Policies & Privacy

Cat Wright Solutions Policies

This policy sets out how we at Cat Wright Solutions otherwise known as Cat Wright Hypnotherapy use and protect information about you when you use our services and website, so that you can be confident that your privacy is protected.

It is our intention to ensure that any data you provide is managed respectfully, kept secure and only used for the purposes for which it has been provided.  This information includes personal information as defined in the General Data Protection and Retention (GDPR) 2018.

The policy will be updated from time to time in line with prevailing legislation.

For the purpose of this policy Cat Wright is the named Data Protection Officer/Controller and Head of Organisation.

When you contact us via the website, phone or email we will collect your:

• Name
• Email address
• Telephone number
• Other information you choose to supply regarding the purpose of your enquiry.

What we do with this information:

• We use this information in order to make contact with you to discuss your requirements.
• We may also use this information to improve our services.
• If you choose to go ahead with an appointment, we will send you a copy of a referral form, which asks for more information (see below) and explains once again how we use information provided in the course of our sessions together.

What information do we ask for in the referral?

• Your name, address and contact details so that we may contact you during the time we are working together.
• Your GP contact details and health information: there are some conditions that are contraindicated for hypnotherapy.
• Your next of kin: this is used only in exceptional, emergency situations.
• In the course of our sessions we will make a note of information you provide to us in order that we can plan future sessions and produce language patterns, which may be used in subsequent sessions.

Why do we need to collect your personal data?

We need to collect information about you so that we can:

• Know who you are so that we can communicate with you in a personal way. The legal basis for this is a legitimate interest.
• Deliver goods and services to you. The legal basis for this is the contract with you.
• Process your payments for the goods and services you choose to access. The legal basis for this is the contract with you.
• Contact you, or next of kin, in case there is a problem, either during the course of our Hypnotherapy Services, or after the work has been completed.

Where do we keep information?

• On our company computers - a personal computer, which is password-protected. One Drive Cloud services, which are password-protected. Passwords are not shared.
• A paper copy - during our sessions notes will be made and used to inform future sessions and content. These written records will be kept in a secure filing cabinet within a lockable room.
• In the event of my death, my therapeutic executor will contact existing clients and archive any client files in accordance with General Data Protection Regulations (GDPR) - see Data Breech section of the Information Governance Policies & Procedures (available on request from cat@catwrightsolutions.co.uk ).
• In the case of a data breach Cat Wright Solutions Hypnotherapy shall comply with the regulations set out under Article 33 of the GDPR.

How long do we keep the information?

• Our governing body states that we must keep records of clients notes for eight years following the final hypnotherapy session after this time information will be deleted/shredded.
• For children we are required to keep records until the client reaches the age of 25 years, after this time information with be deleted/shredded.
• Invoices and financial records are kept in line with HMRC requirements for two years, after this time it will be shredded/destroyed.
• Please also see the Retention Schedule section in the Information Governance Policies & Procedures (available on request from cat@catwrightsolutions.co.uk )

Who do we send information to/share information with?

• Supervision and quality assurance - if it is deemed necessary we may take aspects of your case to supervision in order to better understand how to support you (or your child in the case of the child accessing these services) and to explore aspects from different perspectives. Notes may be taken during the discussions between the hypnotherapist and supervisor. If these notes contain you or your child’s name, we will mark them as confidential and store them securely.
• Information will not be shared with other agencies without your knowledge, unless it is for health or legal reasons.

How can I see all the information you have about me?

You can make a subject access request (SAR) regarding information held about you or your child, should your child be accessing our services, by contacting cat@catwrightsolutions.co.uk . We may ask you to complete a form to provide us with additional information and verification that you are who you say you are in order that we can process the request.

What if my information is incorrect, or I wish to be removed from your system?

Please contact cat@catwrightsolutions.co.uk with regards to information we hold about you.  Should you wish to have your information corrected you must provide us with the correct data, once the information has been updated, we will send you a copy.

Any person may put a request for their personal data to be removed (the ‘right to be forgotten’ or the ‘right to erasure’).  In this instance hard copy data will be shredded and any electronic data will be permanently deleted.  The client will be notified of the completion.  The request for deletion of data and confirmation of completion will be held securely until eight years after the request was made.

Will we send emails and text messages to you?

As part of providing a high quality service to you, we may need to send emails or text messages to you regarding details of appointments or additional information.  These will not contain any personal information.  Cat Wright Solutions will not use your email information or phone number to distribute any marketing information.

Webcam sessions:

Sessions are normally carried out in the therapy room at Cat Wright Solutions, where sessions are conducted by Webcam (Skype or Face-time for example) the sessions are not recorded.  Notes will be taken contemporaneously as per sessions within the therapy room. 

Cookies and links to other websites:

Cookies are small files, which ask for permission to be placed on your computers hard drive so that we can analyse web traffic to our site.  Through this we can see which of our website pages are being viewed and are of interest.  Most web browsers automatically accept cookies but you can modify your settings to decline them if you prefer.  If you choose to do this you may find that you cannot make full use of our website.  Please be aware that links from our website are there for your assistance only.  Once you have used these links please be aware that you have left our website and we do not have any control over other websites. We cannot therefore be held responsible for the protection and privacy of any information you provide when visiting such sites and these sites are not governed by our privacy policy.  We advise therefore that you exercise caution and look at the privacy statement applicable to the website in question.   When an individual visits www.catwrightsolutions.co.uk I use Google analytics who are considered a third party service, to collect information about what visitors do when they visit my website (e.g. which page they visit most).  Google analytics only collect non-identifiable data which means I, or they, cannot identify who is visiting.  Cat Wright Solutions will always be transparent about collecting data and will be clear about how that data is processed.

If your questions are not fully answered by this policy, please contact Cat Wright Solutions at cat@catwrightsolutions.co.uk . If you are not satisfied with the answers from us, you can contact the Information Commissioner’s Office at https://ico.org.uk

ICO registration number: ZA 429920

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Information Governance Policies and Procedures

Introduction

Data held by Cat Wright Solutions will be held lawfully and for the retention periods set out within this document.

This document refers to:

• Written documents
• Spread sheets
• Hardcopy notes and files
• Database entries
• Images
• Recordings
• Emails
• Text messages
• Supervision notes
• Visits to the organisations website
• Social media communication.

Aim and purpose

The aim of this document is to ensure that Cat Wright Solutions has a framework that ensures the rights and freedom of individuals in relation to their personal data (Article 1) and adheres to the best practice in the management of client information and business records.

Information governance sets out the way in which information collated by an organisation is managed and ensures that any information collected:

• is the right information
• is in the right place
• is stored for the right amount of time
• is shared only with the right people
• is collected for the right reasons.

This is a working document and may be updated at any time in line with prevailing legislation and to reflect the growth of the business - and therefore should be revisited regularly to check for any updates. Cat Wright Solutions is fully committed to ensuring clients privacy and data protection rights.

For the purpose of this policy Cat Wright (Catherine Wright) is the named Data Protection Officer/Controller and Head of Organisation.

Information Governance Framework Principles for Cat Wright Solutions

1. Assessment needs for Information Governance (IG) Training have been identified and fully met with a GDPR training session provided by Clifton Practice Hypnotherapy Training School. This training need is updated accordingly.
2. Any changes to the business processes and/or operations will be planned and will comply with the framework to ensure any risks to personal and sensitive information are minimised.
3. Any data collected is solely for the purpose of providing a person-centred service to an individual client - be they seeking Hypnotherapy or Educational services (such as assessment for dyslexia or other additional learning need).
4. All technology (Microsoft Office Products including Outlook) used to store or facilitate information and communication is maintained according to the Data Retention Schedule for Cat Wright Solutions (see later).
5. All records are identifiable, locatable, retrievable and intelligible according to regulations set out by GDPR.
6. It is the responsibility of the data controller to ensure sufficient resources are in place to prioritise adhering to Data Protection Legislation in the business.
7. Any electronic devices where personal or sensitive, confidential information is held will be password protected. Individual documents stored electronically will also contain individual passwords.

Please also refer to Cat Wright Solutions Privacy Policy above for further information relating to information governance.