Privacy Policy

Last Updated 10 October 2021

This Privacy Policy applies to www.focusedtherapylondon.com ('Website') and all of the Services provided by Jacky Sayers trading as Focused Therapy London™ ('I', 'me', 'my', 'myself', 'Focused Therapy London') whether these Services are requested through the Website, in person, any electronic communications or indirectly via the Clinics.

By your use of this Website, as well as where you choose to provide any information to Focused Therapy London in relation to the Services provided, you are agreeing to this Privacy Policy.

The purpose of this Privacy Policy

Focused Therapy London takes you privacy very seriously, and wants you to be aware that any information it receives in relation to you, whether via use of the Website, as a Client or as a Mailing List Subscriber, is only used to provide you with any of the Services you have shown an interest in or which have been requested by you or on your behalf, to publishing any Review that is voluntarily provided by you, and/or where you consent to the use of specific Website Cookies.

Everyone has their own concerns around privacy of their information, but for your immediate peace of mind, Focused Therapy does not do any of the following with regard to any of the information it holds for you:

  • use automated decision-making processes (without human involvement); or
  • disclose, share, sell, rent or distribute any of your information except as detailed within this Privacy Policy; or
  • provide your information to any other individual or organisation without first receiving written consent to do so, other than as already notified within this Privacy Policy

When you contact or speak to Focused Therapy London in relation to the Services provided, submit a review, and/or provide information during or in relation to any query, contact details and preferences provision or update, or in any regard in relation to one more Appointments (either as an Appointment Owner or an Attendee), you are giving Focused Therapy London your permission to process the information you provide as outlined within this Privacy Policy in order to be able to provide the Services you have requested. You are additionally providing Focused Therapy London with your consent that you accept that the information you provide will not to be used for any other purposes except as detailed within this Privacy Policy, without you already having given Focused Therapy London your express written consent to do so.

After reading through this Privacy Policy in full, should you want to get in touch with any questions or requests in relation to the storing or use of your information, under the Data Protection Act 2018 ('DPA') and the UK General Data Protection Regulation or the EU General Data Protection Regulation where you are an EU citizen or resident (together 'GDPR'), any such question or request must be sent to the registered Data Controller via the contact details listed within the Data Controller Details section further below.

Whose information is protected by this Privacy Policy

This Privacy Policy protects the information of all of the following individuals who interact with, or whose information is provided to, Focused Therapy London in relation to the Services:

  • Visitors to this Website
  • Potential Clients
  • Introduced Clients
  • New Clients
  • Current Clients
  • Former Clients
  • Mailing List Subscribers - whether in relation to Focused Therapy London's Newsletter and/or one or more Practice Offer Notifications

Updates to this Privacy Policy

I reserve the right to modify this Privacy Policy at any time it is discovered that there are any amendments that need to be made to it. I will ensure that this page maintains the Last Updated date it was last modified on and have additionally provided a change log below detailing the changes that occurred on this date. Please check back regularly to ensure that you are informed of your current agreement.

If there are any changes to Focused Therapy London (e.g. change of branding, change to limited company, change of company trading name) I reserve the right to change the Website to reflect this. Your privacy rights as a website visitor, a Client and/or as a Mailing List Subscriber will not be affected except as detailed within the updated Privacy Policy.

The information I collect

My primary functions when collecting your information is to use it for both the provision and the improvement of Focused Therapy London's Services to you. When you use the Website or contact Focused Therapy London in relation to the Services provided, I will store any necessary, pertinent or voluntarily disclosed information you provide and only use this information as necessary in order for me to fulfil these primary functions in accordance with the DPA and GDPR.

This information may include one or both of the following information types:

Personal Information

This type of information relates to the identity of an identified or identifiable natural person where not considered to be of a Sensitive Information nature. Examples of this type of information include, but are not limited to, the following:

  • Identity data – this includes details such as first name and surname; date of birth; job title; or, similar
  • Contact data – this includes details such as email addresses; mobile phone numbers; landline telephone numbers; instant messenger details; home and/or business addresses; or, similar
  • Any additional data you may provide; is provided about you; or, is automatically generated or obtained by your use of the Website or any electronic communication method, relating to: ID number; location data; IP address; physical, physiological and genetic information (non uniquely identifying); cultural or social preferences; languages spoken; or, similar

Sensitive Information

This type of information is more sensitive and could potentially put an individual at greater risk to their rights and freedom if there were to be any breach. Examples of this type of information include, but are not limited to, the following:

  • Health data – this includes details such as current and in some cases previous medical conditions; symptoms; pain levels; Medical Consent; medical diagnosis information; medications; allergies; prior surgeries; current and prior injuries; general fitness and well-being information; or, any similar information which may be provided that relates to health in order for Focused Therapy London to undertake risk assessment and establish suitability to receive specific body therapy treatments
  • Banking data - this includes bank account number; bank account sort code detail; or, similar which are required to be provided in order for Focused Therapy London to arrange electronic payment of any Refund due to you
  • Any additional data you choose to provide, or which is provided about you, relating to: racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic data; biometric data (where used for identification purposes); sex life or sexual orientation; or, similar

Information in relation to your health will only be required to be provided to Focused Therapy London where you are scheduled as the Attending Client of any Confirmed Appointment; or, where you are legally or otherwise required to accompany the Attending Client to any Confirmed Appointment in accordance with the Covid-19 Policy (until such time as it is removed from the Website). Under all other circumstances the provision of this type of information is voluntary and would not usually be required to be provided to Focused Therapy London, except where it was pertinent in relation to any query you choose to make to Focused Therapy London in relation to the Services for any reason; or, in order for Focused Therapy London to arrange electronic payment of any Refund due to you.

Information you provide on behalf of others

On any occasion where you as an individual or as part of an organisation provide me with another individual’s information, whether Personal Information or Sensitive Information, this is required to be provided on a lawful basis only. Focused Therapy London will always treat this other individual's information with the same care and due diligence as your own in accordance with the DPA and GDPR.

Any information given to me about another individual; be it as your Attendee, from the Appointment Owner of any Appointment of which you are their Attendee, where you introduce a potential or New Client to Focused Therapy London, in relation to any Query or under any similar circumstances in relation to the Services, will be considered an extension of your own information.

Under such circumstances, the information you provide in relation to this individual will remain linked to you and you are responsible for the data you provide and are accepted to have received consent from the other individual before providing their information to Focused Therapy London. This individual’s information will only be used by me, to the extent required, for the purposes of providing you and/or the relevant individual with the Services.

Information provided by others in relation to you

On any occasion where I am provided with information, whether Personal Information or Sensitive Information, in relation to you by another individual or organisation on your behalf, this information is required to be provided on a lawful basis only. Focused Therapy London will always treat your information provided by another with the same care and due diligence as if you had provided it yourself in accordance with the DPA and the GDPR.

Any information provided to me about you; be it from a General Practitioner ('GP'); any medically qualified individual, the Appointment Owner where you are their Attendee; your Attendee where you are the Appointment Owner; any other Client; the Clinics; any organisation; any other therapist; from your Insurance Company; where you are introduced as a potential or New Client to Focused Therapy London; in relation to any query or under any similar circumstances, this information will be considered an extension of your own information.

Under such circumstances, the information provided in relation to you will be linked to the individual or organisation that provided it and you will be considered to have provided your consent for this information to be provided to Focused Therapy London unless you notify me otherwise. Where information is received in relation to you under these circumstances, Focused Therapy London does not hold any responsibility in how this information is provided or that your express consent has been received in advance of it being disclosed, but will treat this information as though it had been received directly from you. Your information will only be used by Focused Therapy London, to the extent required, for the purposes of providing you with the Services.

Information collected in relation to Appointments

When you attend any Confirmed Appointment where Therapies are provided to you, I am legally required to compile a set of Client Notes which will include both Personal Information and Sensitive Information in relation to you.

Client Notes will be produced, or in some cases updated, around each Appointment you attend and/or are scheduled to attend and will be stored by me for legal record keeping purposes, business record keeping purposes, and for reference purposes in advance of any future Appointment attended by you within a specific time frame (see Data Retention Period).

For more comprehensive information about Client Notes, please refer to the details provided within the accordion below:

How information is collected

Your information may be received by Focused Therapy London via any of the following methods:

  • by the submission of one of the Contact forms on the Website
  • where it is provided in person or via phone, voicemail, text message, email, instant messenger, letter or other similar communication methods
  • where your details are provided by another Client in relation to you receiving any of the Services provided by Focused Therapy London, or where your details are provided via one of the Clinics in relation to a general or specific request to put you in touch with a therapist who provides the Services you are seeking
  • through visiting the Website, by the use of Website Cookies, as detailed within the Cookies Policy

Where third parties are used by Focused Therapy London as a standard business practice to receive your information, links to their UK, EU and/or EEA based privacy policies have been provided in the Third Party Website Links section at the end of this Privacy Policy for your ease of reference. The only exception to this is where they relate to Website Cookies, under which circumstances links to third party privacy policies can instead be found within the Cookies Policy.

How I ensure the security of your information

All information that is processed, used and/or stored by Focused Therapy London in relation to you is done so in accordance with the DPA and GDPR and the following measures have been put in place by Focused Therapy London to ensure the privacy of your information. This information will either be Digital Data or Hard Copy Data, often a combination of the two. Below you will find further details of the security protocols that have been put in place by Focused Therapy London to protect the privacy of your information.

For more comprehensive details about how Focused Therapy London implements security in relation to your Digital and Hard Copy Data, please refer to the details provided within the accordions below:

Cookies and Analytics used on the Website

The Website uses both of the following when visited:

Cookies

Focused Therapy London, like many other businesses, uses some Website Cookies ('cookies') on the Website. A Cookie Consent popup is used to notify you that cookies are used when you first visit the Website from your electronic device to request your direct consent to apply opt-in cookies when visiting it.

Where cookies are deemed to be Necessary Cookies required to make the Website perform correctly, these are set automatically without any direct consent required in accordance with GDPR rules.

Necessary cookies used on the Website do not provide Focused Therapy London with any identifiable information in relation to any user of an electronic device used to view the Website, nor do they require direct consent to be used. Necessary cookies may be disabled by amending your browser settings, but where this is implemented the Website may not function properly or in the way intended.

Any other cookies used on the Website require direct consent in order for them to be activated and unless this is received, these cookies will remain automatically disabled.

For more information about the cookies used on the Website, the ones that have been agreed to from your electronic device and how you can change your cookies preferences, please refer to the Cookies Declaration section within the Cookies Policy.

Analytics

Focused Therapy London additionally uses a third party, Google Analytics, in order to receive some basic analytics information on a non directly identifiable basis when you visit the Website should you provide direct consent to allow Statics Cookies that make this possible.

Website analytics provide statistics and basic analysis tools for search engine optimization (SEO) and marketing purposes. Google Analytics is used to track the performance of the Website performance and collect insights in to website visitors. It can help businesses to gain an insight in to website traffic, see which web pages are most of interest and improve any marketing campaigns it may have in place.

Further details in relation to Google Analytics can be found within the Cookies Policy.

Data Retention Period

Retention of Client Notes

Where you, as the Attending Client of any one or more Appointments, are 18 years of age or older, Focused Therapy London is legally and professionally obligated to keep Client Notes resulting from these Appointments for a minimum period of seven years from your final Appointment date.

Where you, as the Attending Client of any one or more Appointments, are under the age of 18 at the time of any Appointments, Focused Therapy London is legally and professionally obligated to keep Client Notes resulting from these Appointments until you are a minimum of 25 years of age.

Where there is any conflict between the two Data Retention Periods listed above in relation to the retention of your Client Notes, the longer Data Retention Period will apply in all such circumstances.

All Attending Client's Client Notes will either be deleted (electronic) or destroyed (hard copy) by Focused Therapy London after the relevant Data Retention Period has passed, or where there is a legitimate reason under the GDPR and/or DPA to continue retaining them, they will instead be archived and not accessed by Focused Therapy London until such time as there is either a legal reason or legitimate purpose in doing so.

Retention of information receive via Website Cookies

Details of retention periods of information received via Website Cookies when visiting this Website can be found within the Cookies Policy.

Retention of all other information

Where your information is provided to Focused Therapy London for any purpose other than in relation to an Appointment resulting in Client Notes, this information will only be process and used for any legitimate business purposes which have been agreed to by you, or on your behalf by another individual (such as a Parent, Legal Guardian or Carer), until such time as you or they update your contact preferences to notify Focused Therapy London that is is no longer wanted for this to occur, or alternatively at an earlier time should Focused Therapy London no longer consider that there is any useful and/or necessary business related purpose to continue doing so for any reason.

You, or this other individual on your behalf (where appropriate), are able at any time to provide or update your contact details and preferences in relation to receiving future communications and notifications about which specific Services offered by Focused Therapy London are notified to you or them, or to cease all future communications and notifications being sent until such time as you choose to request or be scheduled to receive the Services provided by Focused Therapy London again in the future, by submitting a Contact Details & Preferences form via the Website.

International Data Transfers

The information received from you may in certain circumstances be transferred to and stored by third parties outside countries governed by the UK GDPR. This will only occur where adequacy regulations (known as 'adequacy decisions' within the EU) apply; with your direct written request and consent to do so (exceptional circumstances only); or where direct consent to use Statistics Cookies when visiting this Website has been granted to Focused Therapy London, as this allow for the transfer of your information to Google data centres.

Where any international transfer of your information to a third party occurs on a standard business basis and does not fall under agreed adequacy regulations, Focused Therapy London ensures that any Standard Contractual Clauses (SCCs) that are required to ensure adequate levels of data protection have been agreed to with this third party in advance.

Third parties used by Focused Therapy London

Focused Therapy London uses various third parties in order to be able to provide you with its Services.

Where you submit your information to Focused Therapy London, you are agreeing to the transfer, storing or processing of it by both Focused Therapy London, and where relevant the third parties that Focused Therapy London uses as a standard business practice to provide you with the Services you have requested.

To ensure the protection of your information, Focused Therapy London always reviews the privacy policy of any third party it uses to ensure that it is either governed by GDPR or is based in a country where adequacy decisions are in place from the EU Commission (as granted to the UK on the 28 June 2021). Adequacy decisions permit a cross-border data transfer outside the EU, or onward transfer from or to a party outside the EU without further authorisation from a national supervisory authority. Where neither of these circumstances apply, Focused Therapy London ensures that Standard Contractual Clauses are put in place with any third party before any transfer of your information occurs as required under GDPR rules for restricted transfers.

A list of standard third parties used by Focused Therapy London and their privacy policies can be found as detailed below:

  • Third parties who provide Website Cookies on this Website - please see details within the Cookies Policy
  • For all other third parties - please see details in the Third party privacy policy links section below

The only other circumstances within which Focused Therapy London would provide your information to a third party other than as described above, any only in so far as was reasonably necessary, are for the purposes listed below:

  • with your direct consent to do so
  • where legally required to do so
  • to confirm to your private insurance company details of any receipt of payment already provided by Focused Therapy London in relation to an Appointment you have attended, that has already been provided to you, or directly to your insurance company on your written request
  • for debt recovery processing purposes, as detailed within the Overdue Payments section of the Terms of Service, where any one or more singular Overdue Payment debt remain due to Focused Therapy London from a specific Client 30 days or more after the relevant Overdue Payment occurred

External Website Links

Some links provided on the Website will take you to external websites. Where this occurs all such external website links are shown in bold blue. Focused Therapy London has no control over or input into any third party website content or their privacy policies or cookie policies and is therefore not responsible for their data practices these companies or their website. You will therefore need to read the privacy policy and cookie policy shown on any visited external website via any link provided, to ensure you are happy it sufficiently protects your information.

Your rights in relation to your information

The UK GDPR provides the following rights for individuals:

  • The right to be informed
  • The right of access
  • The right to rectification
  • The right to erasure
  • The right to restrict processing
  • The right to data portability
  • The right to object
  • Rights in relation to automated decision making and profiling

For a fuller explanation of your individual rights in relation to your information under the UK GDPR, a reliable source of information can be found here: ico.org.uk.

For a fuller explanation of your individual rights in relation to your information where the EU GDPR applies, rather than the UK GDPR, a reliable source of information can be found here: gdpr.eu.

Further details in relation to your rights, specifically as they relate to Focused Therapy London, can be found in the accordion below:

Should you wish to apply any of your above listed rights, please get in touch with the Data Controller as detailed below in the Data Controller Details section below, and Focused Therapy London will process your request.

When getting in touch for this purpose, please ensure to be clear about which right it is that you would like to apply and any specific information of yours, or that you have provided to Focused Therapy London on behalf of another individual, it is that you are concerned about. It is also necessary to state your particular concern around Focused Therapy London's use of this information where one applies, and additionally very helpful if you provide a specific time frame around when this information was provided, or time frame in which you have concern about its use, so that your query or request can be responded to without unnecessary checking of details which may cause a delay in providing you with the assistance you require.

Data Breaches

In accordance with the UK GDPR rules, should any data breach of your information occur, Focused Therapy London will ensure to notify you in writing without any undue delay where the breach is likely to result in a high risk of adversely affecting your rights and freedoms.

Where it is also required to notify a supervisory authority of any breach that has occurred, Focused Therapy London will additionally contact the Information Commissioners Office to report the data breach within 27 hours of becoming aware that this breach has occurred; or, as soon as possible thereafter where for any reason this timeframe is not feasible.

Complaints

If you are unhappy with the way that Focused Therapy London has handled your data, please voice your concerns directly with Focused Therapy London in the first instance by contacting the Data Controller as detailed below in the Data Controller Details section below, and Focused Therapy London will work with you to seek a resolution.

If, after this time, you are not satisfied with any response received from, or resolution found by, Focused Therapy London, you have the right to complain to the Information Commission Office ('ICO'): ico.org.uk

Focused Therapy London is registered with the ICO under Registration Number: ZA248976

Data Controller Details

All requests and communications relating to data protection must be sent to Focused Therapy London's Data Controller: Jacky Sayers

Any electronic communications must be emailed to: dataprotection@focusedtherapylondon.com

Any postal communication must be sent to: Jacky Sayers, Data Controller, Focused Therapy London, London Natural Health Centre, 46 Theobalds Road, London, WC1X 8NW, United Kingdom. Where this occurs, an email must additionally sent to the above email address within a maximum of 24 hours of the time this postal communication was sent, so Focused Therapy London is made aware that this communication is due to be picked up from this Clinic; and, to ensure it is read and responded to in a timely manner.

Third party privacy policy links

Please see links below to the privacy policies of third parties used by Focused Therapy London as a standard business practice in order to be able to provide you with its Services:

Caldera Forms - Website Contact Forms:
https://calderaforms.com/privacy-policy/

Google - Gmail, Google Maps, Google Analytics and Google Cloud:
https://policies.google.com/privacy

HSBC - Business Banking Provider:
https://www.hsbc.co.uk/privacy-notice/

Samsung - Samsung Cloud and numerous Samsung Apps:
https://www.samsung.com/uk/info/privacy/

Siteground - Web Hosting Provider:
https://www.siteground.co.uk/viewtos/privacy_policy/

WhatsApp - Instant Messenger Service Provider:
https://www.whatsapp.com/legal/updates/privacy-policy-eea

WordPress - Website Provider:
https://en-gb.wordpress.org/about/privacy/

Focused Therapy London does not have any responsibility or control in relation to website link or policy changes which occur in relation to each. These links are only provided by Focused Therapy London for ease of reference when looking for these policies as they apply to the UK, and you should ensure to check that the information provided at each website link remains correct at the time it is visited, as well as relevant should you be looking for privacy policy details that apply in relation to another country.