Privacy & Data Policy
At The Perry Clayman Project (PCP), we treat your data and security with the highest vigilance. Under the General Data Protection Regulations (GDPR), you have specific rights. This privacy notice tells you what to expect when PCP collects personal information. We are committed to processing your data securely and transparently. This notice applies to current and former clients.
Data Protection Principles
In relation to your personal data, we will comply with data protection law. This says that the personal information we hold about you must be:
- processed fairly, lawfully and in a clear, transparent way
- collected only for valid reasons that we find proper for the course of your time as a patient and not used in any way that is incompatible with those purposes
- only used in the way that we have told you about
- accurate and up to date
- kept only as long as is necessary for the purposes we outline
- process it in a way that ensures it will not be used for anything that you are not aware of or have consented to (as appropriate), lost or destroyed
- kept securely
Types of Information We Hold About You
Personal data or 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.
We hold many types of data about you, including:
- your personal details including your name, address, date of birth, email address, phone numbers
- banking or financial information
- marital status
- next of kin and their contact numbers
- personal medical, health or mental health information, including past medical history
- information concerning treatment at your first and any subsequent visits
- letters of referral to or from us regarding your therapy with us
Special Categories of Data
There are “special categories” of more sensitive personal data which require a higher level of protection, such as information about a person’s health or sexual orientation. These may include:
- mental health
- sex life
- sexual orientation
- ethnic origin
- information on your family or loved ones
We will use your special category data:
- to ensure the care you receive at the clinic is appropriate to your condition
- to determine reasonable adjustments that should be made for access to the clinic or to treatment
We must process special categories of data in accordance with more stringent guidelines. We will process special categories of data when the following applies:
- you have completed our pre-admissions form
- we must process the data in order to carry out our legal obligations
- we must process data for reasons of substantial public interest
Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.
As with all cases of seeking consent from you, you will have full control over your decision to give or withhold consent and there will be no consequences where consent is withheld. Consent, once given, may be withdrawn at any time. There will be no consequences where consent is withdrawn.
The Personal Data We Process and What We Do with It
When you supply your personal details to this clinic they are stored and processed for 4 reasons:
- We need to collect personal information about your health in order to provide you with the best possible treatment. Your request for treatment and our agreement to provide that care constitutes a contract. You can, of course, refuse to provide the information, but if you were to do that we would not be able to provide treatment.
- We have a legitimate interest in collecting that information because without it we couldn’t do our job effectively and safely.
- We also think that it is important that we can contact you in order to confirm your admission and treatment with us or to update you on matters related to your care. This again constitutes legitimate interest, but this time it is your legitimate interest.
- Provided we have your consent, we may occasionally send you general health & mental health information in the form of articles, advice or newsletters. You may withdraw this consent at any time – just let us know by any convenient method.
Change of Purpose
We will only use your personal information for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Retaining Your Personal Data
We have a legal obligation to retain your treatment records for 8 years from the date of your last visit to us but after this period we delete your treatment records.
The nature of addiction and addiction treatment means that once people contact us, they may enter treatment with us immediately, forthcomingly or not at all. If you contact us as a treatment enquiry but decide not to continue to treatment immediately or forthcomingly, we will retain your records for 18 months, after which time we delete your contact records. However, we will be happy to delete this at any point within this 18-month period at your request.
In some circumstances, we may anonymize your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
Data Security – Protecting Your Data
We have put in place measures to protect the security of your information against accidental loss or disclosure, alteration, unauthorised access, destruction or abuse. We have implemented processes to guard against such. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Our Data Security Policy is available on request. Please ask the data controller below for a copy.
Where we share your data with third parties, we provide written instructions to them to ensure that your data are held securely and in line with GDPR requirements. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.
Your records are stored:
- On paper, in filing cabinets, at our offices. The offices are always locked and alarmed when no one is in the building.
- Electronically, using a specialist client management system. This provider has given us their assurances that they are fully compliant with the General Data Protection Regulations. Access to this data is password protected, and the passwords are changed regularly.
- Electronically, using Apple iCould, Google Gmail and Google Cloud (Google Drive) and our 3rd party. These providers have given us their assurances that they are fully compliant with the General Data Protection Regulations. Access to all of this data is password protected, and the passwords are changed regularly.
- On our business computers. These are password-protected, backed up regularly and encrypted.
- On mobile devices. The nature of our business dictates we need access to records whilst travelling. We can access and retrieve your information using mobiles phones and tablet devices. These devices may hold your contact details and any job-specific data but not any financial data. They are password protected and backed-up securely.
Sharing Your Personal Data
We will never share your data with anyone who does not need access without your written or verbal consent.
Only the following people/agencies will have routine access to your data:
- Your practitioners in order that they can provide you with treatment.
- Insurance companies, when applicable, who are your co-data controllers.
We may share your data with third parties in order to facilitate a referral to another healthcare practitioner, rehab clinic, investigation or to keep your GP informed about your progress with treatment.
From time to time, we may have to employ consultants to perform tasks which might give them access to your personal data (but not your treatment notes). We will ensure that they are fully aware that they must treat that information as confidential, and we will ensure that they sign a non-disclosure agreement.
We may also share your data with third parties as part of a Clinic sale or restructure, or for other reasons to comply with a legal obligation upon us. We would always keep you informed of these situations.
Transferring Information Outside the EU
We do not share your data with bodies outside of the European Economic Area, unless on the condition below.
We may, at your consent, provide third-party treatment organisations outside the EU – specifically rehab clinics – in order to facilitate a referral to such a treatment provider. We insist that they treat your information and data in accordance with the strict guidelines set in the EU.
As we process your personal data, you have certain rights. These are a right of access, a right of rectification, a right to be informed, a right of erasure, a right to restrict processing.
- You may request a copy of your data at any time. Please make such a request in writing or by email to the Data Controller whose details are shown below. Please provide the following information: your name, address, telephone number, email address and details of the information you require.
- If you believe any of the personal data we hold on you is inaccurate or incomplete, please contact us directly and any necessary corrections to your data will be made without undue delay.
- The right to be informed. This means that we must tell you how we use your data, and this is the purpose of this privacy notice. We must also inform you of any changes to how we use your data.
- If you believe we should erase your data, please contact the Data Controller, whose details are shown below.
- If you wish us to stop storing, using, or restrict the processing of your data, please contact the Data Controller, whose details are shown below.
- Where you have provided explicit consent for us to use your data you have a right to withdraw this consent at any time.
We want you to be absolutely confident that we are treating your personal data responsibly, and that we are doing everything we can to make sure that the only people who can access that data have a genuine need to do so.
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 the information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Making a Complaint
If you have any questions about this Privacy Notice or how we handle your information please contact the Data Controller, whose details are shown below.
If you feel that we are mishandling your personal data in some way, you have the right to complain. Complaints need to be sent to the Data Controller. Here are the details you need for that:
Data Controller: The Perry Clayman Project (PCP)
Address: Head Office – PCP Luton, 17-21 Hastings Street, Luton, Bedfordshire, LU1 5BE
Telephone: 01582 730 113
If you are not satisfied with our response, then you have the right to raise the matter with the Information Commissioner’s Office (ICO) www.ico.org.uk
Should your personal data that we control be lost, stolen or otherwise breached, where this constitutes a high risk to your rights and freedoms, we will contact you without delay. We will give you the contact details of the person who is dealing with the breach, explain to you the nature of the breach and the steps we are taking to deal with it.
Automated Decision Making and Profiling
We do not use any system which uses automated decision making or profiling in respect of your personal data.
Contact Us Via Social Media
If you send us a private or direct message via social media the message will be stored in that media for three months. It will not be shared with any other organisations.
Visiting our Website
When you visit our website, we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make and do not allow Google to make, any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be upfront about this. We will make it clear when we collect personal information and will explain what we intend to do with it.
Third party links
Occasionally, at our discretion, we may include or offer third party products or services or links to other organisations on our website. These third party sites have separate and independent privacy policies. We, therefore, have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.
Terms and Conditions
Please also visit our terms and conditions of website use section establishing the use, disclaimers, and limitations of liability governing the use of our website at www.rehabtoday.com.
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