PRIVACY POLICY
TBI Therapy Associates
PRIVACY POLICY
This privacy policy sets out how TBI Therapy Associates Limited use and protect your personal
data.
This website is not intended for children and we do not knowingly collect data relating to children.
Any reference to “you” or “your” throughout this Privacy Policy means the individual to whom we provide our services, or if you are business your client to whom we provide our services and/ or the person within your business who we liaise with.
If you have any questions about this privacy policy, including any requests to exercise your legal rights (paragraph 9), please contact us using the information set out in the contact details section (paragraph 10).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.
attend an initial assessment with us;
order treatments from us;
request marketing to be sent to you; and
give us feedback or contact us.
NHS;
your GP;
other healthcare professionals who have provided treatments to you; third party consultants engaged by us to provide treatments to you; and insurance providers.
Technical Data is collected from the following parties:
analytics providers;
advertising networks; and
search information providers.
Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery services.
Identity and Contact Data is collected from data brokers or aggregators. Identity and Contact Data is collected from publicly available sources.
We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which services and offers may be of interest to you so that we can then send you relevant marketing communications.
If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or patient service purposes for example relating to appointment confirmations, appointment reminders, updates to our Terms and Conditions or checking that your contact details are correct.
please see our cookie policy.
We may also share your personal data with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our patients (including Contact, Identity, Financial and Transaction Data) for six years after they cease obtaining treatments or services from us.
In some circumstances you can ask us to delete your data: see paragraph 9 below for further information.
Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see paragraph Opting Out of Marketing above for details of how to object to receiving direct marketing communications).
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machinereadable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
If you want us to establish the data's accuracy;
Where our use of the data is unlawful but you do not want us to erase it; Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
If you wish to exercise any of the rights set out above, please contact us by email to admin@tbitherapyassociates.co.uk.
Email address: admin@tbitherapyassociates.co.uk
Telephone number: 07894546397
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.
IMPORTANT INFORMATION AND WHO WE ARE
This privacy policy gives you information about how we collect and use your personal data through your use of this website, including any data you may provide when you obtain services from us.This website is not intended for children and we do not knowingly collect data relating to children.
CONTROLLER
TBI Therapy Associates Limited is the controller and responsible for your personal data or if you are a business any personal data relating to your client which you provide to us (collectively referred to as "we", "us" or "our" in this privacy policy).Any reference to “you” or “your” throughout this Privacy Policy means the individual to whom we provide our services, or if you are business your client to whom we provide our services and/ or the person within your business who we liaise with.
If you have any questions about this privacy policy, including any requests to exercise your legal rights (paragraph 9), please contact us using the information set out in the contact details section (paragraph 10).
THE TYPES OF PERSONAL DATA WE COLLECT ABOUT YOU
Personal data means any information about an individual from which that person can be identified.We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Medical / Treatment Records
which includes details of any treatments you have received from us or a third party in addition to reports and notes on your health generally. We also collect data on your current physical health which may include details of hospital or clinic visits and any medication administered to you.Identity Data
includes first name, last name, or similar identifier, title, date of birth and gender.Contact Data
includes billing address, email address and telephone numbers.Financial Data
includes bank account and payment card details.Transaction Data
includes details about payments from you and details of services you have purchased from us.Technical Data
includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.Usage Data
includes information about how you interact with and use our website and services.Marketing and Communications Data
includes our communications with you and your preferences in receiving marketing from us and our third parties and your communication preferences.We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.
HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:Your interactions with us
You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:attend an initial assessment with us;
order treatments from us;
request marketing to be sent to you; and
give us feedback or contact us.
Automated technologies or interactions
As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. You can view our cookie policy by checking our cookie policyThird parties
We will receive personal data about you from various third parties as set out below:NHS;
your GP;
other healthcare professionals who have provided treatments to you; third party consultants engaged by us to provide treatments to you; and insurance providers.
Technical Data is collected from the following parties:
analytics providers;
advertising networks; and
search information providers.
Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery services.
Identity and Contact Data is collected from data brokers or aggregators. Identity and Contact Data is collected from publicly available sources.
HOW WE USE YOUR PERSONAL DATA
LEGAL BASIS
The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:Performance of a contract with you:
Where we need to perform the contract we are about to enter into or have entered into with you.Legitimate interests:
We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure patient experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).Legal obligation:
We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.Consent:
We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.DIRECT MARKETING
During the registration process with us when your personal data is collected, you will be asked to indicate your preferences for receiving direct marketing communications from us via email, SMS or post.We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which services and offers may be of interest to you so that we can then send you relevant marketing communications.
THIRD-PARTY MARKETING
We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.OPTING OUT OF MARKETING
You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us by telephone 07894546397 or email admin@tbitherapyassociates.co.uk.If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or patient service purposes for example relating to appointment confirmations, appointment reminders, updates to our Terms and Conditions or checking that your contact details are correct.
COOKIES
For more information about the cookies we use and how to change your cookie preferences,please see our cookie policy.
DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data where necessary with third party consultants for the purposes of providing treatments or services to you.We may also share your personal data with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
INTERNATIONAL TRANSFERS
We do not transfer your personal data outside the UK.DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our patients (including Contact, Identity, Financial and Transaction Data) for six years after they cease obtaining treatments or services from us.
In some circumstances you can ask us to delete your data: see paragraph 9 below for further information.
YOUR LEGAL RIGHTS
You have a number of rights under data protection laws in relation to your personal data. You have the right to:Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see paragraph Opting Out of Marketing above for details of how to object to receiving direct marketing communications).
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machinereadable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
If you want us to establish the data's accuracy;
Where our use of the data is unlawful but you do not want us to erase it; Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
If you wish to exercise any of the rights set out above, please contact us by email to admin@tbitherapyassociates.co.uk.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.CONTACT DETAILS
If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:Email address: admin@tbitherapyassociates.co.uk
Telephone number: 07894546397
COMPLAINTS
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
We keep our privacy policy under regular review.It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.