Privacy Policy

Select Psychology is committed to protecting and respecting your privacy.

We understand that your personal data is entrusted to us and we appreciate the importance of protecting and respecting your privacy. To this end, we comply fully with the data protection law in force in the UK ("Data Protection Laws") and with all applicable clinical confidentiality guidelines.

This Privacy Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. It explains our practices regarding the collection, use, storage and disclosure of personal information that we hold about you.

Please read the following carefully to understand our practices regarding your personal data, how we will treat it and your rights in relation to that data. By providing your personal data to us or by using our services, website or other online or digital platform(s) you are accepting or consenting to the practices as described or referred to in this Privacy Policy.

For the purpose of Data Protection Laws, the data controller is Select Psychology with a registered address at: 1 Tynemouth Road, North Shields, NE30 4AY, registered in England and Wales, company number 9395957.

When we refer to 'we', 'us' and 'our', we mean Select Psychology.

What personal data may we collect from you?

When we refer to personal data in this policy, we mean information that can, or has the potential to, identify you as an individual.

Accordingly, we may hold and use personal data about you as a customer, a patient or in any other capacity, for example when you visit one of our websites, complete a form, access our services or speak to us.

Personal data we collect from you may include the following:

Information that you give us when you enquire, become a customer or patient, or apply for a job with us, including name, address and contact details (email address and phone number).
Details of referrals, quotes and other contact and correspondence we may have had with you.
Details of services or treatment you have received from us, or which have been received from a third party and referred to us.
Information obtained from customer surveys, promotions and competitions that you have entered or taken part in.
Notes and reports about your health and any treatment and care you have received or need, including visits to our clinics.
Patient feedback and treatment outcome information you provide.
Information about complaints and incidents.
Information you give us when you make a payment to us, such as financial or credit card information.
Other information received from other sources, including your use of websites and other digital platforms we operate, business partners, advertising networks, analytics providers, or other companies who have obtained your permission to share information.

Where you use any of our websites, we may automatically collect personal data about you including:

Technical information, including the Internet Protocol (IP) address used to connect your computer to the internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.
Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs), and methods used to browse away from the page.

The data that we request from you may include special category data. This includes information that relates to the following:

Racial or ethnic origin.
Political opinions.
Religious or philosophical beliefs.
Trade union membership.
Genetic data, or biometric data for the purpose of uniquely identifying a natural person.
Health data, or data concerning a natural person's sex life or sexual orientation.

When do we collect personal data about you?

We may collect personal data about you if you:

Visit one of our websites.
Enquire about any of our services.
Register to be a customer or patient with us, or book to receive any of our services.
Fill in a form or survey for us.
Carry out a transaction on our website.
Participate in a competition, promotion or other marketing activity.
Make online payments.
Contact us, for example by email, telephone or social media.
Participate in interactive features on any of our platforms.

What personal data may we receive from third parties and other sources?

We may collect personal data about you from third parties such as:

If you are an employee of one of our corporate clients who has taken up one of our services, we may be passed your name, contact number and email address in order to get in touch with you to arrange an appointment or collect further information.
We have a number of independent third parties acting on our behalf who may collect personal data from you to allow us to carry out the services we offer. For example, an independent General Practitioner may carry out a consultation and collect personal data from you which is subsequently shared with Select Psychology for the continuity of your care, and may be used for quality and monitoring purposes.
We may receive information from the NHS. For the continuity of your care we may be passed medical information, usually in the form of a referral, for the purposes of your treatment with Select Psychology or a third-party consultant.
Insurance providers will pass Select Psychology personal data of patients who have commenced a claim and require treatment with Select Psychology. This will normally be in the form of a referral and may consist of basic details such as full name, date of birth, address, contact number, email address and the type of procedure or treatment required.

How do we lawfully process your personal data?

Your personal data will be kept confidential and secure and will only be used for the purpose(s) for which it was collected and in accordance with this Privacy Policy, applicable Data Protection Laws, clinical records retention periods and clinical confidentiality guidelines.

Set out below are some of the ways in which we process personal data. To do so lawfully we need a legal ground. We normally process personal data if it is:

Necessary to provide you with our services: to carry out our obligations arising from any contract entered into between us and you, including the provision of services or treatments and related matters such as billing, accounting and audit, credit or payment card verification and anti-fraud screening.
In our or a third party's legitimate interests to do so (see details below).
Required or allowed by any applicable law.
With your explicit consent, for example for direct marketing communications.

Generally, we will only ask for your consent to process if there are no other legal grounds to process. In these circumstances, we will always aim to be clear and transparent about why we need your consent and what we are asking it for. Where we are relying on consent, you have the right to withdraw it at any time by contacting us using the details below, and we will stop the processing for which consent was obtained.

To process special category data we rely on additional legal grounds, which generally are as follows:

With your explicit consent.
It is necessary for the purposes of treatment, to assess whether you are able to work, to provide health or social care treatment, or to manage health or social care systems. This may also include monitoring whether the quality of our services or treatment is meeting expectations.
It is necessary to establish, make or defend legal claims or court action.
It is necessary so that we can comply with employment law.
It is necessary for a public interest purpose in line with applicable laws. This should assist in protecting the public against dishonesty, malpractice or other seriously improper behaviour, for example investigating complaints, clinical concerns, regulatory breaches or investigations by the HCPC or ICO.

Processing of personal data in our legitimate interests

One of the legal grounds for processing data is where it is in our legitimate interest to do so, taking into account your interests, rights and freedoms. This allows us to manage the relationship that exists between you and us, and can include the following reasons:

Provide you with information, products or services that you request from us.
Manage all aspects of our relationship with you, our products and services, and any third parties who may provide products or services on our behalf.
Allow you to participate in interactive features of our services, when you choose to do so.
Notify you about changes to our products or services.
Keep our records up to date.
Respond to requests where we have a legal or regulatory obligation to do so.
Check the accuracy of information about you and the quality of your treatment or care, including auditing medical and billing information for insurance claims and as part of any claims or litigation process.
Support your psychologist, counsellor or other healthcare professional.
Assess the quality and type of care you have received (including giving you the opportunity to complete satisfaction surveys) and any concerns or complaints you may raise, so that these can be properly investigated.
Conduct and analyse market research.
Ensure that content from any of our websites is presented in the most effective manner for you and your computer.
Enforce our website terms of use, our policy terms and conditions or other contracts, and protect our or others' rights, property or safety.
Share your personal information with people or organisations in order to run our business or comply with legal and regulatory obligations, including to defend ourselves from claims, exercise our rights and adhere to applicable laws and regulations.
Take part in, or be the subject of, any sale, purchase, merger or takeover of all or part of our business.

The security of your personal data

We protect all personal data we hold about you by ensuring that we have appropriate organisational and technical security measures in place to prevent unauthorised access or unlawful processing, and to prevent personal data from being lost, destroyed or damaged. We conduct assessments to ensure the ongoing security of our information systems.

Any personal data you provide will be held for as long as is necessary, having regard to the purpose for which it was collected and in accordance with all applicable UK laws.

Personal data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Where we transfer your personal data outside the EEA, we will ensure that there are adequate protections in place for your rights, in accordance with Data Protection Laws. By submitting your personal data you understand the basis for this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this Privacy Policy.

All information you provide to us is stored securely. Any payment transactions on our website are processed securely by third-party payment processors. Where we have given you (or you have chosen) a password that enables you to access certain parts of our website, you are responsible for keeping that password confidential. We ask you not to share a password with anyone.

The transmission of information via the internet cannot be guaranteed as completely secure. However, we ensure that any information transferred to our websites is via an encrypted connection. Once we have received your information, we use strict procedures and security features to minimise the risk of unauthorised access.

At your request, we may occasionally transfer personal information to you via email, or you may choose to transfer information to us via email. Email is not a secure method of information transmission; if you choose to send or receive such information via email, you do so understanding the risks associated with doing so.

How long do we retain your personal data?

Unless we explain otherwise to you, we will retain your personal data on the basis of the following guidelines:

For as long as we have a reasonable business need, such as managing our relationship with you and managing our business.
For as long as we provide services or treatment to you, and then for as long as someone could bring a claim against us (in general, a period of 8 years).
In line with legal and regulatory requirements.

Disclosure of your personal data to third parties

In the usual course of our business, we may disclose your personal data (limited to the extent reasonably necessary) to certain third-party organisations that we use to support the delivery of our services. This may include:

Business partners, suppliers and sub-contractors for the performance of any contract we enter into with you.
Organisations providing IT systems support and hosting in relation to the systems on which your information is stored.
Third-party debt collectors for the purposes of debt collection.
Delivery companies for the purposes of transportation.
Third-party service providers for the storage of information and confidential destruction, and third-party marketing companies for the purpose of sending marketing emails, subject to obtaining appropriate consent.

Where a third-party data processor is used, we ensure that they operate under contractual restrictions with regard to confidentiality and security, in addition to their obligations under Data Protection Laws.

We may also disclose your personal data to third parties in the event that we sell or buy any business or assets, or where we are required by law to do so.

Special category information collected during the provision of treatment or services

Special category data (including information relating to your health) will only be disclosed to third parties in accordance with this Privacy Policy. That includes third parties involved with your treatment or care, or in accordance with UK laws and the guidelines of appropriate professional bodies. Where applicable, it may be disclosed to any person or organisation responsible for meeting your treatment expenses or their agents. It may also be provided to external service providers and regulatory bodies (unless you object) for the purpose of clinical audit, to ensure the highest standards of care and record keeping are maintained.

Mental health professionals working with us: We share clinical information about you with our mental health professionals as we think necessary for your treatment. Mental health professionals working with us might be our employees, or independent consultants in private practice. In the case of independent consultants, the consultant is the data controller of your personal data, either alone or jointly with us, and will be required to maintain their own records in accordance with Data Protection Laws and applicable clinical confidentiality guidelines and retention periods. Where that is the case, we may refer you to that consultant to exercise your rights over your data. Our contracts with consultants require them to cooperate with those requests. In all circumstances, those consultants will only process your personal data for the purposes set out in this Privacy Policy or as otherwise notified to you.

External practitioners: If we refer you externally for treatment, we will share with the person or organisation we refer you to the clinical and administrative information we consider necessary for that referral. It will always be clear when we do this.

Your GP: If the practitioners treating you believe it to be clinically advisable, we may also share information about your treatment with your GP. You can ask us not to do this, in which case we will respect that request if we are legally permitted to do so, but you should be aware that it can be potentially very dangerous or detrimental to your health to deny your GP full information about your medical history, and we strongly advise against it.

Your insurer: We share with your medical insurer information about your treatment, its clinical necessity and its cost, only if they are paying for all or part of your treatment with us. We provide only the information to which they are entitled. If you raise a complaint or a claim we may be required to share personal data with your medical insurer for the purposes of investigating it.

The NHS: If you are referred to us for treatment by the NHS, we will share the details of your treatment with the part of the NHS that referred you, as necessary to perform, process and report back on that treatment.

Practice regulators: We may be requested, and in some cases required, to share certain information (including personal data and special category data) about you and your care with regulators such as the Health and Care Professions Council (HCPC), for example if you make a complaint, or if the conduct of a health and care professional involved in your treatment is alleged to have fallen below the appropriate standards and the regulator wishes to investigate. We will ensure that we do so within the framework of the law and with due respect for your privacy.

From time to time we may also make information available on the basis of necessity for the provision of healthcare, but subject always to patient confidentiality. In an emergency, and if you are incapacitated, we may also process your personal data (including special category data) or make it available to third parties on the basis of protecting your vital interests (that is, your life or your health).

We will use your personal data in order to monitor the outcome of your treatment by us and any treatment associated with your care, including any NHS treatment. We participate in internal audits and initiatives to help ensure that patients get the best possible outcomes from their treatment and care. The highest standards of confidentiality will be applied to your personal data in accordance with Data Protection Laws and confidentiality guidelines. Any publishing of this data will be in anonymised, statistical form. Anonymous or aggregated data may be used by us, or disclosed to others, for research or statistical purposes.

Cookies and non-personal information

Certain information you submit may also be collected to help us better understand our customers, improve our website, inform general marketing and provide a better experience of our services. We may use cookies to do this, and from time to time we may analyse Internet Protocol (IP) addresses or other anonymous data sources.

For full details of the cookies we use and how to manage them, please see our Cookie Policy at /cookies/.

Marketing

If you have consented to our processing of your personal data for marketing purposes, in accordance with this Privacy Policy, we may send you information (via mail, email, phone or SMS) about our products and services which we consider may be of interest to you.

You have the right to withdraw your consent at any time. If you no longer wish to receive web-based marketing information you can unsubscribe by emailing [email protected]. For non-web-based marketing information, please write to us at 1 Tynemouth Road, North Shields, NE30 4AY. We would ask you to give us a reasonable amount of notice to update our systems; while precise timings vary by department, we generally ask for at least 30 days' notice.

Your rights under Data Protection Laws

The law gives you certain rights in respect of the personal data we hold about you, as well as information about what we do with it, who we share it with and how long we hold it. We may make a reasonable charge for additional copies of that data beyond the first copy, based on our administrative costs. The website of the Information Commissioner's Office (ico.org.uk) has a wealth of useful information about your rights. In addition to your right to stop marketing, below is a short overview of the most commonly used rights.

Data Subject Access Request: with some exceptions designed to protect the rights of others, you have the right to a copy of the personal data that we hold about you.
The right of erasure (right to be forgotten): the right to have your personal information erased where we have no reason to continue processing it.
Data portability: the right to move, copy or transfer the personal information you have provided to us.
Rights in relation to automated decision making: which has a legal effect or otherwise significantly affects you.
Right to rectification: you have the right to have the personal data we hold about you corrected if it is factually inaccurate. This right does not extend to matters of opinion, such as psychological assessment. If any of your personal data has changed, especially contact information such as email address, postal address or phone number, please get in touch on 0191 258 0008 so we can keep your personal data up to date.

If you want to exercise your rights, the best way to do so is to contact us by email at [email protected], or to write to the Data Protection Officer at the address below. To protect your privacy, we may ask you to prove your identity before we take any steps in response to such a request.

Data Protection Officer, Select Psychology, 1 Tynemouth Road, North Shields, NE30 4AY.

If you are not satisfied with how we handle your request, you can contact the Information Commissioner's Office on 0303 123 1113 or visit ico.org.uk.

Changes to our Privacy Policy

We keep our Privacy Policy under regular review and it may be amended from time to time without notice. We encourage you to review this Privacy Policy regularly.

Contact

If you have any questions about our Privacy Policy, please email us at [email protected] or write to the Data Protection Officer at Select Psychology, 1 Tynemouth Road, North Shields, NE30 4AY.