Privacy Policy

What data I collect about you Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). I may collect, use, store and transfer different kinds of personal data about you such as personally identifiable information such as first name, last name, username or similar identifier, marital status, title, date of birth and gender, occupation, as well as contact data such as email address, home address and telephone numbers.

I also collect Special Categories of Personal Data about you (this includes details about your health) as this is necessary to provide you with the best service. This may include consent to communicate with your GP. I do not collect any other special category including information about criminal convictions and offences.

How I collect data?
Personal information about you may be collected when you correspond with me via phone, email, filling in forms via the website or otherwise.

How I process or share personal data: 
I will use your personal data to fulfil your instructions and requirements and I will ask only for data that is adequate, relevant and not excessive for those purposes. I will only use your personal data when the law allows it. Most commonly, I will use your personal data in the following circumstances:

-Where I need to perform the contract I am about to enter into or have entered into with you. Note that, in this context, a contract does not have to be a formal signed document, or even written down, as long as there is an agreement which meets the requirements of contract law. Broadly speaking, this refers to your request to access therapy services via this service and need to be contacted as part of this service that you require, for which there is a fee payable.

-Where it is necessary for legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

-Where I need to comply with a legal or regulatory obligation.

Consultation

As a therapist I have regular supervision / consultations with other therapists qualified in this process. The process is for the regulation of my own practice (rather than seeking instruction on working with you). In order to protect your privacy, supervisors/consultants do not relay information that would identify you personally nor professionally.

Emergencies

If you are at risk of harm, I may share your contact information with an emergency healthcare service such as a Mental Health Crisis Team or GP (if you consent). If I have become aware of your intent to cause harm to another person/organisation (e.g.terrorism), the law may require that I inform an authority without seeking your permission. In such a situation, the law may require that I share your personal information without your knowledge.

​How secure is my data?

I 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. I 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 I am legally required to do so.

How long will you use my personal data for?

I will only retain your personal data for as long as necessary to fulfil the purposes I collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, I 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 I process your personal data and whether I can achieve those purposes through other means, and the applicable legal requirements. I keep basic information about my patients (including Contact, Identity, Financial and Transaction Data) for 7 years after they cease therapy with me, for tax purposes and to comply with insurance requirements. In some circumstances you can ask me to delete or amend your data see below for further information. In some circumstances I may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case I may use this information indefinitely without further notice to you.

Can I access or amend my data?

​Upon receipt of your written request and enough information to permit me to identify your personal data, I will disclose to you the personal data I hold about you, for which I may make a charge up to the maximum as allowed by applicable law. I will also correct, amend or delete any personal data that is inaccurate and notify any third party recipients of the necessary changes. In some cases I may be able to delete data at your request. Access requests should be made in writing to Ron Bushyager, 195-197 Victoria Street, London SW1E 5NE. I try to respond to all legitimate requests within one month. Occasionally it may take me longer than a month if your request is particularly complex or you have made a number of requests. In this case, I will notify you and keep you updated.

Glossary

Legitimate Interest means the interest of my work in conducting and managing my business to enable me to give you the best service and the best and most secure experience. I make sure to consider and balance any potential impact on you (both positive and negative) and your rights before I process your personal data for legitimate interests. I do not use your personal data for activities where my interests are overridden by the impact on you (unless I have your consent or are otherwise required or permitted to by law). Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that I am subject to.

YOUR LEGAL RIGHTS

You have the right to:

-Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data I hold about you and to check that I am lawfully processing it.

-Request correction of the personal data that I hold about you. This enables you to have any incomplete or inaccurate data I hold about you corrected, though I may need to verify the accuracy of the new data you provide to me.

-Request erasure of your personal data. This enables you to ask me to delete or remove personal data where there is no good reason for me continuing to process it. You also have the right to ask me to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where I may have processed your information unlawfully or where I am required to erase your personal data to comply with local law. Note, however, that I 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 I am relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, I may demonstrate that I have compelling legitimate grounds to process your information which override your rights and freedoms.

-Request restriction of processing of your personal data. This enables you to ask me to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where the use of the data is unlawful but you do not want me to erase it; (c) where you need me to hold the data even if I no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but I need to verify whether I have overriding legitimate grounds to use it.

-Request the transfer of your personal data to you. I will provide to you, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where I used the information to perform a contract with you.

-Withdraw consent at any time where I am relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, I may not be able to provide certain services to you. I will advise you if this is the case at the time you withdraw your consent.

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