Amy Harley Occupational Therapist (data controller – ICO)
Keyworth Notts NG12 5EF
The GDPR states that I must have a lawful basis for processing your personal data. There are different lawful bases depending on the stage at which I am processing your data. The lawful bases for processing your data fall under contractual and consent.
If you have had therapy with me and it has now ended, I will use legitimate interest as my lawful basis for holding and using your personal information. If you are currently having therapy or if you are in contact with me to consider therapy, I will process your personal data where it is necessary for the performance of our agreement. The GDPR also makes sure that I look after any sensitive personal information that you may disclose to me appropriately. This type of information is called ‘special category personal information’. The lawful basis for me processing any special categories of personal information is that it is for provision of health treatment (in this case occupational therapy) and necessary for an agreement with a health professional – in this case between me and you. In this case, special category data will include health information, results of treatment and treatment plans.
How I use your information
Initial contact – When you contact me with an enquiry about my occupational therapy services, I will collect information (standard personal data) to help me satisfy your enquiry. This will include name, address, email address, phone number, date of birth, GP details. If you decide not to proceed, I will ensure that all your personal data is deleted within 4 weeks. If you would like me to delete this information sooner, just let me know.
While you are accessing occupational therapy – I will keep a written record of each session. This includes health information, treatment progress and treatment plans. Records are kept as a password protected document in encrypted I.T. cloud storage or as a paper record in a locked filing cabinet. This information is held in order to deliver occupational therapy services to you.
Rest assured that everything you discuss with me is confidential. That confidentiality will only be broken if I have your explicit permission, if the law allows, if it is to protect the public from harm or if it is in your best interests. I will always try to speak to you about this first, unless there are safeguarding issues that prevent this.
For security reasons I do not retain text messages for more than 2 weeks. If there is relevant information in a text message, I will transfer it to your written record. My email account is password protected with 2 factor authentication and only relevant emails are stored for the duration of your treatment. After this time, email correspondence will be transferred to your written records.
After occupational therapy has ended your written records will be kept securely for 7 years as per law. After this time the records will be securely destroyed. If I need to share your personal data for any reason you will be asked for consent.
I try to be as open as I can in terms of giving people access to their personal information. You have a right to ask me to delete your personal data, to limit how I use your personal data or to stop processing your personal data. You also have a right to ask for a copy of any information that I hold about you and to object to the use of your personal data in some circumstances. You can read more about your rights at www.ico.org.uk/your-data-matters
If I do hold information about you I will:
Give you a description of it and where it came from; tell you why I am holding it, tell you how long I will store it for and how I made the decision; tell you who it could be disclosed to; let you have a copy of the information in an intelligible form.
You may ask me to correct any mistakes there may be in your personal information I hold about you.
To make a request for any personal information I may hold about you, please contact Amy Harley at email@example.com. You are not required to pay any charge and I have one month to respond to you. If you have any complaint about how I handle your personal information you can contact me or the ICO which is the statutory body that oversees data protection law in the UK. https://www.ico.org.uk 0303 123 1113. Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
I take the security of the data I hold about you very seriously and as such take every effort to make sure it is kept secure. I use encrypted devices (PC, laptop and phone) and Microsoft cloud storage, an encrypted email provider (Gmail), a secure video conferencing platform (Zoom) and a locked filing cabinet. I am confident that your data is being stored in a safe and legitimate way.
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