1. Introduction

Feel Well Therapy is committed to protecting the privacy and security of your personal information. We take care to protect the privacy of our clients, referrers, employers and Associate Therapists details when they communicate (online or offline) with us, at events, over the phone, through our websites and social media platforms.

We have therefore developed this privacy policy to inform you of the data we collect, what we do with your information, what we do to keep it secure as well as the rights and choices you have over your personal information.

For the purpose of Data Protection Regulations, the data controller is Feel Well Therapy, with the registered address at The Feel Well Centre 22 High street Loddon Norwich NR146AH.

When we are referring to ‘we, us or our we mean Feel Well Therapy.

2. The information we collect and when

We only collect information that we know we will genuinely use and in accordance with the General Data Protection Regulation (GDPR) 2018 and applicable clinical confidentiality guidelines set out by  Professional Bodies such as the BPS, BABCP or BACP.  We may hold and use personal data about you as a client,  FWT Associate, FWC member, when you visit our website, complete a form, email us, or access our service or speak to us. This may include sensitive personal data such as information on your mental health.

The type of information that we will collect on you, receive or send to authorised third parties with your permission, may include the following. By providing us with this information you are giving us your explicit consent to process this data for the purposes of providing a service to you, or working as an Associate therapist or FWC member. 

• Your name.
• Date of Birth.
• Address.
• Telephone number(s).
• Gp details.
• Email address.
• Emergency contact person.
• Employment details if relevant.
• Health insurance details if relevant.
• Clinical notes and reports about your health and treatment that has been kept during treatment or received from or sent to authorised third parties.
• Details of referrals, correspondence that we may have had with you or sent to us via third parties.
• Client feedback and treatment outcome information you provide.
• Survey responses.
• Information that we request to become an Associate therapist or FWC member  including name, address, bank details, references, DBS certificate and any other relevant details.
• Information you give us if you make a payment to us.
• Information about complaints and incidents.
• Other information received from other sources, including enquiries that you have made via our website, analytics providers, or information provided by other companies who have obtained your permission to share information about you.
• Where you use our website we may automatically collect personal data about you including your Internet protocol (IP) address, information about your visit to our site including the URL and pages you searched or clicked on. Our website uses cookies to distinguish you from other users of our websites. When you first access our website we will request your permission for us to use Cookies. Please follow the link for more information.
  

3. How we use your information

• To contact you, following your enquiry, reply to any questions, suggestions, issues or complaints you have contacted us about;
• Provide you with the information , services that you request from us ;
• To enable us to carry out our contractual obligations to you arising from any contract entered into between you and us;
• To enable us to carry out our contractual obligations to third parties such as your employer, solicitor, NHS provider who may have referred you to us for treatment;
• To as required enable us to undertake audits, in order to check the accuracy of information we hold on you and the quality of the treatment or care that you have received; 
• To provide you with information that we think might be of interest to you provided you have given us your consent to contact you; 
• To take payment from you or give you a refund;
• For statistical analysis and to get feedback from you about our services, websites and other services and activities. For example, we routinely ask for feedback via our client satisfaction questionnaire;

• To power our security measures and services so you can safely access our website;
• To provide you with information on wellbeing and mental health related issues via our Facebook page if you chose to like and follow us;
• We will not pass your information onto others for commercial purposes, unless you have given us your written consent to do so.
  

4. Who we might share your information with

We may share your personal data with others in the following circumstances:

• If the law or a public authority says we must share the personal data;
• If we need to share personal data in order to establish, exercise or defend our legal rights (this includes providing personal data to others for the purposes of preventing fraud and reducing credit risk); or
• From time to time, employ the services of other parties for dealing with certain processes necessary for the operation of the Website. However, all the information we share will be collected and anonymised, so neither you nor any of your devices can be identified from it.
• With our Associate Therapists to enable them to provide appropriate treatment to you. Associate therapists will be operating under contractual restrictions in regard to confidentiality and security in addition to their obligations under the Data Protection Law. They will be required to keep their own clinical records in accordance with Data Protection Laws.
• Your GP provided you give us consent to do so. Under rare circumstances we or our Associate Therapists have a statutory obligation to break confidentiality, namely if we believe that a client is at risk to themselves or others under the Mental Health Act 2007, or if we believe that a child is at risk of  significant  harm under the Children’s Act section 47, 1989. In these instances we will contact your Gp and relevant authorities.
• Your insurer, solicitor or employer, or the NHS if they referred you to us provided we have your consent.
• Professional regulators in the event that a complaint is made about a professionals conduct and this needs to be investigated by their professional regulatory body.
• Professionals are required to undertake supervision by their regulatory body as a means of ensuring good practice, this involve discussing client details with other professional, however this will always be done anonymously.
  

5. How we keep you updated on our services

We may send you relevant information on our services by email on occasions, but only if you have previously consented to receive these when you complete your therapy contract. You can opt out of this choice at any time by unsubscribing from our emails via a link or by sending us a written request to do so.

6. Your rights over your information

6.1.1 Right to Access Your Personal Information

You have the right to access the personal information that we hold about you in many circumstances, by making a request. This is sometimes termed ‘Subject Access Request’. If we agree that we are obliged to provide personal information to you (or someone else on your behalf), we will provide it to you or them free of charge and aim to do so within 30 days from when your identity has been confirmed.

We would ask for proof of identity and sufficient information about your interactions with us that we can locate your personal information.

If you would like to exercise this right, please contact us as set out below.

6.1.2 Right to Correction Your Personal Information

If any of the personal information we hold about you is inaccurate or out of date, you may ask us to correct it. It is important to understand that this right does not extend to matters of opinion by clinicians.

If you would like to exercise this right, please contact us as set out below.

6.1.3 Right to Stop or Limit Our Processing of Your Data

You have the right to object to us processing your personal information if we are not entitled to use it any more, to have your information deleted if we are keeping it too long or have its processing restricted in certain circumstances.

If you would like to exercise this right, please contact us as set out below.

6.1.4 For more information about your privacy rights 

The Information Commissioner’s Office (ICO) regulates data protection and privacy matters in the UK. They make a lot of information accessible to consumers on their website and they ensure that the registered details of all data controllers such as ourselves are available publicly. You can access them here https://ico.org.uk/for-the-public.

You can make a complaint to the ICO at any time about the way we use your information. However, we hope that you would consider raising any issue or complaint you have with us first. Your satisfaction is extremely important to us, and we will always do our very best to solve any problems you may have.

7. How long we keep your information for

We retain a record of your personal information in order to provide you with a high quality and consistent service. We will always retain your personal information in accordance with the General Data Protection Regulation (GDPR) and never retain your information for longer than is necessary.

If you are a client then we are required by law to keep your clinical records for a period of 7 years after our last contact with you at which point they will be deleted/ shredded. For children this will be until the age of 25. In some circumstances we may anonymous your personal information so that it is no longer associated with you i.e. Clinical outcome data and retain this indefinitely in order to monitor and evaluate our service. . If you are not happy for us to do this then please let us know.

If you are an employee or Associate therapist then we will retain and securely destroy your personal information in accordance with applicable laws and regulations.

8. Giving your reviews and sharing your thoughts

When using our website, you may be able to share information through social networks like Facebook and Twitter. For example, when you ‘like’, ‘share’ or review our Services. When doing this, your personal information may be visible to the providers of those social networks and/or their other users. Please remember it is your responsibility to set appropriate privacy settings on your social network accounts so you are comfortable with how your information is used and shared on them.

9. Security

Data security is of great importance to Feel Well Therapy and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure your collected data. 

We take security measures to protect your information including:

• Ensuring that Associate therapists and employees are aware of FWT‘s Privacy Policy and their own obligations under Data protection Law.
• Restricting access to personal data of clients / employees/ Associate Therapists to only those that are required to access it for the purposes of carrying out the agreed service or job role.
• Ensuring that 3^rd parties, Associates who process information on our behalf  are aware of their contractual obligations as a data processor and under Data Protection Regulation.
• Ensuring that computers, phones and portable data storage devices are password protected.
• Ensuring that computers are fitted with malicious software including firewalls and anti-virus protection.
• Ensuring that written note are not left unattended, and always stored in a locked filing cabinet at the end of the day.
• Ensuring that personal information (notes, reports etc.) are kept securely whilst in transit from a clinical base.
• Ensuring that written consent for sharing information is always obtained in the first therapy session and a copy of this given to clients if they wish this.
• Ensure that personal data sent by email to third parties, Associates (i.e. reports) is password protected and sent via an encrypted email provider.
• Burning or shredding confidential information once the time period for retention has lapsed.
• Having an SSl certificate on our website to encrypt the communication between our website and the user.
• Being registered with the Information Commissioners office (ICO).
• Personal data shall not be transferred to a country or territory outside of the European Economic Area (EEA) unless that country or territory ensures an adequate level of protection in accordance with Data Protection Laws.

Please note that sending information directly to our email address [email protected] may not be completely secure as sending information in this way cannot be totally guaranteed. If you do communicate with us via this route then we suggest you only send limited information and ask us to get back to you.

Please also note that our website and Facebook page may contain links to other external sites, these sites have their own privacy policies and we are not responsible for their content and you should check their privacy policy before submitting any personal information.

10. How to contact us

Feel Well Therapy has used reasonable means in compiling this privacy policy. In the event that we have made any material errors or omissions, please notify us of this and we will rectify them in a timely manner.

If you would like to exercise one of your rights as set out above, or you have a question or a complaint about this policy or the way your personal information is processed, please contact us by one of the following means:

By email: to Michelle Webster at  [email protected]
By post: Feel Well Therapy, 22 High street Loddon  Norwich, and NR146AH.

Thank you for taking the time to read our Privacy Policy. If you feel that we could improve our policy or see any inaccuracies please let us know. 

Feel Well Therapy

This Policy was last updated on 17th of august 2023 .