PRIVACY POLICY
POSITIVE HYPNO holds some information about you. This document outlines how that information is used, who we may share that information with and how we keep it secure. This notice does not provide exhaustive detail. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to info@PositiveHypno.co.uk. We keep our Privacy Notice under regular review. This Privacy Notice was last reviewed in March 2019
- What We Do
Positive Hypno provides hypnotherapy services to clients. Positive Hypno also provide workshops and presentations to groups both in private and corporate settings, whereby we aim to educate attendees on lifestyle advice, or provide group hypnotherapy sessions.
- How We Obtain Your Personal Data
Information provided by you
You provide us with personal data in the following ways:
- By completing a registration form
- By signing a terms of engagement form
- During a hypnotherapy consultation
- Through email, over the telephone, online platforms such as Skype and Zoom, and by post
- By providing credit card or online payment
This may include the following information:
- basic details such as name, address, contact details and next of kin
- details of contact we have had with you such as referrals and appointment requests
- health information including your previous medical history, dietary, lifestyle and clinic notes
- GP contact information
We use this information in order to provide you with the hypnotherapy service. This means that the legal basis of our holding your personal data is for legitimate interest.
Following completion of your sessions, we retain your personal data for the period defined by our professional association NGHand registrant body, CNHC. This enables us to process any complaint you may make. In this case the legal basis of our holding your personal data is for contract administration.
- How we use your personal data
We act as a data controller for use of your personal data to provide direct healthcare. We act as a data controller and processor in regard to the processing of credit card and online payments.
We undertake at all times to protect your personal data, including any health and contact details, in a manner which is consistent with our duty of professional confidence and the requirements of the General Data Protection Regulation (GDPR) concerning data protection. We will also take reasonable security measures to protect your personal data storage.
We may use your personal data where there is an overriding public interest in using the information e.g. in order to safeguard an individual, or to prevent a serious crime. Also where there is a legal requirement such as a formal court order. We may use your data for marketing purposes such as newsletters but this would be subject to you giving us your express consent.
- Do you share my information with other organisations?
We will keep information about you confidential. We will only disclose your information with other third parties with your express consent, with the exception of the following categories of third parties:
- Our registrant body, CNHC, and our professional association, NGH, for the processing of a complaint made by you
- Anyone to whom we may transfer our rights and duties under any agreement we have with you
- Any legal or crime prevention agencies and/or to satisfy any regulatory request (eg, CNHC) if we have a duty to do so or if the law allows us to do so
We will seek your express consent before sharing your information with your GP or other healthcare providers. However if we believe that your life is in danger then we may pass your information onto an appropriate authority (such as the police, social services in the case of a child or vulnerable adult, or GP in case of self-harm) using the legal basis of vital interests.
We may share your case history in an anonymised form with our peers for the purpose of professional development. This may be at clinical supervision meetings, conferences, online forums, and through publishing in medical journals, trade magazines or online professional sites. We will seek your explicit consent before processing your data in this way.
- What are your rights?
Every individual has the right to see, amend, delete or have a copy, of data held that can identify you, with some exceptions. You do not need to give a reason to see your data.
If you want to access your data you must make a subject access request in writing to info@PositiveHypno.co.uk. Under special circumstances, some information may be withheld. We shall respond within 14 working days from the point of receiving the request and all necessary information from you. Our response will include the details of the personal data we hold on you including:
- Sources from which we acquired the information
- The purposes of processing the information
- Persons or entities with whom we are sharing the information
You have the right, subject to exemptions, to ask to:
- Have your information deleted
- Have your information corrected or updated where it is no longer accurate
- Ask us to stop processing information about you where we are not required to do so by law or in accordance with the NGH and CNHC guidelines.
- Receive a copy of your personal data, which you have provided to us, in a structured, commonly used and machine readable format and have the right to transmit that data to another controller, without hindrance from us.
- Object at any time to the processing of personal data concerning you
We do not carry out any automated processing, which may lead to automated decision based on your personal data.
If you would like to invoke any of the above rights then please contact Gaynor Wilson (Data Controller) by emailing info@PositiveHypno.co.uk
- What safeguards are in place to ensure data that identifies me is secure?
We only use information that may identify you in accordance with GDPR. This requires us to process personal data only if there is a legitimate basis for doing so and that any processing must be fair and lawful.
We also ensure the information we hold is kept in secure locations, restrict access to information to authorised personnel only, protect personal and confidential information held on equipment such as laptops with encryption (which masks data so that unauthorised users cannot see or make sense of it). We ensure external data processors that support us are legally and contractually bound to operate and prove security arrangements are in place where data that could or does identify a person are processed.
Positive Hypno is registered with the Information Commissioner’s Office (ICO) as a data controller and collects data for a variety of purposes. A copy of the registration is available through the ICO website (search by business name).
- How long do you hold confidential information for?
All records held by the Positive Hypno will be kept for the duration specified by guidance from our professional association CNHC
- Website technical details
Forms
We do use electronic forms on our website making use of an available ‘forms module’ which has a number of built-in features to help ensure privacy. We also aim to use secure forms where appropriate.
In compliance with EU legislation, our cookie policy can seen here: PositiveHypno.co.uk/cookies/
Analytics
Like most websites, we make use of analytics software in order to help us understand the trends in popularity of our website and of different sections. We make no use of personally identifiable information in any of the statistical reports we use from this package. We use an analytics package called Google Analytics who provide details of their privacy policy on the Google website.
- Complaints
If you have a complaint regarding the use of your personal data then please contact us by writing to Gaynor Wilson at info@PositiveHypno.co.uk and we will do our best to help you.
If your complaint is not resolved to your satisfaction and you wish to make a formal complaint to the Information Commissioner’s Office (ICO), you can contact them on 01625 545745 or 0303 1231113