Sunflower CBT Services is committed to protecting your privacy and meeting the requirements of GDPR data protection legislation.
This privacy notice explains:
• what personal data we collect about you;
• why we collect that personal data;
• who we share your personal data with;
• why we might contact you and how you can change that;
• how long we retain your personal data;
• how we keep your personal data secure; and
• what rights you have in relation to your personal data.
When we talk about “personal data” in this notice, we mean any information which could be used to identify you, either directly or indirectly when combined with any other information we may hold about you.
In this privacy notice, when we refer to “we”, “us” or “our”, we mean Sunflower CBT Services, 1a Canberra House, 17 London Rd , St.Albans, AL11LE. We are the data controller under the Information Commissioner’s Office registration number ZA294251.
If you need to contact us about this privacy notice or further details on how we use your personal information please contact the Group Data Protection Officer by post at our address above or by emailing Admin@sunflowercbt.co.uk/ lisa@sunflowercbt.co.uk.
Personal data collected by Sunflower CBT Services
The psychotherapists / registered nurses and healthcare professionals caring for you keep records about your health and any treatment and care you receive from us. These records help to ensure that you receive the best possible care.
They may be written down in paper records or held on computer. These records may include:
• Basic details about you such as name, address, date of birth, next of kin, etc.
• Contact we have had with you such as appointments or clinic visits
• Notes and reports about your health, treatment and care
• Relevant information from people who care for you and know you well such as health professionals and relatives.
Using a secure web service
Website Users:
We collect your data automatically via cookies when you visit our website, in line with cookie settings in your browser. When you visit our website there is certain information that we may automatically collect, whether or not you decide to use our services. This includes your IP address, the date and the times and frequency with which you access the website and the way you browse its content. We will also collect data from you when you contact us via the website. We never share this or sell information on to 3rd parties.
It is essential that your details which we hold are accurate and up to date. Always check that your personal details are correct when you visit us and please inform us of any changes as soon as possible.
Reasons for collecting that personal data
Your records are used to direct, manage and deliver the care you receive to ensure that:
• The Psychotherapists, and other healthcare professionals involved in your care have accurate and up to date information to assess your health and decide on the most appropriate care for you
• Healthcare professionals have the information they need to be able to assess and improve the quality and type of care you receive
• Your concerns can be properly investigated if a complaint or any concerns are raised
• Appropriate information is available if you see another doctor, or are referred to a specialist or another healthcare system to ensure you receive continuity of care.
• Review the care we provide to ensure it is of the highest standard and quality
• Ensure our services can meet patient needs in the future
• Investigate patient queries, complaints and legal claims
• Ensure the clinic receives payment for the care you receive
• Prepare statistics on our performance
• Audit our accounts and services
• Helping to train and educate healthcare professionals
We have a number of lawful bases for using this information under data protection legislation.
• In some cases it will be necessary for us to use information in order to fulfil our contract with you to provide you with healthcare services, such as using your health data for the purposes of diagnosis and assessment by a healthcare professional.
• We are required to use information in order to treat NHS patients that have been referred to Sunflower CBT Services.
• We may also need to use your information for the purposes of establishing, exercising or defending our legal rights, for example in the event of a complaint.
• Where we do not have a contractual or legal obligation to handle your data in a particular way or your explicit consent to use your information for a specific purpose, we have a legitimate interest to conduct general business processes and improve our services. When relying on our legitimate interests we conduct an assessment to ensure that this use of your data is fair, proportionate and in no way detrimental.
Who we share your personal data with
Everyone working within healthcare has a legal duty to keep information about you confidential. Similarly, anyone who receives information from us has a legal duty to keep it confidential.
We will share information with the following main partner organisations:
• NHS Trusts and hospitals that are involved in your care
• Private insurers that are involved in your care
• Clinical Commissioning Groups, NHS Commissioning Support Units, NHS England Local Area Teams and other NHS bodies
• Your General Practitioner (GP)
• Ambulance Services
• PHIN (Private Healthcare Information Network) who are the government’s recognised body for processing private patient’s data
You may be receiving care from other people as well as us, for example Social Care Services or District Nursing Services. We may need to share some information about you with them so we can all work together for your benefit if they have a genuine need for it or we have your permission. Therefore, we may also share your information, subject to strict agreement about how it will be used, with:
• Social Care Services
• Education Services
• Local Authorities
• Voluntary and private sector providers working with us
We will not disclose your information to any other third parties without your permission unless there are exceptional circumstances, such as if the health and safety of others is at risk or if the law requires us to pass on information.
You have the right to restrict how and with whom we share the personal information in your records that identifies you. This must be noted explicitly within your records in order that healthcare professionals and staff treating and involved with you are aware of your decision. By choosing this option, you should be mindful that it may make the provision of treatment or care more difficult or unavailable. You can also change your mind at any time about a disclosure decision.
Receiving communications from Sunflower CBT and updating your preferences
When attending our facilities for an outpatient appointment or you may be asked to confirm that we have an accurate email address, contact number and/or mobile telephone number for you. This can be used to provide appointment details via email, with your consent.
You can update your communications preferences at any time by informing your Psychotherapist involved in your treatment or contacting the Group Data Protection Officer. (Admin@sunflowercnt.co.uk/ lisa@sunflowercbt.co.uk).
Retention of personal data
We retain personal data for no longer than required. This is based on statutory requirements and legal obligations.
Security of personal data
We take our duty to protect your personal information and confidentiality very seriously and we are committed to taking all reasonable measures to ensure the confidentiality and security of personal data for which we are responsible, whether computerised or on paper.
KEEPING INFORMATION SECURE
We invest significant resources to protect your personal information, from loss, misuse, unauthorised access, modification or disclosure. We use a GDPR compliant system
Called “Cliniko” however , no internet-based site can be 100% secure and so we cannot be held responsible for unauthorised or unintended access that is beyond our control. We have a data breach policy that i forms ICO if any known data breach.
Where we have a need to transfer data outside of the European Economic Area (EEA) we do so with appropriate safeguards in place.
Personal data and your rights
Data protection legislation gives you the right to:
• Correct any data we hold about you that is not correct (Rectification)
• Request that we delete your personal data (Erasure)- but for health treatment records we cannot delete until 7years after the last entry/ discharge for legal purposes. For children this is when the child reaches the age of 25. Based on guidance for health professionals treatment records.
• Block or suppress the further processing of your personal data in certain circumstances (Restriction)
• Request access to personal data that we hold about you (Subject Access)
• In some circumstances, receive the personal data which you have provided to us, in a structured, commonly used and machine-readable format and have this transmitted to another data controller (Data Portability)
• Withdraw consent where this is the legal basis for us processing your information
Please contact the Group Data Protection Officer using the details above if you wish to exercise your rights in relation to personal data. Our policy is to verify the authenticity of all requests made, and requests may be refused if we are unable to verify the identity of the requester.
If you have concerns about the way we have handled your personal data please contact the Group Data Protection Officer in the first place- lisa@sunflowercbt.co.uk. If you remain unsatisfied you can contact the Information Commissioner’s Office (ICO) on 0303 123 1113, by emailing casework@ico.org.uk or by post at Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.