Privacy Policy

Any electronic documents, such as text documents, spreadsheets, scanned documents or PDF files, which are stored or used by Focused Therapy London and contain any of your personal information are password protected, and where they contain your sensitive information are encrypted, to make them unreadable by anyone other than Focused Therapy London. A password or a decryption key is required in order to access encrypted files and these are not provided to anyone beyond me.

All electronic documents which contain your information are only created, amended, viewed, scanned or accessed by Focused Therapy London and are therefore not seen by any other individual or organisation without written consent for your information to be provided to another individual or organisation having been received by Focused Therapy London from you, or someone who is legally permitted to give consent on your behalf (such as a Parent or Legal Guardian where you are a minor), in advance.

The only time that any electronic document containing your information would be provided to you or another individual or organisation you designate, would be where you, or someone who is legally permitted to give consent on your behalf, have specifically requested in writing for this to occur, and under these circumstances your information would be provided taking relevant security measures to ensure the privacy of your information was maintained whilst the electronic document was in transit.

Focused Therapy London use Transport Layer Security ('TLS') protection for emails. TLS is an encryption protocol that protects information when it is sent between electronic devices. Use of TLS to protect email traffic is the standard method to ensure email security and all modern email services support TLS when sending and receiving emails.

At the current time, Focused Therapy London only provides a link to WhatsApp for Instant Messenger ('IM') messaging via the internet on its Website and additionally only uses WhatsApp as its standard communication method for sending and receiving direct one to one IM messages for business purposes. Under WhatsApp's European Region (EEA) privacy policy all direct messages and calls are end-to-end encrypted and no one outside the IM message sender and receiver, including WhatsApp itself, can read or listen to them.

Focused Therapy London does not currently use any other IM service provider to send business related IM messages, unless these are in direct response to an IM message received by me via any other IM service provider I have an account with for non business related purposes. Where this occurs, it is the responsibility of the message sender to ensure that they have read and agree to relevant IM service providers most up to date privacy policy in advance of requesting to, or it can be reasonably understood from their message that they wish to, receive a reply from Focused Therapy London which includes any Personal Information and/or Sensitive Information via direct reply. Unless expressly requested by the sender, Focused Therapy London will only reply providing the minimum Personal Information necessary, and no Sensitive Information unless this has been requested, to provide the IM message sender with a reasonable business response in relation to their sent message, or may instead request to provide this information to the sender via a preferred standard business use communication method listed within this Privacy Policy and currently uses for business purposes that it already knows covers any required privacy concerns under the DPA and GDPR.

Clients should only use IM service providers to get in touch with Focused Therapy London where use of their IM service is mentioned or a link to their IM services has been provided on this Website, or any IM messages sent to Focused Therapy London may not be received at all or are not standardly used for business purposes. Where you use an IM service that is not mentioned or linked on this Website, any IM message sent is not guaranteed to be read on any regular basis, or at all, where an IM account is already held by me, and additionally this IM service provider has not been checked to ensure its UK relevant data protection policies ensure that any information sent by you via its services is adequately protected for privacy of your data when this information is sent within the UK in accordance with the DPA and GDPR.

Focused Therapy London use an encryption protocol on the mobile phone that it uses for business purposes. This encryption protects your information from being accessed by anyone other than me via this mobile phone, whether it is saved as contact information, received or sent within an email, text message, phone call, voice message, IM message or where relevant as an attachment.

This business use mobile phone is not left unlocked when unattended by me, and an automatic encryption lock protocol has additionally been implemented to occur within a very brief period of inactivity for enhanced security purposes.

Any personal computer, including any tablet, used to store or access your information is only used by Focused Therapy London and password protected when not directly in use. A firewall is also always active on any such personal computer to further protect your information but, as with all firewalls, this cannot be guaranteed not to be circumvented or hacked.

Where for any reason Focused Therapy London considered it necessary to use any other individual or organisation's computer or tablet to access any of your information, such as by logging in to its business use email account via such an electronic device, this would only occur where it was considered sufficiently well protected to be safe to do so, and ensuring that none of your information would be at risk of being accessible or in any way provided to the relevant individual or organisation in the process of doing so.

Focused Therapy London has numerous contact forms on its Website, all of which are currently provided by Ninja Forms.

Whenever a form is submitted via the Website two processes are set to occur automatically:

• an email version of the information provided in the relevant Website contact form is automatically generated and sent to Focused Therapy London by Ninja Forms via WordPress; and
• WordPress creates a backup log of the information provided in each submitted form which can be viewed by Focused Therapy London

Focused Therapy London has ensured that tools have been used within all contact forms on the Website, so that any entry which does or may include any Personal Information or Sensitive Information, is tagged specifically for reporting and erasing of personal data in accordance with the GDPR.

Focused Therapy London also ensures that all information received by the submission of any of the contact forms is deleted from the backup log generated by WordPress no more than two months after the date each individual contact form was submitted via the Website.

The email versions of the information provided by the Website contact forms sent to Focused Therapy London are retained for business record keeping purposes in accordance with the Data Retention Period section below.

Focused Therapy London uses the Cookiebot plugin ('Cookiebot') to gain direct consent to use any non-essential Website Cookies when visitors use the Website. Consents are automatically collected by Cookiebot on Focused Therapy London's behalf through a secured SSL-connection and all consents are stored as strongly encrypted keys. All Website visitor consents are automatically logged by Cookiebot in an anonymised form before cookie consent data is provided to Focused Therapy London.

For further details of all Website Cookies that Focused Therapy uses on the Website please refer to the Cookies Policy.

Focused Therapy London's Website uses an SSL Certificate (Secure Sockets Layer), to ensure that any information communicated via the Website is encrypted between the web browser and the web server. This secure encryption is considered the gold standard for protection for users of any website when providing Personal and/or Sensitive Information via any website, and this security can always be checked by ensuring the website address is prefixed by 'https' rather than 'http'.

Without SSL certification, website visitors are at higher risk of having their data stolen. SSL certification protects websites from phishing scams, data breaches, and many other threats and provides a secure environment for both website visitors and website owners.

Focused Therapy London keeps you informed by the provision of a comprehensive Privacy Policy and Cookies Policy on the Website, as well as the use of a Cookies Consent Popup to request direct consent for the use of opt-in website cookies when this Website is first visited; and through using appropriate notification methods to keep you informed should any substantial or material changes occur to either of Focused Therapy London's policies.

You are entitled to request what information is held for you by Focused Therapy London. This right of access is commonly referred to as a Subject Access Request.

When making any Subject Access Request to Focused Therapy London, please provide as much detail as possible to the Data Controller about the information that you require and whether it relates to a particular area of information, Service, Appointment, incident and/or a specific period of time.

The Data Controller will come back to you to agree the medium in which you would like your information to be provided to you and will require you to provide proof of your identity to ensure you are the rightful owner of the data that is to be provided.

In some cases, there may be a legal or other reason why it is not possible to facilitate all or some aspect of your request. Where this is the case, the reason for this will be disclosed to you.

You are entitled to request any information that Focused Therapy London holds for you that is inaccurate is rectified to become accurate by the removal of any errors, or to be completed where it is incomplete.

You are entitled to request the erasure of any information that Focused Therapy London holds for you.

Where you request erasure of your information, Focused Therapy London will comply with your request in accordance with the UK GDPR rules. Where any request to erase your information relates to any Client Notes Focused Therapy London holds for you, and your request to have this information erased falls within the legally required Data Retention Period to keep these records, any Client Notes Focused Therapy London holds for you will instead be archived and not accessed until the relevant Data Retention Period detailed above has passed. Once this legally required Data Retention Period has passed will your Client Notes be deleted (electronic) or destroyed (hard copy) as per your erasure request. After this time, only a basic record of your request to have your information erased and confirmation from Focused Therapy London that this has and/or will occur once the relevant Data Protection Period has passed will be kept for business record keeping purposes.

Where you withdraw your consent for your information to be processed, Focused Therapy London will comply with your request in accordance with the UK GDPR rules, and any Client Notes Focused Therapy holds for you will be archived and not be accessed except where Focused Therapy London receives your written consent to do so, where accessing them is necessary to protect the rights of another individual (natural or legal), where there is a need for Focused Therapy London to do so for the establishment, exercise or defence of legal claims, or until Focused Therapy London notifies you in advance that this restricted processing is being lifted again (see further details below).

Requests to restrict processing are usually short term measures only implements whilst any issue with the processing of your information is resolved. Once any issue that caused you to withdraw your consent for the processing of your information is resolved, Focused Therapy London will notify you in advance that it is lifting this restriction and before starting to process your information again.

Where you request your information under data portability, Focused Therapy London will comply with your request in accordance with the UK GDRP rules. Please be aware, you will usually be required to provide some proof of your identity to confirm that you are the rightful owner of the data that is to be provided in order for Focused Therapy London to be able to provide you with your information.

Where your data portability request is in relation to information received via website cookies, you will need to provide Focused Therapy London's Data Controller with Your Consent ID and Consent Date of the relevant electronic device as detailed within the Cookies Declaration section of the Cookies Policy.

Where your data portability request is in relation to information received by one of the Contact Forms used on the Website, you will need to provide Focused Therapy London will relevant details in relation to which form it was that was submitted and an approximate timeframe as to when this occurred.

For any other data portability request, please provide details of the specific data you require.

There should be no issue with providing you with any third party data as part of a portability request, as long as the data has not already been manually or automatically deleted; and, on the basis that you were the individual who originally provided this information to Focused Therapy London. However, there may be an issue where your information also includes that of a third party whose rights and freedoms will be adverse effected in the process, particularly where you request that Focused Therapy London provides any third party information directly to another controller rather than to yourself as all parties will then need to provide their consent in order for Focused Therapy London to be able to transmit this data directly to the other controller.

Your right to object to the processing of your information only applies in certain circumstances.

Where you object to the processing of your information, you are required to notify Focused Therapy London's Data Controller of the specific reasons why you are objecting and give details of the particular situation which has brought about your objection.

Focused Therapy London always takes any objection to the processing of information seriously, and measures have been put in place to ensure your information is only processed for legitimate reasons or where any necessary direct consent has previously been received. Where after exploring your objection, no legitimate reason can be found to process your information, or any direct consent has not been received or has since been changed, Focused Therapy London will immediately cease the processing of your information as necessary in accordance with the UK GDPR rules. Under any other circumstances, Focused Therapy London will disclose to you the legitimate reason it is necessary to process your information, or where relevant provide confirmation that direct consent was previously provided to process your information in this way and discuss with you how you are able to change your consent details going forward should you wish to do so.

Focused Therapy London does not make any decision based solely on automatic processing, including profiling, which produces any legal effects concerning you or similarly significantly affects you and therefore this right has been added for your awareness only and does not apply in relation to any of your information which is, or has previously been, provided to Focused Therapy London.