Turnstone Therapy Practice Ltd. has legal duty to show you this notice under UK-GDPR and as a practice I am committed to protecting you and respecting your privacy.
I understand that your personal data is entrusted to the practice and appreciate the importance of protecting and respecting your privacy. To this end I comply with UK-GDPR law (which came into effect on the 1st January 2021) and all that it entails.
This Privacy Policy sets out the basis on which I collect and process personal data about you including my practices regarding the collection, use, storage and disclosure of personal data that I collect from you and/or hold about you, and your rights in relation to that data.
Please read the following carefully to understand how I process your personal data. By providing your personal data or by using the services of Turnstone Therapy Practice Ltd., you are consenting to the practices as described or referred to in this Privacy Notice.
For the purpose of UK-GDPR, the data controller is Turnstone Therapy Practice Ltd registered at Companies House (number 11560991).
What Personal data may be collected from you:
When referring to personal data in this policy, it means information that can or has the potential to identify you as an individual.
Accordingly, when you make an initial enquiry and leave your name & telephone number for example or complete a form during the assessment stage, this is you providing personal information, which may identify you. Depending on what services you receive this may include sensitive personal data such as information relating to your health, career, finances and living arrangements. I therefore have a legal duty to process your data safely and effectively.
Personal data I collect from you may include the following:
• name, address, contact details (including email address and phone number).
• details of referrals or correspondence from another therapist, medical professional, employer/employee assistance programme or insurer.
• details of contact and correspondence I may have had with you
• brief notes from sessions
• Bank transfer information and a record of payments made / receipts given.
• Details of your emergency contact (other than your GP – such as a next of kin), who you will be required to provide during your assessment session and we will discuss under what circumstances they would be contacted.
• feedback and therapy/coaching outcome information you provide / information obtained from feedback surveys which you may have participated in.
• information about complaints and incidents.
• What we discuss in your sessions may include sensitive personal information, relating to your mental or physical health or racial or ethnic origin (which may include family information, including children’s data). By providing this sensitive personal data, you are providing your explicit consent for Turnstone Therapy Practice Ltd. to process this sensitive personal data for the purposes set out in this Privacy Notice.
Your personal data may be collected when:
• visiting the websites (due to cookies).
• visiting information relating to Turnstone Therapy Practice Ltd. on online directories and social media where is places marketing profiles/pages.
• contact me via telephone or email, such as to enquire about booking therapy/coaching sessions.
• during therapy/coaching sessions
• when filling in a form or survey.
Personal data may also be received from third parties and other sources:
Occasionally I may receive personal data about you from third parties such as:
• a referral from your GP, another therapist or employer/employee assistance programme, however this should be done with your knowledge and would usually contain very basic personal data, which we would then discuss in session.
Storage of your personal data:
Your personal data will be kept confidential and secure and will, unless you agree otherwise, only be used for the purpose(s) for which it was collected and in accordance with this Privacy Policy, applicable Data Protection Laws.
Sensitive personal data related to your health will only be disclosed to those involved with your treatment or care in an emergency/or with your agreement if referring you on to another therapist/healthcare provider. Please note that, although this notice sets out the purposes for which I may use your personal data below, other than in the case of an emergency your sensitive personal data will not be used unless you have given your explicit consent for me to do so.
Therefore I may use your personal data to:
• enable me to carry out my obligations to you arising from any contract entered into between us, including the provision of services and related matters such as, billing, accounting and audit, payment verification and anti-fraud screening.
• Your contact data is held to enable me to provide you with a response to your queries, in a timely manner and provide you with information about any changes to the service provided as they arise, as well as notify you of any future products / services offered that I feel may interest you. Unless you have requested no further correspondence.
• periodically check the accuracy of information about you and assess the progress of your therapy/coaching.
• request feedback at the end of your therapy, providing you with the opportunity to provide verbal comments in session and also to complete a survey at a later date, having had time to reflect.
• to conduct and analyse market research
• to ensure that content from any of my websites is presented in the most effective manner for you and for your computer
Please note: Your data is not shared without your express permission and no automated decisions are made regarding your data
If you have any concerns or complaints please raise them as soon as they occur, so we can discuss them.
The security of your personal data:
At Turnstone Therapy Practice Ltd. I, as its Director, ensure that I have appropriate organisational and technical security measures in place to prevent unauthorised access or unlawful processing of your personal data and to prevent your personal data being lost, destroyed or damaged. I will also conduct assessments to ensure the ongoing security of my information systems.
Any personal data you provide will be held for as long as is necessary having regard to the purpose for which it was collected and in accordance with all applicable UK laws.
All information you provide to us is stored securely. Any payment transactions should be sent in advance of sessions via BACS payments (or be made in cash prior to a session starting) and details of your payment information will be kept secure. BACS bank information will be provided during your first session.
I may occasionally transfer personal information to you via email, or you may choose to transfer information to me via email. Email is not a secure method of information transmission; if you choose to send or receive such information via email, you do so at your own risk.
Sensitive information collected during therapy
Sensitive personal information discussed during your therapy may be noted down by the therapist in brief therapy notes. These are anonymised so that only the therapist will know who they are attributed to and will only be disclosed to a third party (such as your GP) with your express permission. The only exception to this would be in safeguarding/emergency situation, which will be fully explained to you during your assessment session to ensure you fully understand this prior to signing the therapeutic contract.
External practitioners/your GP: If I do refer you externally for treatment, I will share with the person or organisation that I refer you to, the therapeutic and administrative information I consider necessary for that referral. Prior to doing this, I will discuss it with you and be clear on what will be included, ensuring you are in agreement.
Therapy Supervisor: Every therapist is required to undergo regular supervision with a qualified therapist more senior to ourselves. During these sessions, we do discuss our client caseload, whilst we are focusing on the presenting issues of all my clients, there is a possibility that some personal information may be discussed to add context. However, it should be noted that Supervisors are bound by the same ethical codes. This will be explained further in your assessment session.
Marketing
Your information will never be passed on or sold to a third party for marketing purposes. If you have consented to Turnstone Therapy Practice Ltd. processing your personal data for maintaining contact with you following your therapy, in accordance with this Privacy Policy, we may send you information (via mail, email, phone or SMS) about future products and services which I consider may be of interest to you.
You have the right to ask me not to process your information in this way at any time. If you no longer wish to receive such information please e-mail admin@turnstonetherapypractice.co.uk
CCTV
My premises are surveyed by a security camera from a neighbouring businesses for the purposes of security. Images and videos may be retained for a limited period. Please note that there is not a camera the therapy area.
Accessing and updating your information:
The law gives you certain rights in respect of the personal data that we hold about you. In addition to your right to stop marketing, detailed above, below is a short overview of the most commonly-used rights. It is not an exhaustive statement of the law.
• You have the right to request a copy of your personal data in writing.
• You have the right to have the personal data we hold about you corrected if it is factually inaccurate. It is important to understand that this right does not extend to matters of opinion, such as therapeutic assessments, medical diagnoses etc. If any of your personal data has changed, especially contact information such as: email address, postal address and phone number please let me know by e mailing admin@turnstonetherapypractice.co.uk so I can ensure your personal data is kept up to date.
• If you want to exercise your rights in respect of your personal data, the best way to do so is to contact me by email on admin@turnstonetherapypractice.co.uk. In order to protect your privacy, I may ask you to prove your identity before I take any steps in response to such a request.
Changes to the Privacy Policy
I keep this Privacy Notice under regular review and as a result it may be amended from time to time without notice. As a result I encourage you to review this Privacy Policy regularly.
Contact
If you have any questions in relation to our privacy policy, please email me at admin@turnstonetherapypractice.co.uk
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Session Booking: Terms & Conditions:
Booking Sessions
Sessions are by appointment only and require an initial assessment which can be booked be calling on 07599 209812, or via email admin@turnstonetherapypractice.co.uk.
An assessment session is 50 minutes in duration and consists of some administration where some personal details are taken/forms completed, as well and a shorter therapy session. Then if both parties agree that therapy should continue, a therapeutic contract is signed and further sessions are booked.
Sessions are to be paid for via BACS or cash in advance of the session starting and fees can be increased by Turnstone Therapy Practice Ltd. at any time. Clients will be given not less than 14 days notice of any price increase.
Session cancellation: 48 hours notice must be provided for cancellation or 100% payment will still be required.
If for any reason the therapist cancels your appointment they will do their best to find you’re an alternative appointment. If an alternative cannot be arranged, you will not be charged for the missed appointment
The client shall not transfer therapy treatments to any other person.
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Liability & Intellectual Property:
The information available on or through this Site, and the Services supplied via or in connection with this site or at Turnstone Therapy Practice Ltd. do not constitute medical advice and it is your responsibility to determine, through obtaining appropriate medical advice, that you are fit and well and that such contents and services are suitable for you. It is not my responsibility to do so. Before commencing any therapy, you may wish to consult your doctor. It is also vital that you supply me with correct information about yourself. I cannot be liable for any incorrect information supplied by you to myself. I will try to make sure that all information contained on this website (and provided by me to you as part of any therapy) is correct, but, subject to the paragraph below, I do not accept any liability for any error or omission and exclude all liability for any action you (your legal representatives, heirs) may take or loss or injury you may suffer (direct or indirect including loss of pay, profit, opportunity or time, pain and suffering, any indirect, consequential or special loss, however arising) as a result of relying on any information on this website or provided through any service supplied by myself to you. You, your legal representatives and your heirs release waive, discharge and covenant, not to sue Turnstone Therapy Practice Ltd. for any injury or death caused by their negligence or other acts.
Warranties & Liability disclaimer
I, Melanie Roberts as Director of Turnstone Therapy Practice Ltd. is a Registered Member of the British Association of Counsellors and Psychotherapists (BACP), which has a strict ethical codes and professional standards to which I subscribe. I hold an Enhanced Disclosure and Barring (DBS) Certificate. I am registered with the Information Commissioner (ICO) and hold full Liability Insurance.
Whilst every care has been taken to ensure the information on this website is both accurate and up to date, I do not accept any liability to any party for loss, or damage incurred by reliance placed on the information contained in this website or through omission or errors how so ever caused.
Intellectual property
The content of this website is copyright of Turnstone Therapy Practice Ltd. The content is only for your own personal use. You must not use the content for reproduction on any other website, or in any way for commercial purpose of gain unless you first obtain our written consent. The term “content” includes all text, images and graphics (other than certain images licensed from third parties) which appear on the website, and the design and layout of the website. Certain images and company logos at this website are the copyright or trademark of third parties and any use is subject to the terms and conditions of such third parties.
Law and jurisdiction
Your use of this website, these terms and any matters arising are subject to the laws of England. Any dispute is subject to the exclusive jurisdiction of the Courts of England.
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Use of cookies on this website:
This website uses cookies. A cookie is a small file of letters and numbers that I put on your computer if you agree. These cookies allow me to distinguish you from other users of the website which helps me to provide you with a good experience when you browse my website and also allows me to improve my site.
The cookies I use are ‘analytical’ cookies. They allow me to recognise and count the number of visitors and to see how visitors move around the site when they’re using it. This helps me to improve the way my website works, for example by making sure users are finding what they need easily.
For each visitor to my web pages, my web server automatically recognises only the client’s domain name. This information can be used to locate some geographical information, for example your nearest town. In some cases, it may identify your ‘network name’ (if for example you are accessing our website from an organisation with its own network). It does not give me any personal information relating to you as an individual (such as your name, address or email address). This information is used for internal review to improve the content of my web pages and its relevance to my potential clients.
By using my website you are consenting to my usage of the cookies described above. If you do not wish to consent, you can change your browser settings to disallow cookies on this and/or other websites. For instructions for how to disable cookies please refer to instructions from your browser provider.
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Your use of the website:
These terms and conditions of use apply to all users of this website. If you do not accept these terms and conditions of use, then you should immediately stop using this website. Your use of this website constitutes your consent to these terms and conditions of use.
We cannot guarantee that you will always be able to access the website; I will not be liable to you for any interruption or delay that you experience in accessing the website, whatever the cause. I cannot guarantee that the website or the server that makes it available are free of viruses or bugs. All comments regarding the website should be sent to the email address above.
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Recording client details: how your information is used for NHS Test & Trace
To support NHS Test and Trace (which is part of the Department for Health and Social Care) in England, we have been mandated by law to collect and keep a limited record of staff, customers and visitors who come onto our premises for the purpose of contact tracing.
By maintaining records of staff, customers and visitors, and sharing these with NHS Test and Trace where requested, we can help to identify people who may have been exposed to the coronavirus.
As a customer/visitor of Turnstone Therapy Practice Ltd. you will be asked to provide some basic information and contact details. The following information will be collected:
• the names of all customers or visitors, or if it is a group of people, the name of one member of the group
• a contact phone number for each customer or visitor, or for the lead member of a group of people
• date of visit and arrival time and departure time
The venue/establishment as the data controllers for the collection of your personal data, will be responsible for compliance with data protection legislation for the period of time it holds the information. When that information is requested by the NHS Test and Trace service, the service would at this point be responsible for compliance with data protection legislation for that period of time.
The NHS Test and Trace service as part of safeguarding your personal data, has in place technical, organisational and administrative security measures to protect your personal information that it receives from the venue/establishment, that it holds from loss, misuse, and unauthorised access, disclosure, alteration and destruction.
In addition, if you only interact with one member of staff during your visit, the name of the assigned staff member will be recorded alongside your information.
NHS Test and Trace have asked us to retain this information for 21 days from the date of your visit, to enable contact tracing to be carried out by NHS Test and Trace during that period. We will only share information with NHS Test and Trace if it is specifically requested by them.
For example, if another customer at the venue reported symptoms and subsequently tested positive, NHS Test and Trace can request the log of customer details for a particular time period (for example, this may be all customers who visited on a particular day or time-band, or over a 2-day period).
We may/will [delete as necessary] require you to pre-book appointments for visits or to complete a form on arrival.
Under government guidance, the information we collect may include information which we would not ordinarily collect from you and which we therefore collect only for the purpose of contact tracing. Information of this type will not be used for other purposes, and NHS Test and Trace will not disclose this information to any third party unless required to do so by law (for example, as a result of receiving a court order). In addition, where the information is only collected for the purpose of contact tracing, it will be destroyed by us 21 days after the date of your visit.
However, the government guidance may also cover information that we would usually collect and hold onto as part of our ordinary dealings with you (perhaps, for example, your name, date of birth and phone number). Where this is the case, this information only will continue to be held after 21 days and we will use it as we usually would, unless and until you tell us not to.
Your information will always be stored and used in compliance with the relevant data protection legislation.
The use of your information is covered by the General Data Protection Regulations Article 6 (1) (c) – a legal obligation to which we as a venue/establishment are subject to. The legal obligation to which we’re subject, means that we’re mandated by law, by a set of new regulations from the government, to co-operate with the NHS Test and Trace service, in order to help maintain a safe operating environment and to help fight any local outbreak of corona virus.
By law, you have a number of rights as a data subject, such as the right to be informed, the right to access information held about you and the right to rectification of any inaccurate data that we hold about you.
You have the right to request that we erase personal data about you that we hold (although this is not an absolute right).
You have the right to request that we restrict processing of personal data about you that we hold in certain circumstances.
You have the right to object to processing of personal data about you on grounds relating to your particular situation (also again this right is not absolute).
If you are unhappy or wish to complain about how your data is handled or the therapy service you have received, you should contact a member of staff in the first instance to resolve your issue. Your complaint should be sent via the contact details for Turnstone Therapy Practice Ltd. and will be handled with the upmost respect.
If you are still not satisfied, you can complain to the Information Commissioner’s Office regarding data issues. Their website address is www.ico.org.uk / or if your complaint is in relation to the therapy and you feel an appropriate response has not been provided, you may contact either the National Counselling Society at https://nationalcounsellingsociety.org/ or the BACP https://www.bacp.co.uk/
[This wording of this privacy notice is property of Turnstone Therapy Practice Ltd. and should not be copied without prior agreement]