Privacy Policy

This Privacy Policy was last updated on: 12th February 2024. This Privacy Policy applies to YW P&E Limited (referred from here on by our Trading Name ‘Your Way Psychology and Education’ also known as ‘Your Way Psychology & Education’). Your privacy is very important to us, and we want to assure you that the personal information you share with us will be kept private and will be looked after securely. We are committed to protecting the privacy of all personal information obtained from you during your visits to this website and any contact that you have with the clinic.

Our Privacy Policy explains what personal information we may collect from you and the purposes for which it will be used. Please read this policy carefully. By accessing or using this website you are agreeing that your data will be processed in accordance with our privacy policy.

In order to respond and process any enquiries from you, we require you to agree to the conditions set out in this privacy policy. This statement will be regularly reviewed and updated accordingly.

If you have any questions about this privacy policy, please email: admin@yourwaypsychology.co.uk YW P&E Limited is registered with the Information Commissioner’s Office (ICO), registration number ZB496919

What are your rights?

We are committed to protecting your rights to privacy. They include:

· Right to be informed about what we do with your personal data

· Right to have a copy of all the personal information we process about you

· Right to rectification of any inaccurate data we process, and to add to the information we hold about you if it is incomplete

· Right to be forgotten and your personal data destroyed

· Right to restrict the processing of your personal data

· Right to object to the processing we carry out based on our legitimate interest

How we collect data?

We will use various methods to collect data about you and your child, to help us provide the services you have enquired about or requested from us, including:

· Website: We will collect personal data and technical data from you when you use our website, including use of the contact form.

· Telephone: We may telephone you and other people connected to your child’s care to gather information as part of the services you are requesting from us.

· Text and Email: We may use email to communicate with you and other third-parties linked to your child’s care, such as their school. We may also occasionally use text messages to communicate with you, for example, to remind you of upcoming appointments.

· Face-to-face: As part of your assessment, we will meet face-to-face with you, and if relevant, other parties involved in your child’s care. We will take written and/or electronic notes to inform our work. Part of the assessment may also be video recorded to help aid our work, for example, to aid panel meeting discussions.

· Written communications: We will ask you to complete forms as part of our assessment, and other services you request, for example, referral forms, and screening questionnaires. We may also use other forms of written communication, such as letters and email to communicate with you and others connected to your child’s care.

· Third-party sources: We may collect personal data about you and your child from third-parties connected with your child’s care, for example, their school, or other health and social care providers. We may also use search analytics providers to provide us with personal data about individuals accessing our website.

What data do we gather?

In order for us to be able to work with you safely and effectively provide the services we offer, and also to ensure efficient appointment and payment processes, we will gather personal data about you and/or your child. This includes:

· Identity data: Personal detail including you and your child’s name, address, date of birth and gender

· Contact data: Including your email address, contact telephone number(s), postal address, and billing address.

· Other data: Such as, General Practitioner (GP) details, health and social care support agencies, details of educational history, details of private health insurance providers (where relevant)

· Financial data: including bank details and payment/transaction information

· Technical data: As required for accessing and providing information through our website

How do we use data collected from you?

Initial contact

When you contact Your Way Psychology and Education with an enquiry about our services, we will collect information to help us satisfy your enquiry. This will include your name, telephone number, email address and the reason for the referral. If you decide not to proceed, we will ensure all your personal data is deleted within 2 months. If you would like us to delete this information sooner, just let us know.

We only collect data that is needed and relevant to offering you the service that you have enquired about or have asked for. Sometimes we will use your data to help guide you to the most relevant service for your needs. We use your data to:

· Contact you to set up assessment, consultation, or other services.

· Conduct assessments

· Provide follow-up services and recommendations. This may include communicating with you, and with your consent, third parties like schools.

· Invoice you for services provided

We must have a valid lawful basis in order to process personal data. There are six available lawful bases for processing. No single basis is ’better’ or more important than the others – which basis is most appropriate to use will depend on purpose and relationship with the individual. Most lawful bases require that processing is ‘necessary’ for a specific purpose. We will use your data for legitimate interest. The lawful basis for collecting, storing, processing, and sharing your personal data relates to ‘legitimate interest’ and the ‘provision of health treatment’. You can find out more about the lawful basis for personal data collection on the ICO website (www.ico.org.uk).

By contacting us you are agreeing to the above use of data.

How do we store the data we collect from you and when is it deleted?

The personal information we hold about you is stored and processed in line with the Data Protection Act (DPA, 1998) and the General Data Protection Regulation (GDPR, Regulation (EU) 2016/679) adopted on 27th April 2016 and enforceable from 25th May 2018.

We will keep your data for the duration of your work with us, and we will continue to store your data securely for seven years from the date of our last contact with you as a client. We advocate our right to retain your data for this seven-year period so that we can effectively respond to any questions or complaints that may be later raised by you and/your representatives. You have the right to ask for your information to deleted after the seven-year period, but not before then. After the seven-year period, we will delete the information we held about you securely.

We store and process the information we collect about you securely. This includes:

· Client records, including personal data and sensitive personal data is held on a secure, GDPR-compliant electronic system

· Any paper records are kept secure in a locked filing cabinet

· Any clinically relevant email correspondence from/with you will be uploaded to the secure electronic system

· We will share sensitive and confidential information about you and your child (such as report) via secure message/email systems and/or password-protected documents.

· Access to you and your child’s personal information is restricted on a ‘need-to-know’ basis only, i.e. for those concerned directly with your care.

In the unlikely event of a data protection breach, we will notify the Information Commissioner’s Office (ICO) so that the appropriate procedures can be followed.

Keeping our data accurate

It is important that the information, including personal data (for example, name, contact details) and sensitive personal data we hold about you is accurate. During the time you are employing our services, please notify us at the earliest opportunity about any personal data changes, so that we can update the information to ensure accuracy and that our records are up to date. This is necessary for both data protection and safety/safeguarding purposes.

How can I access my information?

All individuals whom Your Way Psychology and Education collect, store and process personal information about as a client/user of our services are entitled to:

· Ask what information we hold about them and why

· Ask how to gain access to this information

· Be informed about how it is kept up to date

· Be information about how we are meeting data protection regulations

If you would like to request a copy of the data we hold about you, you can make a Subject Access Request (SAR) in writing to admin@yourwaypsychology.co.uk. We will aim to provide relevant data within 30 days of receipt of the SAR. We will always verify the identity of anyone making a SAR before disclosing any data.

Your Way Psychology and Education may use the services of other professionals who, in the service of their work, may access your data for the same legitimate interests. For example, we may work with and/or employ other professionals (including, but not limited to) associate psychologist, speech and language therapists, teachers, nurses, allied health professionals, and administrative staff, who also adhere to the General Data Protection Regulations.

Sharing and disclosing information

You and/or your child have a right to express what information you consent to being shared. We may share your personal data, including sensitive personal data with other individuals, agencies and third-parties for the purposes of providing safe and effect services to your child. We will discuss and explain the rational and purpose of sharing information with others and obtain your consent for this, where necessary.

In certain circumstances, Your Way Psychology and Education may be required to disclose personal data, including sensitive data without the data subject’s consent. These circumstances include:

· Risk of harm: If we perceived that a child, or someone else, was at risk of harm. If we needed to breach confidentiality for any reason (and this is very rare) we would discuss this with you first, unless there is a justified reason not to (for example, we felt a child to be in immediate danger)

· To comply with applicable laws, respond to governmental enquiries (or enquiries from a legal, governmental or local authority agency), comply with a valid legal process or procedure, or protect our rights or property.

Third-party links

The Your Way Psychology and Education website may contact links to third-party websites and information. Clicking on these links may enable other third-party organisations to gather personal data about you. We do not control these third-party websites and are not responsible for their privacy and how they use your personal data once you have chosen to visit their website.

Online Appointments

Some of our work may be conducted via online video links using programmes such as Microsoft Teams. We have taken reasonable steps to ensure the confidentiality of the sessions using this online platform, including the use of client-specific meeting links and a waiting room so all guests of the session are admitted by the host within our organization.

These sessions are not audio or video recorded (unless discussed and agreed with the client and clinician) and we would kindly ask our clients not to audio or video record the sessions without prior discussion, agreement and consent from the clinician they are working with.

Clients accessing our services must be able to access the sessions on an appropriate device and be able to set-up and protect the environment in which they access the online session(s) to maintain their confidentiality. For example, having access to a room or environment which is private, confidential and with no interruptions or distractions.

Management of information in the event of incapacitation or death of a clinician

In the event of incapacitation or death of the clinician working with you, such as a psychologist, we will inform you of this as soon as possible and arrange alternative support. Another allocated professional may be asked to access and manage information related to our work with you, with a view to informing you of such an event, supporting you in the transition to another clinician or service, and ensuring continued safe storage and management of records. This psychologist/professional will also adhere to the GDPR principles and will only be shared if and when there is a legitimate need for them to access the information.

Acting on concerns

If any of our workforce have concerns about customers, colleagues, or volunteers, we expect them in line with our safeguarding policy and their own disciplines regulatory body, report these concerns as appropriate. For more details please see the safeguarding policy.

Accessibility

If you have any difficulties reading and/or understanding this privacy policy, please contact us and we will try to help you understand the information.

Complaints

If you are unhappy with any aspects of the way we collect, store, process and share the information about you and your child, please contact our data protection lead via admin@yourwaypsychology.co.uk , so that we can answer any questions you have and try to resolve the issue. You also have the right to complain to the Information Commissioner’s Office (ICO) which is the UK’s supervisory authority for data protection issues. Please see www.ico.org.uk for further information, if required.

Changes to this privacy policy

We may change this privacy policy from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be immediately posted on our site, and you will be deemed to have accepted the terms of the privacy policy by accessing our site following the alterations, or if we have made you aware of the changes via email or text.

If you have any questions

This Privacy Policy applies to YW P&E Limited (referred to throughout this policy by our Trading Name ‘Your Way Psychology and Education’).

www.yourwaypsychology.co.uk

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