1. Information About Me
My Site is owned and operated by Lorna Devine, a sole trader registered in England.
Data Protection Officer: Lorna Devine.
Email address: lorna@lornadevine.com.
Telephone number: 07825415904.
I am a member of the British Association for Behavioural & Cognitive Psychotherapies (BABCP).
For my online CBT therapy practice, I adhere to the BABCP standards of conduct, performance and ethics. A copy of this code is available on request, or may be viewed on the BABCP website.
2. What Does This Policy Cover?
This Privacy Policy applies only to your use of My Site. My Site may contain links to other websites. Please note that I have no control over how your data is collected, stored, or used by other websites and I advise you to check the privacy policies of any such websites before providing any data to them.
3. What Is Personal Data?
Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’. Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
4. What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which I will always work to uphold:
The right to be informed about my collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact me to find out more or to ask any questions using the details in Part 10.
The right to access the personal data I hold about you. Part 9 will tell you how to do this.
The right to have your personal data rectified if any of your personal data held by me is inaccurate or incomplete. Please contact me using the details in Part 10 to find out more.
The right to be forgotten, i.e. the right to ask me to delete or otherwise dispose of any of your personal data that I hold. Please contact me using the details in Part 10 to find out more.
The right to restrict (i.e. prevent) the processing of your personal data.
The right to object to me using your personal data for a particular purpose or purposes.
The right to withdraw consent. This means that, if I am relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
The right to data portability. This means that, if you have provided personal data to me directly, I am using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask me for a copy of that personal data to re-use with another service or business in many cases.
Rights relating to automated decision-making and profiling. I do not use your personal data in this way.
For more information about my use of your personal data or exercising your rights as outlined above, please contact me using the details provided in Part 10.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data I hold about you changes, please keep me informed as long as I have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about my use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. I would welcome the opportunity to resolve your concerns myself, however, so please contact me first, using the details in Part 10.
5. What Personal Data Do You Collect and How?
Subject to the following, I do not collect any personal data from you. I do not place cookies on your computer or device, nor do I use any other means of data collection.
My Site collects certain information automatically, including your IP address, the type of browser you are using, and certain other non-personal data about your computer or device such as your operating system type or version, and display resolution.
If you send me an email, I may collect your name, your email address, and any other information which you choose to give me. For the purposes of the Data Protection Legislation, I am the data controller responsible for such personal data.
The lawful basis under the Data Protection Legislation that allows me to use such information is article 6(1)(f) of the UK GDPR which allows me to process personal data when it is necessary for the purposes of my legitimate interests, in this case, the proper operation and functionality of My Site. If you contact me as described above, you will be required to consent to my use of your personal data to contact you. In this case, my lawful basis for using your personal data will be article 6(1)(a) of the UK GDPR, which allows me to use your personal data with your consent for a particular purpose or purposes.
The data I would collect from you if you chose to provide it is as follows:
1. Personal details
2. Family details
3. Lifestyle and social circumstances
4. Financial details
5. Physical or mental health details
6. Racial or ethnic origin
I will collect information from you when:
1. You sign up to our newsletter or mailing list
2. You download an opt-in
3. You join a course or programme
4. You contact us for information via our website or social media channels, by phone or email
5. You post on our social media channels, website or blog
6. You work with us in a commercial capacity
7. You sign up at an event or workshop/group
I may use the information collected to:
1. Allow you to process a booking for a product or course
2. Send you our newsletters or provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes
3. Allow you to participate in the service you have chosen to do so
4. Notify you about changes to our service
6. How Do You Use My Personal Data?
Where I collect any personal data, it will be processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. I will comply with my obligations and safeguard your rights under the Data Protection Legislation at all times. For more details on security see Part 7, below.
As stated above, I do not generally collect any personal data directly from you, but if you contact me and I obtain your personal details from your email, I may use them to respond to your email. The other technical data referred to above is necessary for the technical operation of My Site and will not normally be used in any way to personally identify you.
Any and all emails containing your personal data will be deleted no later than 1 year after the subject matter of your query has been resolved and no other personal data will be retained for any longer than is necessary.
I will not share any of your personal data with any third parties for any purposes other than storage on an email and/or web hosting server.
7. Website Analytics and Target Marketing
I use website analytics to provide the best user experience and service to you and to evaluate and improve our site. We utilise a third party data analytics service provider, Google Analytics which works with Showit or other such software/website to improve our visibility and to monitor website browser behaviour and navigation across our site.
These third-party data analytics service providers collect this information on our behalf in accordance with our instructions and in line with their own privacy policies. Our service providers may collect the following data about the way you use our site, which will almost always be anonymised and aggregated before reporting back to us:
1. Number of visitors to our site
2. Pages visited whilst using the site and time spent per page
3. Page interaction information, such as scrolling, clicks and browsing methods
4. Source location and details about where users go when they leave the site
5. Page response times and any download errors
6. Other technical information relating to end user device, such as IP address or browser plug-in
From time to time, we may use the information collected about you to present you with targeted advertisements using platforms such as Facebook, Twitter, Google and/or Instagram.
8. How and Where Do You Store My Data?
I will store some of your personal data in the UK. This means that it will be fully protected under the Data Protection Legislation.
I may store some or all of your personal data in countries outside of the UK. These are known as “third countries”. We will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:
We ensure that your personal data is protected under binding corporate rules. Binding corporate rules are a set of common rules which all our group companies are required to follow when processing personal data. For further information, please refer to the Information Commissioner’s Office.
I will only store or transfer personal data in or to countries that are deemed to provide an adequate level of protection for personal data. For further information about adequacy decisions and adequacy regulations, please refer to the Information Commissioner’s Office.
9. Do You Share My Personal Data?
I will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.
I sell, transfer, or merge parts of my business or assets, your personal data may be transferred to a third party. Any new owner of my business may continue to use your personal data in the same way that I have used it, as specified in this Privacy Policy (i.e. to communicate with you).
In some limited circumstances, I may be legally required to share certain personal data, which might include yours, if I am involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
If any of your personal data is transferred to a third party, as described above, I will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, my obligations, and the third party’s obligations under the law, as described above in Part 7.
If any personal data is transferred outside of the UK, I will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 7.
If I sell, transfer, or merge parts of my business or assets, your personal data may be transferred to a third party. Any new owner of my business may continue to use your personal data in the same way(s) that I have used it, as specified in this Privacy Policy (i.e. to communicate with you).
In some limited circumstances, I may be legally required to share certain personal data, which might include yours, if I am involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
10. How Can I Access My Personal Data?
If you want to know what personal data I have about you, you can ask me for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email address shown in Part 10. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You can find it here: https://assets.publishing.service.gov.uk/media/5f76fab2d3bf7f7c2ad4b459/personal-data-sample-request-form.odt
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover my administrative costs in responding.
I will respond to your subject access request within one month and, in any case, not more than one month of receiving it. Normally, I aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date I receive your request. You will be kept fully informed of my progress.
11. How Do I Contact You?
To contact me about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Lorna Devine):
Data Protection Officer: Lorna Devine.
ICO Registration Reference: ZA755622.
Email address: lorna@lornadevine.com.
Telephone number: 07825 415 904.
12. Changes to this Privacy Policy
I may change this Privacy Policy from time to time. This may be necessary, for example, if the law changes, or if I change my business in a way that affects personal data protection.
Any changes will be immediately posted on My Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of My Site following the alterations. I recommend that you check this page regularly to keep up-to-date. This Privacy Policy was last updated on 26 August 2024.
