Who I am

I am Rhona Brown, a clinical psychologist and cognitive analytic therapy practitioner, working in the NHS and independently. I am registered with the HCPC (Health & Care Professions Council – Registrant PYL03027). I am a member of the BPS (British Psychological Society) and an accredited CAT practitioner with ACAT (Association for Cognitive Analytic Therapy).

What I do

I offer a range of services related to psychological therapy and cognitive analytic therapy. These include psychological assessment and therapy, clinical supervision, consultation and training. I also offer advice and services around promotion of psychological ideas through writing, editing, digital media including website design/content, and use of social media (eg blogging and microblogging).

My commitment

I am committed to protecting and respecting your privacy. I hold your personal data securely and comply with data protection legislation. I do not share your personal data with external organisations. This notice provides an overview of how I comply with data protection legislation and the basis on which any personal data I collect from you, or that you provide to me, will be processed.

Legal basis for processing your data

I may collect and process your personal information under the following legal bases:

Consent – eg because you have asked me to contact you or provide you with a service. You are able to remove your consent at any time. You can do this by contacting me at contact@manchestercat.co.uk

Contract – eg if I enter into a contract with you and use of your personal data is required in order to fulfil that contract. An example would be sending you information or materials by post to your home address as part of the work I had contracted to provide to you.

Legitimate Interests – eg in order to offer and conduct the service I provide to you, it is necessary to gather and use your data as part of this provision. An example would be contacting you in the course of psychological therapy or supervision, and keeping records about the content of our sessions.

Please also note that in the course of psychological therapy or clinical supervision I may gather and process more sensitive personal information about you which is necessary to the provision of these professional services. This is defined by the ICO as “special category data” and the legal basis for me holding this is set out under Article 9 (h) of GDPR regulations.

Vital Interests – eg there may be occasions, perhaps in an emergency or crisis situation, when safeguarding and other professional and ethical requirements mean that I need to use your personal data in order to prevent or minimise risk of harm or threat to life. An example would be if there was significant risk of you ending your life or harming another person, and I needed to inform your GP or others as a preventative measure.

How I obtain personal data

‘Personal data’ refers to identifiable information about you, like your name, email, address, telephone number, bank account details, payment information, support queries, website comments and so on. If you can’t be identified (for example, when information about you as been aggregated and anonymised) then this notice doesn’t apply.

I may collect personal information about you when you request a specific service and every time you email me your details. You may provide me with your personal details when you contact me for information about services I provide, or communicate with me otherwise.

How I use personal information

I use this information

• to contact you to respond to your queries (if you email me with a question, for example)
• to provide you with services
• to contact you in relation to such services (for example to give you notice of changes to appointments)
• to process payments
• to contact you to ask you for feedback or to respond to surveys
• to keep you informed about other activities and developments which may be of interest to you

Financial records

I am required by law to hold information on payments received for our financial records. This information may include:

• Your full name and other identifying details
• Your email address
• If you are a business, your business name and correspondence address
• The dates and amounts of payments and invoices, and
• Payment data that allows me to create financial records.

The information I hold and the way I use it varies, depending on the service you use. More specific information is given below:

Therapy clients and supervisees

Personal details for people contacting me for therapy or supervision are held securely for the purpose of providing these services, in compliance with data protection laws. Written or electronic records of therapy or supervision sessions are held separately from any of your identifying details.

Data retention and destruction

I will not keep information about you any longer than is necessary. The length of time I keep your data may be determined by statutory or regulatory requirements.

If therapy has been provided I retain this information for seven years for clinical governance purposes.

Supervision records will be held for three years.

I will delete or securely destroy all personal data when it is no longer required.

Your Rights

Subject Access

You have the right to see what personal data I hold about you. You also have the right to know where I got the data from, how and why I am processing your data, who it has been shared with, and how long I intend to keep it for.

Rectification

You have the right to ask me to investigate, and correct where appropriate, any personal data I hold about you that you believe is wrong.

Erasure

You have the right to ask me to erase personal data that I hold about you where I no longer have a lawful purpose to process the data, or where the data is being processed based on your consent which has now been withdrawn.

This right may be restricted by my need to comply with laws, regulations or other legitimate reasons that require me to retain data. However, I will tell you if this is the case.

Restriction of Processing

You have the right to ask me to restrict the processing of your personal data. Restricted processing means that I cannot make any changes to the data unless I have your consent. You can ask for restricted processing where:

• You believe the data I hold is inaccurate and I need time to properly investigate,
• I have unintentionally come into possession of your personal data that I should not hold but you do not want me to delete,
• Where I no longer need your personal data, but you want me to hold on to it for legal reasons, or
• Where you have objected to how I use your personal data, and this is being investigated.

Right to Object

Where you feel that I am processing your personal data in a way that is inappropriate, you have the right to object and so ask me to demonstrate legitimate grounds for doing so. This includes asking me not to communicate with you other than in ways you choose.

I hope you never need to make a complaint, but if you do not think I have not responded appropriately to your needs, you may raise your concern within three months with the Information Commissioner at www.ico.org.uk

Right to not be subject to Automated Decision-making or Profiling

I do not use automated processing or profiling and your data are never subject to these methods.

How to contact me

If you would like any further information, or you would like to exercise any of your data protection rights, please get in touch.

By post: PO Box 555, MANCHESTER, M16 6GD

By email: contact@manchestercat.co.uk (please note this email address is not monitored at all times and it may not be possible to respond to your communication immediately)

May 2021