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.

CHANGE DATE CHANGES MADE
10 October 2021 Data Controller details
Wording amended and added in relation to postal communications sent to Focused Therapy London and the requirement to email the Data Controller within 24 hours of any postal communication being sent to the Clinic for Focused Therapy London's awareness.
30 June 2021 Relevant section: Updates to this Privacy Policy
Addition of Privacy Policy Change Log accordion and addition of wording in relation to it.

Relevant section: Third parties used by Focused Therapy London
Amendment of details in relation to adequacy decisions made by the EU Commission, adding a description of what adequacy decisions means and detailing the date upon which adequacy decisions were granted to the UK by the EU.
13 September 2021 Relevant section: Third parties used by Focused Therapy London
Amendment made in relation to text relating to debt recovery in relation to any one or more Overdue Payment, to bring all relevant details in line with changes made to the Overdue Payment section of the Terms of Service on the 13th September 2021.

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:

As a basic reference Client Notes held in relation to each scheduled Attending Client may include, but are not limited to, any of the following information that has already been provided by you or on your behalf in advance of you attending your Appointments or be based on information received during your Appointments:

  • Treatment Notes - a record of each Appointment you have with Focused Therapy London which contain legally required and other pertinent Personal Information and Sensitive Information details in relation to you. These also include the therapy protocols that were undertaken during your Appointment, your response and feedback in relation to them, and any additional details legally required or considered useful or necessary to be recorded by Focused Therapy London in relation to your treatment session
  • Signed Consent forms - consent forms that have been signed by you in person, or another individual on your behalf (where necessary), where these are a legally required or considered necessary by Focused Therapy London for you to receive specific treatment protocols, treatment in certain areas of your body or relate to GDPR Consent and Preferences
  • Electronic Consent Communications - copies of consent provided by you electronically to allow Focused Therapy London to provide your information to another individual or organisation not specifically mentioned within this Privacy Policy, Contact Detail and Preferences forms (new and updated) and Mailing List Preferences forms
  • External Consent and Notes related to you - copies of any written Medical Consent required for you to receive treatment, confirmations of verbal Medical Consent, written medical information received from you or a medical expert and/or treatment notes from another therapist in relation to you where these have been provided to Focused Therapy London either directly by Focused Therapy London or are provided via you
  • Medical Updates - any Covid-19 Screening forms (legally required during the pandemic) and Medical Update forms signed by you during your Appointments, as well as any other electronic (including attachments) updates you provide or which are provided on your behalf, to Focused Therapy London in relation to your medical health (which may include your current vaccination status, medications being taken and/or risk factors when receiving body therapy treatments)
  • Your Appointment and Payment future schedule and history - information pertaining to any Appointments arrangements put in place either by you or on your behalf, details of all Confirmed Appointments scheduled for you in the future and those which occurred in the past, as well as details of any Appointment Costs which remain due for payment or have already been received in relation to these Appointments
  • Consent forms signed by another individual on your behalf - such as where you are the Attending Client and legally require Parent or Legal Guardian Consent or Carer Consent in order to receive treatment from Focused Therapy London, or you are not able to understand and/or sign the necessary Consent form yourself for any reasonable reason

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:

Electronic Document Security

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.

Email Security

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.

Instant Messenger Security

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.

Mobile Phone Security

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.

Personal Computer Security

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.

Website Contact Forms Security

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

Website Cookies Security

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.

Website Security

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.

In Storage Security

Any hard copy documents that contain your information and are not currently in use are stored securely in locked filing cabinets which are only accessible by me, located within a non-public access building.

When in use within this environment, any hard copy document containing your information is not left unattended by Focused Therapy London at any time where there is a risk that it may be viewed by anyone other than myself.

In Use Security

I carry a basic Appointment schedule in hard copy with me the majority of the time which spans all Appointments scheduled or tentatively scheduled with Focused Therapy London for a period of five weeks from and including the current week. Where you have an Appointment scheduled or tentatively scheduled within this five week period, this Appointment schedule will include your first initial and surname, as well as very basic information in relation to your Appointment such as its date, start time and length, payment cost and status, and will additionally include the first initial and surname of the Appointment Owner where this is another individual. Beyond the inclusion of first initials and surnames, this Appointment schedule does not detail any other identifiable Personal Information or Sensitive Information in relation to any Clients of Focused Therapy London.

On the same day as any Appointment you have a scheduled or tentatively scheduled with Focused Therapy London, I will have hard copy documents with me which form part of your Client Notes. These Client Notes will include your most recent Treatment Notes and will additionally include any Consent Forms and Medical Updates which are required to be signed by you, or on your behalf (where relevant), at the start of your Appointment. These Client Notes are kept to the minimum amount necessary to provide you with your Appointment, but will contain your Personal Information as well as Sensitive Information relating to your health. Whilst in transit, I keep these Client Notes with me at all times and shielded from view by others. Whilst at the Clinic, your Client Notes are only brought out for use during your Appointment and at all other times are stored safely to ensure they are not seen by others. Should there be any time where your Client Notes will be left unattended by me whilst they are at the Clinic, and there is any risk of them potentially being seen by others, they are stored securely within either a locked security file box or locker which are not accessed by anyone other than myself.

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:

In all circumstances listed below, where terminology is used in relation to information held for you by Focused Therapy London, this additionally includes any information that is held by third parties as described within the Third parties used by Focused Therapy London section of this Privacy Policy.

Your right to be informed

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.

Your right of access

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.

Your right to rectification

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.

Your right to erasure

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.

Your right to restrict processing

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.

Your right to data portability

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

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.

Your rights in relation to automated decision making and profiling

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.

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.