Privacy Notice and Cookie Policy

I am committed to protecting and respecting your privacy and the law requires me to explain your rights and my obligations to you.

This policy complies with applicable English law, including the EU General Data Protection Regulation (GDPR) and the Data Protection Act 2018.

Please carefully read this Privacy Notice as it contains information on:

• The personal data I may request

• Your privacy rights and your protection under the law.

I reserve the right to modify this privacy policy at any time, for example, if the law changes. Changes will take effect immediately upon being posted on this website and you will be deemed to have accepted the terms of the privacy policy when you first give consent.

Information on me: 

• Inner Compass Therapies is a trading name used by me, Kishori Pancholi, through which I provide a private psychological service which provides assessment and treatment of mental health disorders to fee-paying and insurance based patients

• I operate the website www.innercompasstherapies.co.uk (the “Website”)

• I am a data controller under the data protection rules. Please contact me here for more information on this Privacy Policy

What I collect:

When you become a client a contract is formed between us. The service I provide you as a client necessitates you providing personal information including:

Your name

• Contact information including email address, telephone number, mobile phone number, postal address

• Emergency contact details

• GP details

• Relevant medical details

• Preference for receiving information by email, phone,  text or letter

I process this information on the basis that there is a contract between us, or that you have requested we use the information before we enter into a contract.

I will continue to process this information until the contract between us ends or is terminated by either party.

How I may use your information

I rely on the legitimate interest basis to use your personal information. For example, when you access my services, I have a legitimate interest to use your information to respond to you for your benefit.

I also rely on obtaining your consent to use your personal information. For example, I will seek your consent to receive emails about further available services.

I may use your information for a number of purposes including the following:

• For invoicing purposes

• To provide you with information about changed or cancelled services

• To provide you with information about my work or activities that you have agreed to receive

• To assess my performance (anonymised)

• To ensure I know how you prefer to be contacted

• To keep a record of which services you have received from me

• To make suggestions and recommendations to you about goods or services that may interest you.

• To notify you about changes to my services

• For any other reasonable purposes, acting always in accordance with the data protection law (as amended from time to time)

Information I process with your implicit consent:

You provide your consent to me to process information that may be personal data through certain actions when otherwise there is no contractual relationship between us. For example, when you browse The Inner Compass Therapies website or ask me to provide you with more information about my services.

• Wherever possible, I aim to obtain your explicit consent to process this data

• Sometimes you give your consent implicitly, such as when you write to Inner Compass Therapies requesting a response

• When you contact Inner Compass Therapies by telephone, or by email, I collect the data you have given me in order to give the information you have requested

• I record your request and your reply on the basis that there is legitimate interest to efficiently manage my business

• I keep personally identifiable information associated with your message such as your name, telephone number or email address so as to communicate with you and provide a high quality service

• Sometimes I process information because I have a statutory obligation to comply with a legal requirement. (For example, I may be required to give information to legal authorities, if they so request, or if they have the proper authorisation such as a search warrant or court order)

• I will continue to process your information on this basis until you withdraw your consent

• You may withdraw your consent at any time by contacting me. 

The lawful basis and purpose of the processing:

• Your explicit consent is the lawful basis for the processing of your personal data

• The purpose of the processing is to provide you with an efficient service in terms of arranging appointments and for professional record keeping

• Your personal information will not be shared unless you give permission, or we are required by law to do so

Information Sharing and Disclosure

I may share your information with the following selected third parties:

• Your GP, but only with specific, written permission from you

• If I am under a duty to disclose or share your personal data in order to comply with any legal obligation, (for example to government bodies and law enforcement agencies) or in order to enforce or apply other agreements; or to protect my rights, property, or safety or that of others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction. No data is to be shared outside of the EU.

Keeping your records

• I keep records of your personal information only for as long as required to operate the service in accordance with legal requirements and tax and accounting rules

• I will keep certain personal information for longer in order to confirm your identity, when you were a client of Inner Compass Therapies and for how long

• However, unless specifically requested in writing by you, assessment materials will be kept for a period of 2 years (unless required to inform on-going support) and then destroyed. Assessment reports will be kept securely in electronic and handwritten form for an appropriate length of time-usually 5 years-to allow your access to them at a future date

• I may retain non-identifiable data for statistical purposes for longer than 5 years

Where we may store your information

The data that we collect from you will be stored securely by me and/or electronically on The Inner Compass Therapies online systems.

• Your personal data is kept to help provide you with the services you have requested

• For the purposes of record keeping

• To comply with the law

• To support a claim or a defence in court

• To comply with the regulations of my professional body the British Association of Cognitive and Behavioural Psychotherapy (BABCP)

By submitting your personal data, you agree to this transfer, storing or processing.

I will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

Your Control of your personal data

• Your personal information will be held and processed until you withdraw consent

• You have the right to have your information erased

• You have the right to request access to the personal information that is held. We will respond within 30 days

• You have the right to have your personal data corrected

• You have the right to lodge a complaint regarding the use of your personal data with the ICO https://ico.org.uk/concerns

Security

I am committed to ensuring that your information is secure. I have policies and procedures in place to prevent unauthorised disclosure and to safeguard the information that is collected.

Complaint

• If I receive a complaint, I will record all the information I am given

• I will use that information to resolve the complaint

• If I think a complaint is vexatious or without basis, I will not enter into correspondence 

• If you complain about the content of my website, I will investigate your complaint. If I feel it is justified, or if I feel the law requires me to do so, I will remove the content

• If you have a complaint about how your data has been processed, you should inform me here.

Links to other websites

• The Inner Compass Therapies website may contain links to other websites of interest

• Once you have accessed these links, we do not have control over those websites

• Such websites are not governed by this privacy policy and we cannot be held responsible for the protection and privacy of any information you may provide when visiting them