Privacy notice

 

INTRODUCTION
Your privacy is very important to us and you can be confident that your personal information will be kept safe and secure and will only be used for the purpose it was given to us. We adhere to current data protection legislation, including the General Data Protection Regulation (EU/2016/679) (the GDPR), the Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2003.


This privacy notice tells you what we will do with your personal information from initial point of contact through to after your work with us has ended, including:

  • Why we are able to process your information and what purposes we process it for
  • Whether you have to provide it to us
  • How long we store it for
  • Whether there are other recipients of your personal information
  • Whether we intend to transfer it to another country
  • Whether we carry out automated decision-making or profiling, and
  • Your data protection rights.

We are happy to respond to any questions you might have about our data protection policy and you can contact the Family Separation Clinic at any time via office@familyseparationclinic.co.uk


‘Data controller’ is the term used to describe the person/organisation that collects and stores and has responsibility for people’s personal data. In this instance, the data controller is Family Separation Clinic LLP.


Family Separation Clinic LLP is registered with the Information Commissioner’s Office. Our registration number is ZA806410.

 

Our postal address is Family Separation Clinic LLP | 50 Liverpool Street | London | EC2M 7PY


Our lawful basis for holding and using your personal information
The GDPR states that we must have a lawful basis for processing your personal data. There are different lawful bases depending on the stage at which we are processing your data. We explain these below:


If you have had a personal consultation, engaged in therapy, attended a training or coaching event, been a party to court proceedings in which we were instructed, or engaged with any other service provided by the Family Separation Clinic LLP or anyone acting on our behalf, whether online or in person, and it has now ended, we will use legitimate interest as our lawful basis for holding and using your personal information.


If you are currently engaging us in any of the services listed above, or if you are in contact with us to consider engaging us in any such services, we will process your personal data where it is necessary for the performance of our contract.


The GDPR also makes sure that we look after any sensitive personal information that you may disclose to us appropriately. This type of information is called ‘special category personal information’. The lawful basis for us processing any special categories of personal information is that it is for provision of health or health related treatment (for example, psychotherapy, therapeutic coaching etc) and necessary for a contract (explicit or implied) with us. Data concerning health means personal data related to the physical or mental health of a natural person, including the provision of health care services, which reveal information about his or her health status.


How we use your information
Initial contact: When you contact us with an enquiry about our services, we will collect information to help us satisfy your enquiry. This will include your name, email address and any other information you may provide. Alternatively, another professional (for example, your legal representative) may send us your details when making a referral, or a parent or trusted individual may give us your details when making an enquiry on your behalf.


If you decide not to proceed we will ensure all your personal data is deleted within six months. If you would like us to delete this information sooner, please let us know.


While you are accessing our services: Everything you discuss or share with us is confidential. That confidentiality will only be broken:

  • Where we are required to as part of a court ordered or court based process
  • Where we are legally compelled to do so
  • Where we have reason to believe that someone, especially a child, is at risk of harm
  • Where there is a duty to the public to disclose
  • Where disclosure is permitted by law and required to protect our interest
  • Where disclosure is made at your request or with your consent

This will only happen in special circumstances where we believe it is absolutely necessary. Whenever possible we will talk to you before this happens, unless there are safeguarding issues that prevent this.


We will keep a record of your personal details to help us provide you with a high quality service. These details are kept securely and are not shared with any third party.


We may keep written notes of our work with you. These will be held for three years, in case you choose to access our services again. Written notes are securely destroyed three years after our last service delivery to you.


We do not retain text messages for more than one year. If there is relevant information contained in a text message we may transfer this to our written records. Likewise, any email correspondence will be deleted after one year if it is not important, otherwise, it will be retained in accordance with our policy for written notes.


After the work has ended: Once the work we are doing with you has ended your records will be kept for three years from the end of our contact (written or implied) and are then securely destroyed.


Where we have been provided with a ‘court bundle,’ this will be destroyed at the point at which we are no longer instructed.
Our policies on document retention may be superseded by a relevant order from a court.


Third party recipients of personal data
We sometimes share personal data with third parties, for example, where we have contracted with a supplier to carry out specific tasks. In such cases we have carefully selected which partners we work with. We take great care to ensure that we have a contract with the third party that states what they are allowed to do with the data we share with them. We ensure that they do not use your information in any way other than the task for which they have been contracted


Your rights
We aim to be as open as we can be in terms of giving people access to their personal information. You have a right to ask us to delete your personal information, to limit how we use your personal information, or to stop processing your personal information. You also have a right to ask for a copy of any information that we hold about you and to object to the use of your personal data in some circumstances. You can read more about your rights at https://ico.org.uk/for-the-public/


If we do hold information about you, we will:

  • give you a description of it and where it came from;
  • tell you why we are holding it, tell you how long we will store your data and how we made this decision;
  • tell you who it could be disclosed to;
  • let you have a copy of the information in an intelligible form.

You can also ask us, at any time, to correct any mistakes there may be in the personal information we hold about you.
To make a request for any personal information we may hold about you, please put the request in writing addressing it to office@familyseparationclinic.co.uk


If you have any complaint about how we handle your personal data please do not hesitate to get in touch with us by writing or emailing to the contact details given above.


If you want to make a formal complaint about the way we have processed your personal information you can contact the ICO which is the statutory body that oversees data protection law in the UK. For more information go to ico.org.uk/make-a-complaint.

 

Data security
We take the security of the data we hold about you very seriously and, as such, we take every effort to make sure it is kept secure. Any information that we may keep about you on paper is stored in a locked filing cabinet, locked cupboard or other secure storage, in secure premises. Any information that we may keep about you in electronic form is stored on encrypted and password protected devices.


When you use our website
We have a specific Privacy Policy that covers our website. To read this policy, please visit https://www.familyseparationclinic.com/j/privacy