PRIVACY & COOKIE POLICY
Introduction
Welcome to the The Self-Worth Psychologist’s privacy policy.
The Self-Worth Psychologist take the privacy rights of all its clients seriously and adopts a high standard of
compliance and confidentiality when dealing with your data. The Self-Worth Psychologist wants you to understand that this is a safe place for you to discuss your feelings and concerns and The Self-Worth Psychologist operates in a highly confidential environment. This privacy policy sets out the details of how data is collected and processed through the use of our website.
Important information and who we are:
Purpose of this privacy policy
This privacy policy aims to give you information on how The Self-Worth Psychologist collects and processes
your personal data through your use of this website, including any data you may provide through this website
when you purchase our services or any products or sign up to our newsletter.
This website is not intended for children, and we do not knowingly collect data relating to children via our website.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we
may provide on specific occasions when we are collecting or processing personal or sensitive data about you so
that you are fully aware of how and why we are using your data. This privacy policy supplements other notices
and privacy policies and is not intended to override them.
Controller
Jeanette Fegan is the data controller and is responsible for your personal data (referred to as “we”, “us” or “our”
in this privacy notice).
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this
privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal
rights, please contact the DPO using the details set out below.
Contact details
If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the
following ways:
Full name of legal entity: Jeanette Fegan
Email address: jeanette@theselfworthpsychologist.com
Postal address:
Telephone number: 07789 085410
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK
supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to
deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy policy and your duty to inform us of changes:
We keep our privacy policy under regular review. This version was last updated in December 2023.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your
personal data changes during your relationship with us.
Third-party links
This website may include links to third-party websites, plug-ins, and applications. Clicking on those links or
enabling those connections may allow third parties to collect or share data about you. We do not control these
third-party websites and are not responsible for their privacy statements. When you leave our website, we
encourage you to read the privacy policy of every website you visit.
The data we collect about you:
Personal data, or personal 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 (anonymous data). We may collect,
use, store and transfer different kinds of personal data about you which we have grouped
together as follows:
Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and
gender.
Contact Data includes billing address, delivery address, email address and telephone numbers
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of products and services
you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone
setting and location, browser plug-in types and versions, operating system and platform, and other technology
on the devices you use to access this website.
Profile Data includes your username and password, purchases or orders made by you, your interests,
preferences, feedback, and survey responses.
Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third
parties and your communication preferences.
We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
Sensitive Data includes information about your health, including information about your existing and previous medical conditions, medication details, psychiatric history, and any other relevant health information to enable us to carry out our services to you.
We require your explicit consent for processing sensitive data, so when you submit your details, we will send you a further communication asking for you to confirm your consent to this processing.
We do not collect any other Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you
fail to provide that data when requested, we may not be able to perform the contract we have or are trying to
enter with you (for example, to provide you with services or goods). In this case, we may have to cancel a
service or product you have with us, but we will notify you if this is the case at the time.
How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms before or
during an appointment, verbally during discussions at our practice, or by corresponding with us by post,
phone, email or otherwise. This includes personal data you provide when you:
apply for our services or any of our products.
create an account on our website.
subscribe to our service or publications.
request marketing to be sent to you.
enter a competition, promotion, or survey; or
give us feedback or contact us.
Automated technologies or interactions. As you interact with our website, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
Technical Data from the following parties:
analytics providers such as [Google] based outside the EU.
advertising networks such as Facebook based outside the EU; and search information providers such as
Google based outside the EU.
Contact, financial and transaction data from providers of technical, payment and delivery services such
as [Stripe or PayPal] based outside the EU.
Identity and contact data from publicly available sources such as Companies House and the Electoral
Register based inside the EU.
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract, we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your
consent when collecting sensitive data (such as health information) and before sending third party direct
marketing communications to you via email or text message. You have the right to withdraw consent to marketing
at any time by contacting us.
Purposes for which we will use your personal data:
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and
which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where
appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose
for which we are using your data. Please contact us if you need details about the specific legal ground we are
relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
| To register you as a new customer | (a) Identity (b) Contact | Performance of a contract with you |
| To provide our services and to process and deliver any orders including: (a) provide our services to you (b) Manage payments, fees and charges (c) Collect and recover money owed to us | (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications (f) Sensitive Data | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) (c) Explicit consent (in the case of Sensitive Data). |
| To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| To enable you to partake in a prize draw, competition or complete a survey | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical | (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical | Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | (a) Technical (b) Usage | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about goods or services that may be of interest to you | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications | Necessary for our legitimate interests (to develop our products/services and grow our business) |
Marketing
Our lawful ground of processing your personal data to send you marketing communications is either your consent
or our legitimate interests (namely to grow our business).
Under the Privacy and Electronic Communications Regulations, we may send you marketing communications
from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed
to receive marketing communications and in each case, you have not opted out of receiving such communications
since. Under these regulations, if you are a limited company, we may send you marketing emails without your
consent. However, you can still opt out of receiving marketing emails from us at any time.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may
want or need, or what may be of interest to you. This is how we decide which products, services and offers may
be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased
goods or services from us and you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing
purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by contacting us.
Cookies
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a
good experience when you browse our website and also allows us to improve our site.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer
if you agree. Cookies contain information that is transferred to your computer’s hard drive.
We use the following cookies:
Strictly necessary cookies. These are cookies that are required for the operation of our website. They include,
for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use
of e-billing services.
Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see
how visitors move around our website when they are using it. This helps us to improve the way our website
works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognise you when you return to our website. This enables us to
personalise our content for you, greet you by name and remember your preferences (for example, your choice
of language or region).
Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you
have followed. We will use this information to make our website and the advertising displayed on it more relevant
to your interests.
We do not share the information collected by the cookies with any third parties.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or
some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you
may not be able to access all or parts of our website.
Change of purpose
We will only use your personal data 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 you wish to
get an explanation as to how the processing for the new purpose is compatible with the original purpose please
contact us.
If we need to use your personal data 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 data without your knowledge or consent, in compliance with the
above rules, where this is required or permitted by law.
Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table ‘Purposes
for which we will use your personal data’ above.
Service providers, acting as processors who provide IT and system administration services.
Professional advisers, acting as processors or joint controllers, including healthcare professionals, lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators, and other authorities, acting as processors or joint controllers, based who require reporting of processing activities in certain circumstances.
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law.
We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
International transfers
We may transfer your data outside the United Kingdom and European Economic Area (EEA).
Many of our external third parties are based outside the United Kingdom and the EEA so their processing of your
personal data will involve a transfer of data outside the United Kingdom and the EEA.
Whenever we transfer your personal data out of the United Kingdom and the EEA, we ensure a similar degree
of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
1. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the United Kingdom
2. Where we use certain service providers, we may use specific contracts approved by the UK Information Commissioner’s Office and the European Commission which give personal data the same protection it has in Europe.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the United Kingdom and the EEA.
Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost,
used or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal
data to those employees, agents, contractors and other third parties who have a business need to know. They
will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any
applicable regulator of a breach where we are legally required to do so.
Data retention: how long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it
for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We
may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is
a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity
of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the
purposes for which we process your personal data and whether we can achieve those purposes through other
means, and the applicable legal, regulatory, tax, accounting, or other requirements.
By law we must keep medical information about patients for 7 years after treatment has finished. For any
children we treat we are obliged to retain the medical information until 7 years after the child’s 18th birthday. By
law we must keep basic information about our customers (including contact, identity, financial and
transaction data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you)
for research or statistical purposes, in which case we may use this information indefinitely without further notice
to you.
1. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You
have the right to:
2. Request access to your personal data (commonly known as a “data subject access request”). This enables you
to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
3. Request correction of the personal data that we hold about you. This enables you to have any incomplete or
inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you
provide to us.
4. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where
there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove
your personal data where you have successfully exercised your right to object to processing (see below), where
we may have processed your information unlawfully or where we are required to erase your personal data to
comply with local law. Note, however, that we may not always be able to comply with your request of erasure for
specific legal reasons which will be notified to you, if applicable, at the time of your request.
5. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third
party) and there is something about your particular situation which makes you want to object to processing on
this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object
where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate
that we have compelling legitimate grounds to process your information which override your rights and freedoms.
6. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
a. If you want us to establish the data’s accuracy.
b. Where our use of the data is unlawful, but you do not want us to erase it.
c. Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
d. You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
7. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
8. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we
may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could
refuse to comply with your request in these circumstances.
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 your personal data (or to exercise any of your other rights). This is a security measure to ensure that
personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you
for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month
if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.