My Privacy Policy

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My contact details

My name is Jodi Brown, and I am a sole trader (trading as Side by Side) providing Cognitive Behavioural Therapy to individuals, both face-to-face and online. In this policy, I may also refer to myself as a psychotherapist, which is a generic term for someone who delivers psychological therapies.

I am registered with the Information Commissioner's Office (ICO) under the Data Protection Act 2018.

I appreciate that there’s a lot of information here, but it is important you are fully informed about your rights, and how your data is used. If you have any questions about the information in this policy, please do not hesitate to get in touch.

You can contact me via the following means:

Phone Number: 07796 716864
E-mail: jodi@sidebyside.training
Website: https://sidebyside.training

Why do I need a Privacy Policy?

This policy is designed to help you understand what kind of information I collect in connection with my services, and how I will process and use this information in line with the General Data Protection Regulations (GDPR) which came into effect on 25th May 2018. These regulations replace the existing Data Protection Act (DPA) and apply to organisations operating within the EU.

In the course of providing you with therapeutic services, I will collect and process information that is commonly known as personal data. This policy describes how I collect, use, share, retain, dispose of and safeguard personal data. This policy also sets out your individual rights.

You can download this Privacy Policy at the bottom of this page.

What type of personal information do I collect?

As a psychotherapist, I will handle the following categories of data:

Personal Data: your name, date of birth (DOB), gender, and any other personal information you choose to disclose when contacting me.

Financial Data: includes bank account and payment details and records.

Contact Data: that may include your billing address, email address and telephone numbers.

Technical Data: that may include your internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access my website.

Usage Data: that may include information about how you use my website.

Cookie Data: information gathered by the use of cookies in your web browser. 

Special category (sensitive) Data: in order to provide the very best service to you, I may be required to collect information from you which will be classified as sensitive. This data will only be collected if it is appropriate to your course of therapy and may include:

• Your and/or your family’s physical and mental health history (including history of alcohol consumption, drug use and any medication previously prescribed).
• Current physical and mental health symptoms including suicide risk, self-harm, alcohol and drug use, and any medication you are currently taking.
• Questionnaire scores (questionnaires that assess the severity of your symptoms).
• Relationship history and current status
• Religion
• Race or ethnic origin
• Sexuality and sexual preferences
• Personal data may also contain data relating to criminal convictions and offences (for the purposes of safeguarding and processing criminal conviction and offence data responsibly, this data is treated in the same manner as special categories of personal data, where I am legally required to comply with specific data processing requirements.)

Why I need your personal information

I will use your personal data for the performance of my contract with you (in other words, I need to keep accurate records to provide you with psychotherapy) and to share information with other agencies (ie. those who you have given me consent to talk to or those with whom I have a legal duty to share information). I also need to retain data to enable me to process any complaints.

The personal information I process is provided to me directly by you for one of the following reasons:

• To help inform decisions that I make about your treatment and care;
• To ensure that your treatment and care is safe and effective;
• To review care provided, to ensure it is of the highest standard possible;
• For clinical supervision;
• To send you communications which you have requested and that may be of interest;
• To notify you of changes to my services;
• To seek your views or comments on the services I provide;
• To book, or remind you of upcoming appointments.
• To improve my products and services.

There are 3 situations where I am obliged to share your information with third parties, without your consent:

• Court Order: if I am required to disclose data about you under a Court Order.
• Child / Vulnerable Adult Protection: if I am concerned about the welfare of a child or vulnerable adult, i.e., where there are child or adult protection issues.
• Risk to yourself or risk to others: where there is an imminent risk of harm to yourself or others, i.e., you have expressed an intent to kill yourself, or to kill someone else, imminently.

How I get your personal information

Over the phone: if you choose to make contact with me over the phone, I may collect information from you as a requirement for inviting you in for an assessment (see above “What type of personal information do I collect?”)?

Via email: when you enquire about my services by email, and I reply to you by email, I cannot guarantee that your email, or my reply is 100% secure. It is important that you understand that no data transmission over the Internet can be guaranteed to be 100% secure. If you wish to send me any documents via email and have any concerns about confidentiality and the data contained within your documents, I am happy for you to password protect your documents before sending them to me. You can either provide me with your password in a separate email, or phone me and provide me with your password over the phone.

Face to face: when you attend your CBT session, I collect and record data from you in order to get to know you, understand you, and better help you overcome your difficulties.

Completing forms: once we agree on a day/time for you to attend an assessment session, I will ask you to complete a Client Details form. This form will ask you to provide me with personal information, including your name, date of birth, address, contact details, GP and other health related information.

Via my website: as you interact with my website, it may automatically collect technical data about your equipment, browsing actions and patterns. I collect this personal data by using cookies, server logs and other similar technologies. For more information regarding how I use cookies and similar technologies in connection with your use of my platforms, please read my cookie policy.

If you choose to get in touch with me via my website contact form, no cookies are stored, and your information is not stored on my website. Your enquiry goes through to me via email. Whilst I store this information so that I’m able to respond to your query and get in touch, I would never sell or share this information. Should I ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement. 

From third-parties: I may receive information about you from third parties I work closely with, including other health professionals and your health insurance company. Third parties including analytics providers provide me with information that helps me ensure my website is user-friendly and provides my website visitors with the information they seek. The only third parties I may have reason to obtain information from (in relation to your treatment) are your insurance company and/or referring GP or psychiatrist.

Your insurance company may refer you directly to me, and if they do, they will often provide me with your personal information. If your GP or consultant psychiatrist refers you to me for CBT, they may also write a referral letter which may contain both personal and sensitive information. If you have any concerns about whether the above third parties are GDPR compliant, please contact them directly. I will never knowingly obtain data about you from any third party without your knowledge or consent.

How I store your personal information

Any personal data that I collect from you via any form of contact (e.g. email, phone, completed forms, notes) will be kept securely. This includes:

• Your pre-therapy questionnaire, your contact details, and brief session notes are stored on a computer and password protected.
• Any brief session notes are anonymised, using your initials only and are password protected.

Whenever I collect or process your personal data, I will only keep it for as long as is necessary for the purpose for which it was collected.

When deciding on the appropriate length of time to keep the data, I look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements. Client notes/records are kept for the length of time that is required for complying with my business insurance code of practice. For tax purposes the law requires me to keep basic information about my clients (including Contact, Identity, Financial and Transaction Data) for seven years after they stop being clients. At the end of that retention period, your data will either be deleted completely or anonymised.

Your Rights

You have the following rights in relation to your Data:

• Right to access – the right to request (i) copies of the information I hold about you at any time, or (ii) that I modify, update or delete such information. If I provide you with access to the information that I hold about you, I will not charge you for this, unless your request is “manifestly unfounded or excessive.” Where I am legally permitted to do so, I may refuse your request. If I refuse your request, I will tell you the reasons why.
• Right to correct – the right to have your Data rectified if it is inaccurate or incomplete.
• Right to erase – the right to request that I delete or remove your Data from my systems.
• Right to restrict my use of your Data – the right to “block” me from using your Data or limit the way in which I can use it.
• Right to data portability – the right to request that I move, copy or transfer your Data.
• Right to object – the right to object to my use of your Data including where I use it for my legitimate interests.
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You are not required to pay any charge for exercising your rights. If you make a request, I have one month to respond to you.

Please contact me at jodi@sidebyside.training if you wish to make a request.

How to complain

If you have any concerns about my use of your personal information, you can make a complaint to me directly at: jodi@sidebyside.training

You can also complain to the Information Commissioner’s Officer (ICO) if you are unhappy with how I have used your data.

The ICO’s address:           

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk