Dr Fiona Dowman t/a Purple Bridge Psychology’s Website Privacy Policy

Introduction

Welcome to Dr Fiona Dowman t/a Purple Bridge Psychology’s privacy policy.

I take the privacy rights of all my clients seriously and adopts a high standard of compliance and confidentiality when dealing with your data. I want you to understand that this is a safe place for you to discuss your feelings and concerns and I operate in a highly confidential environment. This privacy policy sets out the details of how data is collected and processed through the use of my website.

Important information and who I am

Purpose of this privacy policy

This privacy policy aims to give you information on how I collect and process your personal data through your use of this website, including any data you may provide through this website when you purchase my services or any products or sign up to my newsletter or email mailing list. This includes when you when you fill out online forms through my practice management system, Write Upp.

This website is not intended for children and I do not knowingly collect data relating to children via my website.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy I may provide on specific occasions when I am collecting or processing personal or sensitive data about you so that you are fully aware of how and why I am using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller
I, Dr Fiona Dowman am the data controller and I am responsible for your personal data.
I am responsible for overseeing questions in relation to this privacy policy.

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). I would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact me in the first instance.

Changes to the privacy policy and your duty to inform me of changes
I keep my privacy policy under regular review. This version was last updated in May 2024.
It is important that the personal data I hold about you is accurate and current. Please keep me informed if your personal data changes during your relationship with me.

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. I do not control these third-party websites and I am not responsible for their privacy statements. When you leave my website, I encourage you to read the privacy policy of every website you visit.

2. The data I 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).

I may collect, use, store and transfer different kinds of personal data about you which I 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 me.
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 my website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from me and our third parties and your communication preferences.

I 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, I may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if I combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, I 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 me to carry out my services to you. I require your explicit consent for processing sensitive data, so when you submit your details, I will send you a further communication asking for you to confirm your consent to this processing.

In the course of therapy, I may collect 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 I collect any information about criminal convictions and offences.

If you fail to provide personal data
Where I need to collect personal data by law, or under the terms of a contract I have with you, and you fail to provide that data when requested, I may not be able to perform the contract I have or am trying to enter into with you (for example, to provide you with services or goods). In this case, I may have to cancel a service or product you have with me but I will notify you if this is the case at the time.

How is your personal data collected?

I use different methods to collect data from and about you including through:

Direct interactions. You may give me your Identity, Contact and Financial Data by filling in forms before or during an appointment, verbally during discussions at my practice, or by corresponding with me by post, phone, email or otherwise. This includes personal data you provide when you:

apply for my services or any of my products;
create an account on my website;
subscribe to my service or publications;
request marketing to be sent to you;
enter a competition, promotion or survey; or
give me feedback or contact me.

Automated technologies or interactions. As you interact with my website, I will automatically collect Technical Data about your equipment, browsing actions and patterns. I collect this personal data by using cookies and other similar technologies. I may also receive Technical Data about you if you visit other websites employing my cookies. Please see my cookie policy for further details.
Third parties or publicly available sources. I 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 I use your personal data

I will only use your personal data when the law allows me to. Most commonly, I will use your personal data in the following circumstances:

Where I need to perform the contract I am about to enter into or have entered into with you.
Where it is necessary for my legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where I need to comply with a legal obligation.

Generally, I do not rely on consent as a legal basis for processing your personal data although I 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 me.

Purposes for which I will use your personal data
I have set out below, in a table format, a description of all the ways I plan to use your personal data, and which of the legal bases I rely on to do so. I have also identified what my legitimate interests are where appropriate.

Note that I may process your personal data for more than one lawful ground depending on the specific purpose for which I am using your data. Please contact me if you need details about the specific legal ground I am 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

(a) Identity

(b) Contact

(d) Transaction

(e) Marketing and Communications

(f) Sensitive Data

(a) Performance of a contract with you

(b) Necessary for my legitimate interests (to recover debts due to me)

To manage my 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

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for my legitimate interests (to keep our records updated and to study how customers use my products/services)

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity

(b) Contact

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for my legitimate interests (to study how customers use my products/services, to develop them and grow my business)

To administer and protect my business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(a) Necessary for my legitimate interests (for running my 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 I serve to you

(a) Identity

(b) Contact

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for my legitimate interests (to study how customers use my products/services, to develop them, to grow my business and to inform my marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for my legitimate interests (to define types of customers for my products and services, to keep my website updated and relevant, to develop my business and to inform my marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity

(b) Contact

(d) Usage

(e) Profile

(f) Marketing and Communications

Necessary for my legitimate interests (to develop my products/services and grow my business)

Marketing
My lawful ground of processing your personal data to send you marketing communications is either your consent or my legitimate interests (namely to grow my business).

Under the Privacy and Electronic Communications Regulations, I may send you marketing communications from me if (i) you made a purchase or asked for information from me about my 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, I may send you marketing emails without your consent. However you can still opt out of receiving marketing emails from me at any time.

Promotional offers from me
I may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what I think you may want or need, or what may be of interest to you. This is how I decide which products, services and offers may be relevant for you (I call this marketing).

You will receive marketing communications from me if you have requested information from me or purchased goods or services from me and you have not opted out of receiving that marketing.

Third-party marketing
I will get your express opt-in consent before I share your personal data with any third party for marketing purposes.

Opting out
You can ask me or third parties to stop sending you marketing messages at any time by contacting me.

Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Change of purpose
I will only use your personal data for the purposes for which I collected it, unless I reasonably consider that I 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 me.

If I need to use your personal data for an unrelated purpose, I will notify you and I will explain the legal basis which allows me to do so.

Please note that I 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

I may share your personal data with the parties set out below for the purposes set out in the table ‘Purposes for which I 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 party software which meets UK GDPR standards for data security. This includes accountancy software, practice management software and email management services.
Third parties to whom I may choose to sell, transfer or merge parts of my business or my assets. Alternatively, I may seek to acquire other businesses or merge with them. If a change happens to my business, then the new owners may use your personal data in the same way as set out in this privacy policy.

I require all third parties to respect the security of your personal data and to treat it in accordance with the law. I do not allow my 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 my instructions.

International transfers

I may transfer your data outside the United Kingdom and European Economic Area (EEA).

Many of my 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 I transfer your personal data out of the United Kingdom and the EEA, I ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

I 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
Where I use certain service providers, I 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 me if you want further information on the specific mechanism used by me when transferring your personal data out of the United Kingdom and the EEA.

Data security

I 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, I 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 my instructions and they are subject to a duty of confidentiality.

I 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 I am legally required to do so.

Data retention

How long will you use my personal data for?

I will only retain your personal data for as long as reasonably necessary to fulfil the purposes I collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. I may retain your personal data for a longer period in the event of a complaint or if I reasonably believe there is a prospect of litigation in respect to my relationship with you.

To determine the appropriate retention period for personal data, I 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 I process your personal data and whether I can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law I have to keep medical information about patients for 7 years after treatment has finished. By law I have to keep basic information about my 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 me to delete your data: see your legal rights below for further information. In some circumstances I will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case I may use this information indefinitely without further notice to you.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

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 I hold about you and to check that I am lawfully processing it.

Request correction of the personal data that I hold about you. This enables you to have any incomplete or inaccurate data I hold about you corrected, though I may need to verify the accuracy of the new data you provide to me.

Request erasure of your personal data. This enables you to ask me to delete or remove personal data where there is no good reason for me continuing to process it. You also have the right to ask me to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where I may have processed your information unlawfully or where I am required to erase your personal data to comply with local law. Note, however, that I 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.

Object to processing of your personal data where I am 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 I am processing your personal data for direct marketing purposes. In some cases, I may demonstrate that I have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask me to suspend the processing of your personal data in the following scenarios:

If you want me to establish the data's accuracy.
Where my use of the data is unlawful but you do not want me to erase it.
Where you need me to hold the data even if I no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to my use of your data but I need to verify whether I have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. I 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 me to use or where I used the information to perform a contract with you.

Withdraw consent at any time where I am 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, I may not be able to provide certain products or services to you. I 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 me.

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, I may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, I could refuse to comply with your request in these circumstances.

What I may need from you
I may need to request specific information from you to help me 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. I may also contact you to ask you for further information in relation to your request to speed up my response.

Time limit to respond
I try to respond to all legitimate requests within one month. Occasionally it could take me longer than a month if your request is particularly complex or you have made a number of requests. In this case, I will notify you and keep you updated.