Therapy Owls is committed to protecting personal data. This privacy policy (Policy) includes our privacy notice and it tells you about the use and fair processing of personal data when on our website or in any interaction with us.
Who’s responsible
Our Policy tells you how Therapy Owls collects and processes your personal data through your use of our website.
We may provide other information about how and why we are using your data; in our contract with you for example.
This Policy is issued on behalf of Therapy Owls and covers the expressions “Therapy Owls”, “we”, “us” or “our” used in it.
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us at info@therapyowls.co.uk
What Personal Information Do We Collect?
Under this Policy, personal information includes (without limitation) any information about an identifiable individual, other than the person’s business title or business contact information when used or disclosed for the purpose of business communications.
Personal information does not include anonymous or non-personal information.
We collect and maintain different types of personal information in respect of those individuals who seek to be, are, or were clients, therapists, employed or contracted by us, including the personal information contained in:
- Booking sessions
- Making requests for information and applications
- Medical documentation
- CVs
- references and notes
- photographs and video/audio
- contracts and related correspondence
- training/development documentation
- invoicing information
- documentation relating to health and welfare benefits.
In addition to the examples listed above, personal information also includes information such as name, home address, telephone and mobile telephone numbers, personal email address, date of birth, marital status, gender and any other information which is disclosed in the course of an application for and employment or contractual arrangements with Therapy Owls.
Where personal information that we collect about you is held by a third party, we will use all reasonable endeavours to obtain your permission before we seek out this information from such sources (such permission may be given directly by you, or implied from your actions).
From time to time, we may use the services of third parties and may also receive personal information collected by those third parties in the course of performing their services.
If so, we will take reasonable steps to ensure that such third parties have the right to disclose your personal information to us.
Where permitted or required by applicable law or regulatory requirements, we may collect information about you without your knowledge or consent. Otherwise, Therapy Owls ordinarily will collect personal information directly from you.
Collecting Personal Information
The personal information collected is used and disclosed for our business purposes. Such uses include:
- considering applications and verification
- evaluating contractors
- administering payments and invoicing
- establishing training/development/performance requirements
- gathering evidence for disciplinary action, or termination
- establishing emergency contact points
- complying with laws
- compiling databases
- such other purposes as are reasonably required by Therapy Owls.
Monitoring
The work output of Therapy Owls employees and contractors in whatever format belongs to us and work product and the tools used to generate it are always subject to review and monitoring by Therapy Owls.
In the course of conducting our business, we may monitor employee/contractor activities to ensure compliant use.
When using Therapy Owls resources employees/contractors should not have any expectation of privacy with respect to their use of such resources.
How Do We Use Your Personal Information?
We may use your personal information for the purposes described in this Policy, or for any additional purposes that we advise you of and where your consent is required by law we have obtained your consent in respect of the use or disclosure of your personal information.
We may use your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.
When Do We Disclose Your Personal Information?
We may share your personal information with other parties who require such information to assist us with managing or our employment/contract/client relationship with you.
Also, your personal information may be disclosed:
- as permitted or required by applicable laws
- as part of any regular reporting activities Therapy Owls is obligated to satisfy
- to protect property of Therapy Owls
- during emergency situations or where necessary to protect safety
- where the personal information is publicly available or
- with your consent.
Notification and Consent
Privacy, employment laws and contractual arrangements may not require Therapy Owls to obtain your consent for the collection, use or disclosure of personal information for the purpose of establishing, managing or terminating those arrangements.
To the extent that your consent is required, we will assume, unless you advise us otherwise, that you have consented to this. Use or disclosure of your personal information may, at any time, subject to legal or contractual restrictions and reasonable notice, be withdrawn.
All such requests for withdrawal or variation of consent should be in writing and addressed to the Directors and Marked “Important – Privacy Policy”.
How is Your Personal Information Protected?
Therapy Owls uses reasonable endeavours to maintain safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to protect your personal information from loss and unauthorised access, copying, use, modification or disclosure.
How Long is Your Personal Information Retained?
Except as otherwise permitted or required by law, Therapy Owls will retain personal information for as long as it believes is reasonably necessary to fulfil the purposes for which the personal information was collected.
We may, instead of destroying or erasing your personal information, make it anonymous such that it cannot be associated with or tracked back to you. In most cases your data will be deleted 7 years after any contractual arrangements have ceased.
If you have applied to work for or with Therapy Owls and have been unsuccessful we may retain your data. This will be deleted within 12 months.
Updating Your Personal Information
It is important that your personal information is accurate and current. If your personal information happens to change during the course of your employment, please keep us informed of such changes.
We may (acting reasonably) choose not agree with your request to change your personal information and may add alternative text instead.
Access to Your Personal Information
You can request the personal information we hold. For any request please contact the Directors in writing marked “Important – Privacy Request for Information”.
We reserve the right to ask for specific information from you to enable us to process your request and we may charge a reasonable fee for this.
There are situations where legal requirements allow or require us to refuse to provide some or all of the personal information that we hold about you.
In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.
If we cannot provide you with access to your personal information, we will use reasonable endeavours to inform you of the reasons why.
Other rights
Data protection laws provide certain other rights. These are not always absolute and must be considered in the context of the legislation. For example:
- rights to request the deletion or removal of personal data where there is no
- compelling reason for its continued processing
- rights to restrict processing
- rights to data portability
- rights to object to processing based on legitimate reasons
- rights related to automated decision making including profiling.
Any questions you may have regarding the processing of your personal data should be directed in writing to our principal place of business marked for the attention of: Chief Executive Officer – Therapy Owls.
Updated January 2023