Red Squirrel holds some information about you. This document outlines how that information is used, who we may share that information with and how we keep it secure. This notice does not provide exhaustive detail. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the email firstname.lastname@example.org . We keep our Privacy Notice under regular review. This Privacy Notice was last reviewed in July 2018.
1. What We Do
Red Squirrel provides occupational therapy services to clients affected by hoarding difficulties, to improve their health and wellbeing, through meaningful activity and occupational interventions. We focus on preventing risks associated with hoarding, the optimisation of physical and mental health. Through occupational therapy consultations and assessment, we aim to support those with hoarding difficulties to live a fulfilling life, to the best of their ability by examining the person holistically and working with them to identify occupational deficits. We will then seek to address these deficits through personalised interventions, support and advice.
2. How We Obtain Your Personal Data
2.1 Information provided by you
You provide us with personal data in the following ways:
By completing occupational therapy questionnaires
During a consultation or assessment
Through email, over the phone or by post
By providing details relating to payment
This may include the following information:
Basic details such as name, address and contact details
Details of contact we have had with you such as referrals, appointment requests
Health information including previous medical history, lifestyle, medicine details, clinic notes and occupational therapy plans
GP contact information, housing contact information, other agencies involved with your care.
We use this information in order to provide you with direct healthcare. This means that the legal basis of our holding your personal data is for legitimate interest.
Following completion of your healthcare we retain your personal data for the period defined by our professional association RCOT and registrant body, Health and Care Professions Council. This enables us to process any complaint you may make. In this case the legal basis of our holding your personal data is for contract administration.
2.2 Information We Get from Other Sources
With your permission, we may gain information from other persons or companies involved in your care. We use this information in order to provide you with direct healthcare. This means that the legal basis of our holding your personal data is for legitimate interest.
We may obtain sensitive information from other healthcare providers. The provision of this information is subject to you giving us your express consent. If we do not receive this consent, from you, we will not be able to coordinate your healthcare with that provided by other providers. The consequences of this means the healthcare provided by us may be less effective.
3. How We Use Your Personal Data
We act as a data controller for use of your personal data to provide direct healthcare. We also act as a controller and processor in regard to the processing of your data from third parties such as relatives, friends, other services and healthcare providers. We act as a data controller and processor in regard to the processing of bank transfer payments.
We undertake at all times to protect your personal data, including any health and contact details, in a manner which is consistent with our duty of professional confidence and the requirements of the General Data Protection Regulation (GDPR) concerning data protection. We will also take reasonable security measures to protect your personal data storage.
We may use your personal data where there is an overriding public interest in using the information, for example in order to safeguard an individual, or to prevent a serious crime. Also where there is a legal requirement such as a formal court order. We may use your data for marketing purposes such as testimonies but this would be subject to you giving us your express consent.
4. Do you share my information with other organisations?
We will keep information about you confidential. We will only disclose your information with third parties with your express consent with the exception of the following categories of third parties:
Our registrant body, the Health and Care Professionals Council, HCPC, for the processing of a complaint made by you
Any contractors and advisors that provide a service to us or act as our agents on the understanding that they keep the information confidential
Anyone to whom we may transfer our rights and duties under any agreement we have with you
Any legal or crime prevention agencies and/or to satisfy any regulatory request (for example, HCPC) if we have a duty to do so or if the law allows us to do so
We may share your information with other persons, such as the fire brigade, as part of providing you with direct healthcare. We will not include any sensitive information.
We will seek your express consent before sharing your information with your GP or other healthcare providers. However if we believe that your life is in danger then we may pass your information onto an appropriate authority (such as the police, social services in the case of a child or vulnerable adult, or GP in case of self-harm) using the legal basis of vital interests.
We may share your case history in an anonymised form with our peers for the purpose of professional development. This may be at clinical supervision meetings, conferences, online forums, and through publishing in medical journals, trade magazines or online professional sites. We will seek your explicit consent before processing your data in this way.
5. What Are Your Rights?
Every individual has the right to see, amend, delete or have a copy, of data held that can identify you, with some exceptions. You do not need to give a reason to see your data.
If you want to access your data, you must make a subject access request in writing to email@example.com . Under special circumstances, some information may be withheld. We shall respond within 20 working days from the point of receiving the request and all necessary information from you. Our response will include the details of the personal data we hold on you including:
Sources from which we acquired the information
The purposes of processing the information
Persons or entities with whom we are sharing the information
You have the right, subject to exemptions, to ask to:
Have your information deleted
Have your information corrected or updated where it is no longer accurate
Ask us to stop processing information about you where we are not required to do so by law or in accordance with the HCPC and RCOT guidelines.
Receive a copy of your personal data, which you have provided to us, in a structured, commonly used and machine readable format and have the right to transmit that data to another controller, without hindrance from us.
Object at any time to the processing of personal data concerning you
We do not carry out any automated processing, which may lead to automated decision based on your personal data.
If you would like to invoke any of the above rights then please write to the Data Controller at 34 Keydell Avenue, Horndean, Hampshire, PO8 9TD or email firstname.lastname@example.org .
6. What safeguards are in place to ensure data that identifies me is secure?
We only use information that may identify you in accordance with GDPR. This requires us to process personal data only if there is a legitimate basis for doing so and that any processing must be fair and lawful.
Within the health sector, we also have to follow the common law duty of confidence, which means that where identifiable information about you has been given in confidence, it should be treated as confidential and only shared for the purpose of providing direct healthcare. We will protect your information, inform you of how your information will be used, and allow you to decide if and how your information can be shared.
We also ensure the information we hold is kept in secure locations, restrict access to information to authorised personnel only, protect personal and confidential information held on equipment such as laptops with encryption (which masks data so that unauthorised users cannot see or make sense of it). We ensure external data processors that support us are legally and contractually bound to operate and prove security arrangements are in place where data that could or does identify a person are processed.
Red Squirrel is registered with the Information Commissioner’s Office (ICO) as a data controller and collects data for a variety of purposes. A copy of the registration is available through the ICO website (search by business name).
7. How long do you hold confidential information for?
All records held by Red Squirrel will be kept for the duration specified by guidance from our professional association HCPC and RCOT.
8. Website Technical Details
We do use electronic forms on our website making use of an available ‘forms module’ which has a number of built-in features to help ensure privacy. We also aim to use secure forms where appropriate.
- Cookie name
This is used to store whether you have agreed to receive cookies, persistent for one year.
8.2 Google Analytics
These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.
Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org
To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout
If you have a complaint regarding the use of your personal data then please contact us by writing to the Data Controller at 34 Keydell Avenue, Horndean, Hampshire PO8 9TD or email email@example.com and we will do our best to help you.
If your complaint is not resolved to your satisfaction and you wish to make a formal complaint to the Information Commissioner’s Office (ICO), you can contact them on 01625 545745 or 0303 1231113.