Data Protection Policy…
Ultimate Resilience is a trading name of East Midlands Psychology Ltd. East Midlands Psychology Ltd needs to collect and use certain types of information about the Individuals or Service Users who come into contact with East Midlands Psychology Ltd in order to carry on our work. This personal information must be collected and dealt with appropriately whether is collected on paper, stored in a computer database, or recorded on other material and there are safeguards to ensure this under the Data Protection Act 1998.
East Midlands Psychology Ltd is the Data Controller under the Act, which means that it determines what purposes personal information held, will be used for. It is also responsible for notifying the Information Commissioner of the data it holds or is likely to hold, and the general purposes that this data will be used for.
East Midlands Psychology Ltd may share data with other agencies such as the local authority, funding bodies and other voluntary agencies.
The Individual/Service User will be made aware in most circumstances how and with whom their information will be shared. There are circumstances where the law allows East Midlands Psychology Ltd to disclose data (including sensitive data) without the data subject’s consent. These are:
a Carrying out a legal duty or as authorised by the Secretary of State
b Protecting vital interests of a Individual/Service User or other person
c The Individual/Service User has already made the information public
d Conducting any legal proceedings, obtaining legal advice or defending any legal rights
e Monitoring for equal opportunities purposes – i.e. race, disability or religion
f Providing a confidential service where the Individual/Service User’s consent can not be obtained or where it is reasonable to proceed without consent: e.g. where we would wish to avoid forcing stressed or ill Individuals/Service Users to provide consent signatures.
East Midlands Psychology Ltd regards the lawful and correct treatment of personal information as very important to successful working, and to maintaining the confidence of those with whom we deal.
East Midlands Psychology Ltd intends to ensure that personal information is treated lawfully and correctly.
To this end, East Midlands Psychology Ltd will adhere to the Principles of Data Protection, as detailed in the Data Protection Act 1998. Specifically, the Principles require that personal information:
a Shall be processed fairly and lawfully and, in particular, shall not be processed unless specific conditions are met,
b Shall be obtained only for one or more of the purposes specified in the Act, and shall not be processed in any manner incompatible with that purpose or those purposes,
c Shall be adequate, relevant and not excessive in relation to those purpose(s)
d Shall be accurate and, where necessary, kept up to date,
e Shall not be kept for longer than is necessary
f Shall be processed in accordance with the rights of data subjects under the Act,
g Shall be kept secure by the Data Controller who takes appropriate technical and other measures to prevent unauthorised or unlawful processing or accidental loss or destruction of, or damage to, personal information,
h Shall not be transferred to a country or territory outside the European Economic Area unless that country or territory ensures an adequate level of protection for the rights and freedoms of Individuals/Service Users in relation to the processing of personal information.
East Midlands Psychology Ltd will, through appropriate management and strict application of criteria and controls:
a Observe fully conditions regarding the fair collection and use of information
b Meet its legal obligations to specify the purposes for which information is used
c Collect and process appropriate information, and only to the extent that it is needed to fulfil its operational needs or to comply with any legal requirements
d Ensure the quality of information used
e Ensure that the rights of people about whom information is held, can be fully exercised under the Act. These include:
- The right to be informed that processing is being undertaken,
- The right of access to one’s personal information
- The right to prevent processing in certain circumstances and
- The right to correct, rectify, block or erase information which is regarded as wrong information
f Take appropriate technical and organisational security measures to safeguard personal information
g Ensure that personal information is not transferred abroad without suitable safeguards
h Treat people justly and fairly whatever their age, religion, disability, gender, sexual orientation or ethnicity when dealing with requests for information
i Set out clear procedures for responding to requests for information
Informed consent is when
- An Individual/Service User clearly understands why their information is needed, who it will be shared with, the possible consequences of them agreeing or refusing the proposed use of the data
- And then gives their consent.
East Midlands Psychology Ltd will ensure that data is collected within the boundaries defined in this policy. This applies to data that is collected in person, or by completing a form.When collecting data, East Midlands Psychology Ltd will ensure that the Individual/Service User:
a Clearly understands why the information is needed
b Understands what it will be used for and what the consequences are should the Individual/Service User decide not to give consent to processing
c As far as reasonably possible, grants explicit consent, either written or verbal for data to be processed
d Is, as far as reasonably practicable, competent enough to give consent and has given so freely without any duress
e Has received sufficient information on why their data is needed and how it will be used.
Information and records relating to service users will be stored securely and will only be accessible to authorised staff and volunteers.
Information will be stored for only as long as it is needed or required statute and will be disposed of appropriately.
It is East Midlands Psychology Ltd’s responsibility to ensure all personal and company data is non-recoverable from any computer system previously used within the organisation, which has been passed on/sold to a third party.
Data Access and Accuracy
All Individuals/Service Users have the right to access the information East Midlands Psychology Ltd holds about them. East Midlands Psychology Ltd will also take reasonable steps ensure that this information is kept up to date by asking data subjects whether there have been any changes.
In addition, East Midlands Psychology will ensure that:
- It has a Data Protection Officer with specific responsibility for ensuring compliance with Data Protection
- Everyone processing personal information understands that they are contractually responsible for following good data protection practice
- Everyone processing personal information is appropriately trained to do so
- Everyone processing personal information is appropriately supervised
- Anybody wanting to make enquiries about handling personal information knows what to do
- It deals promptly and courteously with any enquiries about handling personal information
- It describes clearly how it handles personal information
- It will regularly review and audit the ways it hold, manage and use personal information
- It regularly assesses and evaluates its methods and performance in relation to handling personal information
- All staff are aware that a breach of the rules and procedures identified in this policy may lead to disciplinary action being taken against them.This policy will be updated as necessary to reflect best practice in data management, security and control and to ensure compliance with any changes or amendments made to the Data Protection Act 1998.
Protecting your personal details on our website
The Website is brought to you by East Midlands Psychology Ltd. East Midlands Psychology Ltd believes it is important to protect your Personal Data (as defined in the Data Protection Act 1998) and we are committed to giving you a personalised service that meets your needs in a way that also protects your privacy. This policy explains how we may collect Personal Data about you. It also explains some of the security measures we take to protect your Personal Data, and tells you certain things we will do and not do. You should read this policy in conjunction with the Website Terms.
When we first obtain Personal Data from you, or when you take a new service or product from us, we will give you the opportunity to tell us if you do or do not want receive information from us about other services or products (as applicable). You can normally do this by ticking a box on an application form or contract. You may change your mind at any time by emailing us at the address below.
Some of the Personal Data we hold about you may be ‘sensitive personal data’ within the meaning of the Data Protection Act 1998, for example, information about your health or ethnic origin.
We may collect Personal Data about you from a number of sources, including the following:
1.1. From you when you agree to take a service or product from us, in which case this may include your contact details, date of birth, how you will pay for the product or service and your bank details.
1.2. From you when you contact us with an enquiry or in response to a communication from us, in which case, this may tell us something about how you use our services.
1.3. From documents that are available to the public, such as the electoral register.
Using Your Personal Information
2.1. Personal Data about our customers is an important part of our business and we shall only use your Personal Data for the following purposes and shall not keep such Personal Data longer than is necessary to fulfil these purposes:
2.1.1. To help us to identify you when you contact us.
2.1.2. To help us to identify accounts, services and/or products which you could have from us or selected partners from time to time. We may do this by automatic means using a scoring system, which uses the Personal Data you have provided and/or any information we hold about you and Personal Data from third party agencies (including credit reference agencies).
2.1.3. To help us to administer and to contact you about improved administration of any accounts, services and products we have provided before, do provide now or will or may provide in the future.
2.1.4. To allow us to carry out marketing analysis and customer profiling (including with transactional information), conduct research, including creating statistical and testing information.
2.1.5. To help to prevent and detect fraud or loss.
2.1.6. To allow us to contact you in any way (including mail, email, telephone, visit, text or multimedia messages) about products and services offered by us and selected partners unless you have previously asked us not to do so.
2.1.7. We may monitor and record communications with you (including phone conversations and emails) for quality assurance and compliance.
2.1.8. We may check your details with fraud prevention agencies. If you provide false or inaccurate information and we suspect fraud, we will record this.
2.3. We may allow other people and organisations to use Personal Data we hold about you in the following circumstances:
2.3.1. If we, or substantially all of our assets, are acquired or are in the process of being acquired by a third party, in which case Personal Data held by us, about our customers, will be one of the transferred assets.
2.3.2. If we have been legitimately asked to provide information for legal or regulatory purposes or as part of legal proceedings or prospective legal proceedings.
2.5. In connection with any transaction which we enter into with you:
2.5.1. We, and other companies in our group, may carry out credit and fraud prevention checks with one or more licensed credit reference and fraud prevention agencies. We and they may keep a record of the search. Information held about you by these agencies may be linked to records relating to other people living at the same address with whom you are financially linked. These records will also be taken into account in credit and fraud prevention checks. Information from your application and payment details of your account will be recorded with one or more of these agencies and may be shared with other organisations to help make credit and insurance decisions about you and members of your household with whom you are financially linked and for debt collection and fraud prevention. This includes those who have moved house and who have missed payments.
2.5.2. If you provide false or inaccurate information to us and we suspect fraud, we will record this and may share it with other people and organisations. We, and other credit and insurance organisations, may also use technology to detect and prevent fraud.
2.5.3. If you need details of those credit agencies and fraud prevention agencies from which we obtain and with which we record information about you, please write to our Data Protection Manager at East Midlands Psychology Ltd, 10 Milton Court, Ravenshead, Nottingham, NG15 9BD.
We have strict security measures to protect Personal Data.
3.1. We work to protect the security of your information during transmission by using Secure Sockets Layer (SSL) software, which encrypts information you input.
3.2. We reveal only the last five digits of your credit card numbers when confirming an order. Of course, we transmit the entire credit card number to the appropriate credit card company during order processing.
3.3. We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personally identifiable customer information. Our security procedures mean that we may occasionally request proof of identity before we disclose personal information to you.
3.4. It is important for you to protect against unauthorised access to your password and to your computer. Be sure to sign off when you finish using a shared computer.
4.1. If you communicate with us using the internet, we may occasionally email you about our services and products. When you first give us Personal Data through the Website, we will normally give you the opportunity to say whether you would prefer us not to contact you by email. You can also always send us an email (at the address set out below) at any time if you change your mind.
4.2. Please remember that communications over the internet, such as emails and webmails (messages sent through a website), are not secure unless they have been encrypted. Your communications may go through a number of countries before they are delivered – this is the nature of the internet. We cannot accept responsibility for any unauthorised access or loss of Personal Data that is beyond our control.
5.1. The Website may include third-party advertising and links to other websites. We do not provide any personally identifiable customer Personal Data to these advertisers or third-party websites.
5.3. We exclude all liability for loss that you may incur when using these third party websites.
6.4. If you would like access to the Personal Data that we hold about you, you can do this by emailing us at email@example.com or writing to us at the address noted above. There may be a nominal charge of £10 to cover administrative costs.
6.5. We aim to keep the Personal Data we hold about you accurate and up to date. If you tell us that we are holding any inaccurate Personal Data about you, we will delete it or correct it promptly. Please email us at firstname.lastname@example.org or write to us at the address above to update your Personal Data.