Your privacy
THIS IS THE PRIVACY NOTICE OF SYMBIOSIS WELLBEING. IN THIS DOCUMENT, “I “AND “MY” REFERS TO SYMBIOSIS WELLBEING OPERATING IN THE CAPACITY OF SOLE OWNER AND THERAPIST JEAN-PAUL DUNIN TRADING UNDER THE NAME OF SYMBIOSIS WELLBEING UNDERSTANDS THAT YOUR PRIVACY IS IMPORTANT TO YOU AND THAT YOU CARE ABOUT HOW YOUR PERSONAL DATA IS USED.
I RESPECT AND VALUE THE PRIVACY OF ALL MY CLIENTS AND POTENTIAL CLIENTS ENQUIRING ABOUT MY SERVICES AND WILL ONLY COLLECT AND USE PERSONAL DATA IN WAYS THAT ARE DESCRIBED HERE, AND IN A WAY THAT IS CONSISTENT WITH OUR OBLIGATIONS AND YOUR RIGHTS UNDER THE LAW.
THIS PRIVACY INFORMATION EXPLAINS HOW I USE YOUR PERSONAL DATA: HOW IT IS COLLECTED, HELD, AND HOW IT IS PROCESSED. IT ALSO EXPLAINS YOUR RIGHTS UNDER THE LAW RELATING TO YOUR PERSONAL DATA.
(1) WHAT IS PERSONAL DATA?
PERSONAL DATA IS DEFINED BY THE GENERAL DATA PROTECTION REGULATION (EU REGULATION 2016/679) (THE “GDPR”) AS ‘ANY INFORMATION RELATING TO AN IDENTIFIABLE PERSON WHO CAN BE DIRECTLY OR INDIRECTLY IDENTIFIED IN PARTICULAR BY REFERENCE TO AN IDENTIFIER’.
PERSONAL DATA IS, IN SIMPLER TERMS, ANY INFORMATION ABOUT YOU THAT ENABLES YOU TO BE IDENTIFIED. PERSONAL DATA COVERS OBVIOUS INFORMATION SUCH AS YOUR NAME AND CONTACT DETAILS, BUT IT ALSO COVERS LESS OBVIOUS INFORMATION SUCH AS IDENTIFICATION NUMBERS, ELECTRONIC LOCATION DATA, AND OTHER ONLINE IDENTIFIERS. THE PERSONAL DATA THAT I USE IS SET OUT IN PART 3, BELOW.
(2) WHAT ARE MY RIGHTS?
UNDER THE GDPR, YOU HAVE THE FOLLOWING RIGHTS, WHICH I WILL ALWAYS WORK TO UPHOLD:
(A) THE RIGHT TO BE INFORMED ABOUT COLLECTION AND USE OF YOUR PERSONAL DATA. THIS PRIVACY NOTICE SHOULD TELL YOU EVERYTHING YOU NEED TO KNOW, BUT YOU CAN ALWAYS CONTACT US TO FIND OUT MORE OR TO ASK ANY QUESTIONS USING THE DETAILS IN PART 9.
THE RIGHT TO ACCESS THE PERSONAL DATA I HOLD ABOUT YOU. PART 8 WILL TELL YOU HOW TO DO THIS. (PLEASE NOTE THAT WHEN WORKING WITH YOU AS A CLIENT THAT THERE MAY VERY WELL BE A SOUND REASON OF A LEGITIMACY OF INTEREST NOT TO DISCLOSE INFORMATION THAT MIGHT AFFECT THE SUCCESS AND PERMANENCY OF YOUR TREATMENT. REVEALING CERTAIN DETAILS AND INFORMATION MAY RISK UNDOING ALL THE GOOD THAT HAS BEEN DONE, IN THIS CASE I WILL DISCUSS FULLY THOSE REASONS WITH YOU. HOWEVER ULTIMATELY, I DO HAVE TO OBSERVE THE LAW AND RESPECT YOUR RIGHTS)
(B) THE RIGHT TO HAVE YOUR PERSONAL DATA RECTIFIED IF ANY OF YOUR PERSONAL DATA HELD IS INACCURATE OR INCOMPLETE. PLEASE CONTACT USE THE CONTACT DETAILS IN PART 9 TO FIND OUT MORE.
(C) THE RIGHT TO BE FORGOTTEN, I.E. THE RIGHT TO ASK US TO DELETE OR OTHERWISE DISPOSE OF ANY OF YOUR PERSONAL DATA THAT WE HAVE.
(D) PLEASE NOTE THAT WHEN YOU ARE A CLIENT BEING TREATED, OUR GOVERNING BODY’S REGULATIONS REQUIRE US TO HOLD YOUR PERSONAL RECORDS AND DATA FOR A PERIOD OF UP TO SEVEN OR EIGHT YEARS. THESE RECORDS WILL BE STORED SECURELY, AND THE STORAGE PERIOD WOULD BE DETERMINED AS A LEGITIMACY OF INTEREST IN THE SCOPE OF HISTORICAL RECORDS BEING MADE AVAILABLE SHOULD A PERSON REQUIRE ADDITIONAL THERAPY. EIGHT YEARS IS DEEMED BY OUR GOVERNING BODY TO BE A SENSIBLE TIME FRAME TO STORE CLIENT RECORDS FOR. (THESE RECORDS WILL BE STORED SECURELY AND SECURELY DESTROYED UNDER THE TERMS OF THE DATA PROTECTION ACT AFTER THIS TIME PERIOD)
(E) THE RIGHT TO RESTRICT (I.E. PREVENT) THE PROCESSING OF YOUR PERSONAL DATA.
(F) THE RIGHT TO OBJECT TO USING YOUR PERSONAL DATA FOR A PARTICULAR PURPOSE OR PURPOSES.
(G) THE RIGHT TO DATA PORTABILITY. THIS MEANS THAT YOU CAN ASK FOR A COPY OF YOUR PERSONAL DATA HELD TO RE-USE WITH ANOTHER SERVICE OR BUSINESS IN MANY CASES.
(H) RIGHTS RELATING TO AUTOMATED DECISION-MAKING AND PROFILING. I DO NOT USE YOUR PERSONAL DATA IN THIS WAY
FOR MORE INFORMATION ABOUT OUR USE OF YOUR PERSONAL DATA OR EXERCISING YOUR RIGHTS AS OUTLINED ABOVE, PLEASE SEE CONTACT DETAILS PROVIDED IN PART 9.
FURTHER INFORMATION ABOUT YOUR RIGHTS CAN ALSO BE OBTAINED FROM THE INFORMATION COMMISSIONER’S OFFICE OR YOUR LOCAL CITIZENS ADVICE BUREAU.
IF YOU HAVE ANY CAUSE FOR COMPLAINT ABOUT OUR USE OF YOUR PERSONAL DATA, YOU HAVE THE RIGHT TO LODGE A COMPLAINT WITH THE INFORMATION COMMISSIONER’S OFFICE.
3) WHAT DATA DO YOU HOLD?
I MAY COLLECT SOME OR ALL OF THE FOLLOWING PERSONAL DATA;.
• NAME
• DATE OF BIRTH
• GENDER
• ADDRESS
• EMAIL ADDRESS
• TELEPHONE NUMBER
• YOUR PRESENTING ISSUE OR SPECIFIC GOALS ETC.
• INFORMATION REGARDING LIFESTYLE/WORK/RELATIONSHIPS
•YOUR PREFERENCES AND INTERESTS• PREVIOUS THERAPY TREATMENTS • GP DETAILS
• MEDICAL AND HEALTH CONDITIONS WHERE APPLICABLE
• MEDICATION
• JOB TITLE
• PROFESSION
• PAYMENT INFORMATION
• WE WILL ALSO NEED TO ASK AND RECORD IF YOU ARE THE SUBJECT OF ANY CRIMINAL INVESTIGATION OR PENDING COURT CASE OR IF YOU ARE ATTENDING JURY SERVICE AS THIS WILL EXCLUDE US FROM HELPING YOU AT THIS TIME IF SO. THIS MUST BE RECORDED ON YOUR DATA.
• OTHER SOURCES OF PERSONAL DATA: YOUR PERSONAL DATA IS OBTAINED FROM THE FOLLOWING THIRD PARTY• YOUR GP IF THERE ARE ANY CONTRA INDICATIONS TO TREATMENT• CPN IF APPLICABLE.
(4) HOW DO YOU USE MY PERSONAL DATA?
UNDER THE GDPR, I MUST ALWAYS HAVE A LAWFUL BASIS FOR USING PERSONAL DATA.
THIS MAY BE BECAUSE THE DATA IS NECESSARY FOR MY PERFORMANCE OF A CONTRACT WITH YOU, BECAUSE YOU HAVE CONSENTED TO MY USE OF YOUR PERSONAL DATA, OR BECAUSE IT IS IN OUR LEGITIMATE INTERESTS TO USE IT. I.E CLIENT RECORD KEEPING. YOUR PERSONAL DETAILS ARE REQUIRED IN ORDER FOR ME TO ENTER INTO A CONTRACT WITH YOU TO PERSONALISE AND TAILOR THERAPY SERVICES FOR YOU AND CAN BE USED FOR THE FOLLOWING PURPOSES:
• MANAGING YOUR CLIENT RECORDS• SUPPLYING MY PRODUCTS /SERVICES TO YOU.
,
• COMMUNICATING WITH YOU. THIS MAY INCLUDE RESPONDING TO LETTERS, EMAILS, TELEPHONE CALLS/TEXTS/MESSAGES.
• SUPPLYING YOU WITH INFORMATION BY EMAIL OR POST THAT YOU HAVE OPTED-IN TO.
(YOU MAY UNSUBSCRIBE OR OPT-OUT AT ANY TIME BY NOTIFYING US IN WRITING OR EMAIL.)
• IN ACCORDANCE WITH ETHICAL OBLIGATIONS AND DUTY OF CARE TO OUR CLIENT’S WELFARE AND OTHERS ASSOCIATED, AS STATED UPON OUR TERMS AND CONDITIONS OF TREATMENT
WITH YOUR EXPRESS PERMISSION, I MAY ALSO USE YOUR PERSONAL DATA FOR MARKETING PURPOSES, I.E. TESTIMONIALS ON MY WEBSITE AND SOCIAL MEDIA WHICH WILL BE ANONYMISED UNLESS CONSENT HAS BE GIVEN TO WAIVE YOUR ANONYMITY. WITH YOUR EXPRESS PERMISSION, I MAY ALSO USE YOUR PERSONAL DATA FOR MARKETING PURPOSES WHICH MAY INCLUDE CONTACTING YOU BY EMAIL, TELEPHONE OR TEXT MESSAGE AND/OR POST WITH INFORMATION, NEWS, AND OFFERS ON MY SERVICES.
YOU WILL NOT BE SENT ANY UNLAWFUL MARKETING OR SPAM. I WILL ALWAYS WORK TO FULLY PROTECT YOUR RIGHTS AND COMPLY WITH OUR OBLIGATIONS UNDER THE GDPR AND THE PRIVACY AND ELECTRONIC COMMUNICATIONS (EC DIRECTIVE) REGULATIONS 2003, AND YOU WILL ALWAYS HAVE THE OPPORTUNITY TO OPT-OUT.]
I DO NOT USE ANY AUTOMATED SYSTEMS FOR CARRYING OUT, CERTAIN KINDS OF DECISION-MAKING OR PROFILING.
(5) HOW LONG WILL YOU KEEP MY PERSONAL DATA?
I WILL NOT KEEP YOUR PERSONAL DATA FOR ANY LONGER THAN IS NECESSARY IN LIGHT OF THE REASON FOR WHICH IT WAS FIRST COLLECTED. YOUR PERSONAL DATA WILL THEREFORE BE KEPT FOR THE FOLLOWING PERIOD.
• ALL CLIENT RECORDS AND CASE HISTORIES WHETHER MANUAL NOTES OR ELECTRONIC DATA WILL BE STORED FOR A PERIOD OF SEVEN – EIGHT YEARS IN COMPLIANCE WITH THE CURRENT GUIDELINES AND REQUIREMENTS OF OUR PROFESSIONAL BODIES.
IN OUR CASE, THE BWRT INSTITUTE AND THE EFTMR ACADEMY.
• THESE MEASURES ARE REGARDED AS A LEGITIMACY OF INTEREST AND ARE PUT IN PLACE AS BEST CLIENT PRACTICE DESIGNED TO PROTECT OUR CLIENT’S LONG TERM INTERESTS.
• AFTER THIS PERIOD UNLESS SPECIFICALLY REQUESTED BY YOU THE CLIENT THEY WILL BE SECURELY DESTROYED IN ACCORDANCE WITH THE DIRECTIVES OF THE DATA PROTECTION ACT.
(6) HOW AND WHERE DO YOU STORE OR TRANSFER MY PERSONAL DATA?
I.I WILL ONLY STORE YOUR PERSONAL DATA IN THE UK. THIS MEANS THAT IT WILL BE FULLY PROTECTED UNDER THE GDPR. UNLESS YOUR DETAILS ARE REQUIRED TO REFER YOU TO OTHER WOLD WIDE THERAPIST SHOULD THIS BE DEEMED NECESSARY AND WITH YOUR CONSENT IN WHICH CASE II AND III MAY APPLY.
II. I WILL ONLY STORE YOUR PERSONAL DATA WITHIN THE EUROPEAN ECONOMIC AREA (THE “EEA”). THE EEA CONSISTS OF ALL EU MEMBER STATES, PLUS NORWAY, ICELAND, AND LIECHTENSTEIN. THIS MEANS THAT YOUR PERSONAL DATA WILL BE FULLY PROTECTED UNDER THE GDPR OR TO EQUIVALENT STANDARDS BY LAW.]
III. I MAY TRANSFER SOME OR ALL OF YOUR PERSONAL DATA IN COUNTRIES THAT ARE NOT PART OF THE EUROPEAN ECONOMIC AREA (THE “EEA” CONSISTS OF ALL EU MEMBER STATES, PLUS NORWAY, ICELAND, AND LIECHTENSTEIN). THESE ARE KNOWN AS “THIRD COUNTRIES” AND MAY NOT HAVE DATA PROTECTION LAWS THAT ARE AS STRONG AS THOSE IN THE UK AND/OR THE EEA. THIS MEANS THAT I WILL TAKE ADDITIONAL STEPS IN ORDER TO ENSURE THAT YOUR PERSONAL DATA IS TREATED JUST AS SAFELY AND SECURELY AS IT WOULD BE WITHIN THE UK AND UNDER GDPR. THE SECURITY OF YOUR PERSONAL DATA IS ESSENTIAL TO US AND TO PROTECT YOUR DATA, WE TAKE A NUMBER OF IMPORTANT MEASURES, INCLUDING THE FOLLOWING:
• WHERE STORED ON A P.C. IT IS ENCRYPTED, AND PASSWORD PROTECTED, AND THE PC IS KEPT IN A SECURE LOCKED LOCATION WHEN NOT IN USE BY US.
• ALL WRITTEN CASE NOTES AND PERSONAL DATA IS STORED UNDER LOCK AND KEY IN A SECURE LOCATION
(7) DO YOU SHARE MY PERSONAL DATA?
I AM SUBJECT TO THE LAW LIKE EVERYONE ELSE. SOMETIMES, I MUST PROCESS YOUR INFORMATION IN ORDER TO COMPLY WITH A STATUTORY OBLIGATION. THEREFORE, I WILL NOT SHARE ANY OF YOUR PERSONAL DATA WITH ANY THIRD PARTIES FOR ANY PURPOSES, SUBJECT TO TWO IMPORTANT EXCEPTIONS.
• IN SOME LIMITED CIRCUMSTANCES, I MAY BE LEGALLY REQUIRED TO SHARE CERTAIN PERSONAL DATA, WHICH MIGHT INCLUDE YOURS. FOR EXAMPLE, THIS MAY BE IF WE ARE INVOLVED IN LEGAL PROCEEDINGS, OR I MAY BE REQUIRED TO COMPLY WITH CERTAIN LEGAL OBLIGATIONS, OR THE INSTRUCTIONS OF A GOVERNMENT AUTHORITY, OR GIVE INFORMATION TO LEGAL AUTHORITIES IF THEY SO REQUEST IF THEY HAVE THE PROPER AUTHORISATION SUCH AS A COURT ORDER.
• IN THE COURSE OF THERAPY TREATMENT, SHOULD THERE BE LEGITIMATE CONCERNS OF SELF-HARM OR RISK TO A MINOR OR OTHER PERSON THEN A DUTY OF LEGAL OBLIGATION UNDER THE CODE OF ETHICS THAT I ADHERE TO REQUIRES NOTIFICATION AND SHARING. THERE ARE NO EXCEPTIONS.
(8) HOW CAN I ACCESS MY PERSONAL DATA?
IF YOU WANT TO KNOW WHAT PERSONAL DATA WE HAVE ABOUT YOU, YOU CAN ASK US FOR DETAILS OF THAT PERSONAL DATA AND FOR A COPY OF IT (WHERE ANY SUCH PERSONAL DATA IS HELD). THIS IS KNOWN AS A “SUBJECT ACCESS REQUEST”.
ALL SUBJECT ACCESS REQUESTS SHOULD BE MADE IN WRITING AND SENT TO THE EMAIL SHOWN IN PART 9. THERE IS NOT NORMALLY ANY CHARGE FOR A SUBJECT ACCESS REQUEST.
HOWEVER, IF YOUR REQUEST IS ‘MANIFESTLY UNFOUNDED OR EXCESSIVE’ (FOR EXAMPLE, IF YOU MAKE REPETITIVE REQUESTS) A FEE MAY BE CHARGED TO COVER OUR ADMINISTRATIVE COSTS IN RESPONDING. COSTS AVAILABLE UPON APPLICATION:
I WILL RESPOND TO YOUR SUBJECT ACCESS REQUEST WITHIN NOT MORE THAN ONE MONTH OF RECEIVING IT. NORMALLY, I AIM TO PROVIDE A COMPLETE RESPONSE, INCLUDING A COPY OF YOUR PERSONAL DATA WITHIN THAT TIME. IN SOME CASES, HOWEVER, PARTICULARLY IF YOUR REQUEST IS MORE COMPLEX, MORE TIME MAY BE REQUIRED UP TO A MAXIMUM OF THREE MONTHS FROM THE DATE WE RECEIVE YOUR REQUEST. YOU WILL BE KEPT FULLY INFORMED OF OUR PROGRESS.
(9) HOW DO I CONTACT YOU?
SHOULD YOU WISH TO CONTACT ME ABOUT ANYTHING TO DO WITH YOUR PERSONAL DATA AND DATA PROTECTION, INCLUDING TO MAKE A SUBJECT ACCESS REQUEST, PLEASE USE THE FOLLOWING DETAILS:
FOR THE ATTENTION OF: JEAN-PAUL DUNIN SYMBIOSIS WELLBEING USING THE EMAIL ADDRESS HELLO@SYMBIOSISWELLBEING.ORG.
(10) CHANGES TO THIS PRIVACY NOTICE
I MAY CHANGE THIS PRIVACY NOTICE FROM TIME TO TIME. THIS MAY BE NECESSARY, FOR EXAMPLE, IF THE LAW CHANGES, OR IF I CHANGE OUR BUSINESS IN A WAY THAT AFFECTS PERSONAL DATA PROTECTION.
ANY CHANGES WILL BE MADE AVAILABLE CONTACTING YOU DIRECTLY WITH NOTIFICATION AS TO THE NATURE OF THE CHANGES.
YOU THE CLIENT HAVE BEEN SHOWN A COPY OF THE SAID PRIVACY POLICY NOTICE AND BY SIGNING YOUR CLIENT AGREEMENT ACCEPT THE TERMS OF THE PRIVACY POLICY NOTICE.
UPDATED JANUARY 2021
GDPR PRIVACY POLICY NOTICE