of the EEA in countries which do not always offer the same levels of protection for your personal data. Where this is the case we will ensure that such providers operate under contractual restrictions to protect the security of your data.

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6. How long do we keep the information?

We will only keep your personal data for as long as is necessary to fulfil the purposes for which we collected it. RJT Psychology keeps all your personal data for a 7 year period following our last contact with you unless you and your therapist agrees otherwise. This arrangement allows us to comply with Professional Body Guidance, UK Tax Law and Indemnity Insurance Policies. Data may be kept for longer in exceptional circumstances such as those related to legal processes.  At RJT Psychology we will securely store your data for this period then all records of our contact, including any personal details, will be destroyed securely or deleted.

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7. Data collected through our website

7.1 In addition to the above, we use technology to collect information about the use of our website. For example, our servers automatically log which pages of our website visitors view, IP addresses and which web browsers they use. This technology allows us to compile statistics about our visitors and their use of our website. The IP address of visitors is collected in line with legal requirement, but it is not used in any monitoring or statistics.

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7.2 Our website may contain hyperlinks to other pages on our website. We may use technology to track how often these links are used and which pages on our website our visitors choose to view. This technology enables us to compile statistics about the use of these hyperlinks.

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7.3 In order to collect the data through our website we may use 'cookies'. Please refer to our Cookie Policy at www.rjtpsychology.co.uk/cookie-policy. For more information about cookies, including how to set your browser to reject them, please go to www.allaboutcookies.org.

 

7.4 Your IP address may also be used by us to help diagnose problems or to administer our website. An IP address is an assigned number, similar to a telephone number that identifies your computer on a network. Your IP address is also used to gather broad demographic information. IP lookups may also be undertaken by us to identify the domain you are coming from in order that we can assess our users demographics.

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7.5 Our website may contain hyperlinks to websites that are not operated by us. These hyperlinks are provided for your reference and convenience only and do not imply any endorsement of the activities of such third party websites or any association with their operators. We do not control these websites and are not responsible for their personal data practices. These other third party websites may also use cookies or similar technologies in accordance with their own separate policies. For privacy information relating to these other third party websites, please consult their policies as appropriate.

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YOUR RIGHTS

You are able to exercise certain rights in relation to your personal data that we process. These are set out in more detail at https://ico.org.uk/for-organisations/guide-to-the-general-data-protectionregulation-gdpr/individual-rights/.

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8. How can I see all the information you have about me? – Right to access

In relation to a Subject Access Right request, you may request that we inform you of the data we hold about you and how we process it. 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.

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If you wish to make a Subject Access Request, please send the request to our Data Protection Officer Dr Rachel Toole at rachel@rjtpsychology.co.uk. We may require additional verification that you are who you say you are to process this request. We may withhold such personal information to the extent permitted by law. In practice, this means that we may not provide information if we consider that providing the information will violate your vital interests.

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9. What if my information is incorrect? – Right to Rectification

If you wish to have your information corrected, please contact the Data Protection Officer. We may require additional verification that you are who you say you are to process this request.  You must provide us with the correct data and after we have corrected the data in our systems we will send you a copy of the updated information in the same format as the Subject Access Request as detailed above.

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10. How can I have my information removed? – Right to Erasure

You have the right to ask us to delete the personal data we hold about you in certain circumstances.

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If you want to have your data removed we have to determine if we need to keep the data, for example in case HMRC wish to inspect our records. If we decide that we should delete the data, we will do so without undue delay.

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11. Will we leave voicemails and send emails and text messages to you?

As part of this service, we need to send information to you in order to provide you a service, for example, relevant information when you are taken on as a new client, details of your appointments etc. We will use your telephone number and may leave a voicemail, email address or SMS (text messages); however, it is noted that this does increase the risk of someone intercepting the information. Additionally, we may contact you:

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• About information you have asked for, in order to answer your request

• If you have chosen to receive further information from us

• To invite you to take part in feedback surveys about our services (it is always up to you whether you want to take part)

• If you have given us feedback, to discuss that feedback or ask your permission to publish it.

 

12. How do I opt out of receiving voicemails, emails and/or text messages from us?

If you are receiving text messages from us, you may unsubscribe at any time by responding to the text with the word “unsubscribe”. Similarly, if you are receiving emails from us, you may unsubscribe at any time by following the instructions included within the email. You may of course contact us directly about this. Please inform us directly if you do not wish a voicemail to be left. When you opt out of these communications, we will suppress your details on our systems to ensure we have a record of your decision to not be contacted in that particular manner. We will not use the email address or phone number for such messages again unless you opt back in.

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13. How do we make changes to this Privacy Notice?

 

We may update this Privacy Notice from time to time. We will notify you of any changes by posting the new Privacy Notice on our website. You are advised to review this periodically for any changes. Changes to this Privacy Notice are effective when they are posted on our website -    https://www.rjtpsychology.co.uk/about-7. If you would like a copy please email your request to  rachel@rjtpsychology.co.uk.

This Privacy Notice was written on 4.5.18 and was last updated on 28.6.23.

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14. Making a complaint

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. Contact details can be found at www.ico.org.uk. You can also contact them by phoning 0303 123 113.

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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. We can be contacted via email - rachel@rjtpsychology.co.uk, telephone – 07419 994522 or by writing to Dr Rachel Toole, Room 31, Haling Dene Centre, Cannock Road, Penkridge, Stafford, ST19 5DT.

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15. How to contact us about this Privacy Notice

If you have any questions or comments about this Privacy Notice or should you wish to exercise your Data Protection Rights we can be contacted via email - rachel@rjtpsychology.co.uk, telephone – 07419 994522 or by writing to Dr Rachel Toole, Room 31, Haling Dene Centre, Cannock Road, Penkridge, Stafford, ST19 5DT.