This Privacy Notice Provides you with:
- A detailed overview of how we manage your data – including how we collect, use and store your data, circumstances where your personal data may be shared, and how we comply with the law.
- Information about your rights regarding your personal data and how to exercise them.
What data we collect
The information we collect with vary depending on your level of engagement with and use of our services. Brighter Minds may collect the following data:
- Personal identification information, such as: name, contact details (address, phone number, email), date of birth.
- Financial information, such as credit card details used to pay us.
- Health information, such as mental and physical health history, GP details.
- Emergency contact details, including next of kin.
Sensitive Personal Data
Certain data is identified within Data Protection Law as more sensitive. This includes personal data about health, race, religion and political views. This data may be collected as part of the process for accessing cognitive behavioural therapy (CBT) where it is necessary to have an understanding of your current and historical mental and physical health in order to inform treatment. The confidentiality of your information is important to Brighter Minds. We ensure measures are in place to prevent unauthorised access to and use of sensitive personal data. In doing so, Brighter Minds complies with the EU General Data Protection Regulation (GDPR), the Data Protection Act and medical confidentiality guidelines issued by professional bodies including, but not limited to, the British Association of Behavioural and Cognitive Psychotherapists (BABCP) Standards of Conduct.
If you provide us with personal information about other individuals, you should inform the individual about the contents of this Privacy Notice.
How we collect information
The majority of the data that we collect is data that is provided directly by you. You may provide data directly to us when you:
- Register for services provided by Brighter Minds.
- Use the services you have registered for.
- Contact or interact with us through our website, by email or by social media.
- Correspond with us by letter, email, telephone or social media, including where you refer to Brighter Minds in a public post through social media or our website.
- Participate in our marketing activities.
- Complete a feedback form about our services online, via email or in person.
- Access our website or social media pages via your browser’s cookies.
- Share information during an appointment.
We may collect data from other sources including, but not limited to:
- GPs and other clinicians (including their receptionists and medical secretaries)
- Mental health care providers.
- Third parties who may have referred you to Brighter Minds, such as health insurance providers.
How we use your data
Brighter Minds will only use your data where there is a lawful basis for doing so. We will generally rely on the following legal justifications:
- Contract Purposes. When you book or subscribe to our services, you are entering a contract with us. In order for us to be able to fulfil this (for example, by sending you the newsletter you have subscribed to or arranging the CBT appointment or workshop you have booked), we need to process and store your data. When we process any orders or transactions, we may send data to and use subsequent data from credit reference agencies to prevent fraudulent activities.
- Legitimate Business Interests. We may collect your personal data for legitimate business interests. For example, to contact you regarding offers or services we think you might be interested in and where this causes you no harm.
- Where we have a legal or regulatory obligation to use your personal information.
Where we need to use your personal information to establish, exercise or defend our legal rights.
- With your explicit consent. For any situations not covered by the legal grounds above, where data is required, we will explicitly ask you for this information.
The data we collect is used for the following purposes:
- To send you communications which you have requested or may be of interest.
- To notify of changes to our services.
- To remind you of upcoming appointments or any changes relating to services you have booked.
- To help inform your treatment and decisions made about your care.
- To review the care we provide to ensure it is safe, effective and of the highest standard.
- For clinical supervision.
- To gain your feedback.
- To improve our services.
Confidentiality and Information Sharing
In accessing CBT with us, we are required to gain your explicit consent to process your sensitive personal data. It is a legal requirement to maintain clinical records of the therapy sessions that take place. These records are kept electronically and are password protected. Clinical appointments are confidential, however, in some instances, the therapist may have a legal duty to share information with other parties. Details around this are clearly outlined within the Therapeutic Working Agreement which needs to be signed prior to the attendance of an initial consultation. This is also routinely discussed at the start of every initial consultation.
How we store your data
If you are accessing CBT treatment, your clinical records are kept electronically using GDPR compliant software. Brighter Minds will store your data for a minimum of 7 years in line with GDPR requirements and the terms of our professional indemnity insurance arrangements. We will then securely delete this data.
Our aim is for our communications with you to be relevant and respectful. Under the Privacy and Electronic Communications Regulations, we may send you marketing information if you opted in for this. You can opt out of receiving marketing communications from us at any time by contacting us or clicking ‘unsubscribe’ at the bottom of any marketing emails.
Your Data Protection Rights
You have the right to:
- Access – You have the right to request access to the personal data held by Brighter Minds, with some exceptions.
- Rectification – You have the right to request that any inaccurate or incomplete information held about you is corrected or completed.
- Erasure – You have the right to request that Brighter Minds erases your personal data, under certain conditions.
- Restrict Processing – You have the right to request that Brighter Minds restricts the processing of your personal data, under certain conditions.
- Object to Processing – You have the right to object to Brighter Minds processing your personal data, under certain conditions.
- Data Portability – You have the right to request that Brighter Minds transfers your personal data to yourself or another organisation, under certain conditions.
Should you wish to exercise any of these rights, please contact us at firstname.lastname@example.org. We will need to verify your identity as a security measure to prevent your data being disclosed to anyone unauthorised to receive it. We will then respond to your request within one month.
Further information about these rights can be found on the ICO Website
Cookies are text files used to collect standard Internet Log information and visitor behaviour information. When you visit our website, we may collect information from you through cookies. We do this to help us understand how our website is used. Our website uses two main types of cookies:
- Functionality – these cookies help us recognise you on our website and remember any previously selected preferences. This may include language and location.
- Advertising – these cookies collect information about your visit to our website, such as the content you viewed and links you followed as well as information about your browser, device and IP address. We may sometimes share limited aspects of this data with third parties for advertising purposes which means that when you visit another website, you may be shown adverts based on the browsing patterns identified on our website.
You can set your browser to not accept cookies. Further information can be found at the ICO website. Please note that in some cases, stopping cookies can prevent full website functionality.
Privacy Policies of Other Websites
Should you require any further information about anything outlined in this policy you can contact us by emailing us at: email@example.com
Should you feel unhappy with the way Brighter Minds has collected or used your data, or if Brighter Minds have not been able to satisfactorily address any concerns you have contacted us about, you have the right to raise a complaint with the Information Commissioner’s Office (ICO) which is the UK supervisory authority for data protection issues. Their contact details can be found on their website: www.ico.org.uk. We would be grateful if you would contact us first if you do have a complaint so we can do our best to resolve it for you.