Privacy & Cookie Policy

This Privacy Policy was published Tuesday 19th Sep 2023. At NurtureNeuro Ltd we are committed to protect and respect your privacy in compliance with EU- General Data Protection Regulation (GDPR). This privacy policy explains when and why we collect personal information, how we use it, the conditions under which we may disclose it to others and how we keep it secure. This privacy policy applies to the use of our services and to our sales, marketing and customer contract fulfilment activities. It also applies to individuals seeking a job at NurtureNeuro Ltd.

Who are we?

NurtureNeuro Ltd is a Medical Health Centre based in Brentwood, Essex.

We are registered with the Information Commissioners Office (ICO).

When do we collect personal data about you?

• When you are using our services.
• When you interact with us in person, through correspondence, by phone, by social media, or through our websites.
• When we collect personal information from other legitimate sources, such as third-party data aggregators, NurtureNeuro Ltd marketing partners, public sources or social networks. We only use this data if you have given your consent to them to share your personal data with others.
• We may collect personal data if it is considered to be of legitimate interest, and if this interest is not overridden by your privacy interests. Before data is collected we make sure an assessment is made, ensuring that there is an established mutual interest between you and NurtureNeuro Ltd.

Why do we collect and use personal data?

We collect and use personal data for purpose of administering its business needs, relevant in enabling us to provide healthcare services to clients. Including performing direct sales, direct marketing and customer service. We may use your information for the following purposes:

• Send you marketing communications which you have requested. These may include information about our products and services, events, and activities. This communication is subscription based and requires your consent.
• Send you information about the products and services that you have purchased from us.
• Perform direct sales activities in cases where legitimate and mutual interest is established.
• Provide you content and venue details on a webinar or event you signed up for.
• Reply to a ‘Contact Us’ or other web forms you have completed on the NurtureNeuro Ltd website (e.g. to download a document/PDF).
• Follow up on incoming requests (customer support, emails, chats, or phone calls).
• Provide you with access and services related to NurtureNeuro Ltd.
• Perform contractual obligations such as order confirmation, license details, invoice, reminders, and similar. The contract may be with NurtureNeuro Ltd directly.
• Notify you about any disruptions to our services.
• Contact you to conduct surveys about your opinion on NurtureNeuro Ltd products and services.
• Accounting purposes, such as invoicing for a service.
• Service monitoring, development, and review.

Our legal basis for collecting personal data

We record and share information about clients in line with the six principles of the General Data Protection Regulations.

The six principles state that personal data must be:

1. Processed fairly, lawfully and in a transparent manner in relation to the data subject.
2. Collected for specified, explicit and legitimate purposes and not further processed for other purposes incompatible with those purposes.
3. Adequate, relevant, and limited to what is necessary in relation to the purposes for which data is processed.
4. Accurate and where necessary, kept up to date.
5. Kept in a form that permits identification of data subjects for no longer than is necessary for the purposes for which the data is processed.
6. Processed in a way that ensures appropriate security of the persona data including protection against accidental loss, destruction, or damage, using appropriate technical or organisational measures.

Collecting personal data based on consents

The collection of personal data based on consent from the data subject will be done by using “Consent Forms” that will store documentation related to the consent given by the individual. Individual consents will always be stored and documented in our systems.

Collecting personal data based on contracts

We use personal information for fulfilling our obligations related to contracts and agreements with customers, partners and suppliers.

Collecting personal data based on legitimate interest

We may use personal data if it is considered to be of legitimate interest, and if the privacy interests of the data subjects do not override this interest. Normally, to establish the legal basis for data collection, an assessment has been made during which a mutual interest between NurtureNeuro Ltd and the individual person has been identified. This legal basis is primarily related to our sales and marketing purposes. We will always inform individuals about their privacy rights and the purpose for collecting personal data.

What type of personal data is collected?

We collect name, phone number, title and email address, in addition to your company’s name and contact information. We may also collect feedback, comments and questions received from you in service-related communication and activities, such as meetings, phone calls, documents, and emails. From our websites we may collect IP-address and actions taken on the site. If you apply for a job at NurtureNeuro Ltd, we collect the data you provide during the application process.

Where is your data stored?

Personal data that we collect from you via any contact forms placed through our website will either be sent securely to our email addresses or will be stored on our servers.

By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

As the transmission of information via the internet is not completely secure, we cannot guarantee the security of your data transmitted to our site and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Health records you send to us through completing data on google forms, is stored securely on google business workplace servers. Google state they properly secure their data and respect the privacy of the information they place in their systems. Google state that they have spent years developing one of the world’s most advanced and secure infrastructures.

Your data is also held on password protected staff laptops, and backed up on an external hard drive, which is stored securely.

Who has access to your data?

The clinical psychologist has primary use of your data. In some circumstances administrative staff and practice management staff handle your data, such as receiving and storing data. Where possible these staff are not permitted to read personal health record data.

How long do we keep your personal data?

We comply with legal requirements under applicable laws.

We shall retain your data only for as long as necessary in accordance with applicable laws. HCPC states that independent psychologists keep records relating to contact with adults for 7 years and follow NHS guidance in relation to children. Retention and destruction of health records, both paper and electronic, is covered in the NHS code of practice for records management. Retention is until age 26 for people seen as children, and 20 years after the last contact for adults. After this, we shall securely delete your data.

We may process data for statistical purposes, but in such cases, data will be anonymised.

Your rights to your personal data

You have the following rights with respect to your personal data:

• The right to request a copy of your personal data that NurtureNeuro Ltd holds about you.
• The right to request that NurtureNeuro Ltd corrects your personal data if inaccurate or out of date.
• The right to request that your personal data is deleted when it is no longer necessary for NurtureNeuro Ltd to retain such data.
• The right to withdraw any consent to personal data processing at any time. For example, your consent to receive e-marketing communications:
  • If you want to withdraw your consent to e-marketing, please make use of the link to manage your subscriptions included in our communication. Please note that you may still receive system messages and administrative communications from NurtureNeuro Ltd, such as order confirmations, system messages and notifications about your account activities.
• The right to request that NurtureNeuro Ltd provides you with your personal data and, if possible, to pass on this information directly (in a portable format) to another data controller when the processing is based on consent or contract.
• The right to request a restriction on further data processing, in case there is a dispute in relation to the accuracy or processing of your personal data.
• The right to object to the processing of personal data, in case data processing has been based on legitimate interest and/or direct marketing.

We will reply to any request as quickly as possible and within 40 days of receipt unless there is a justifiable reason for delay.

Any query about your Privacy Rights should be sent to info@nurtureneuro.co.uk

Do we share your data with anyone?

We recognise that you have a right to know that the information they share with us will be regarded as confidential, as well as to be informed about the circumstances when, and the reasons why, we are obliged to share information.

We do not share, sell, rent, or trade your information with any third parties without your consent, except from what is described below:

Third-party Service Providers working on our behalf:

If required by law: We will disclose your personal information if required by law or if we, as a company, reasonably believe that disclosure is necessary to protect our company’s rights and/or to comply with a judicial proceeding, court order or legal process. However, we will do what we can to ensure that your privacy rights continue to be protected.

Safeguarding

We are obliged to follow the common law duty of confidentiality.

We are obliged to share confidential information without authorisation from the person who provided it, or to whom it relates, if it is in the public interest. That is when:

• it is to prevent a crime from being committed or to intervene where one may have been, or to prevent harm to a child or adult; or
• not sharing it could be worse than the outcome of having shared it.

In relation to safeguarding concerns the three critical criteria are:

• Where there is evidence that the child or adult is suffering, or is at risk of suffering, significant harm.
• Where there is reasonable cause to believe that a child or adult may be suffering, or is at risk of suffering, significant harm.
• To prevent significant harm arising to children and young people or adults, including the prevention, detection, and prosecution of serious crime.

Changes to this Privacy Policy

NurtureNeuro Ltd reserves the right to amend this privacy policy at any time. The applicable version will always be found on our websites. We encourage you to check this privacy policy occasionally to ensure that you are happy with any changes. If we make changes that significantly alter our privacy practices, we will notify you by email or post a notice on our websites prior to the change taking effect.

Your right to complain with a supervisory authority

If you are unhappy with the way in which your personal data has been processed, you may contact info@nurtureneuro.co.uk

What happens if data is not shared according to our information and sharing policy and is in breach of the national guidelines and legislation?

In the event of a data breach, we shall ensure that we follow the guidelines as stated under the data protection guidelines and will report the breach to the Information Commissioner’s Office.

Use of Cookies

The use of cookies and beacons

We use cookies and web beacons (‘Website Navigational Information’) to collect information as you navigate the company’s websites. This may include Facebook, and Google Analytics. Website Navigational Information includes standard information from your web browser, such as browser type and browser language; your Internet Protocol (“IP”) address; and the actions you take on the company’s websites, such as the web pages viewed and the links clicked. This information is used to make websites work more efficiently, as well as to provide business and marketing information to the owners of the site, and to gather such personal data as browser type and operating system, referring page, path through site, domain of ISP, etc. for the purposes of understanding how visitors use a website. Cookies and similar technologies help us tailor our website to your personal needs, as well as to detect and prevent security threats and abuse. If used alone, cookies and web beacons do not personally identify you.

What is a Cookie?

A cookie is a small amount of data, which often includes a unique identifier that is sent to your computer or mobile phone (referred to here as a “device”) browser from a website’s computer and is stored on your device’s hard drive. Each website can send its own cookie to your browser if your browser’s preferences allow it, but (to protect your privacy) your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other websites. Many websites do this whenever a user visits their website in order to track online traffic flows.

How do we use Cookies?

Information supplied by cookies can help us to analyse the profile of our visitors and help us to provide you with a better user experience. For example, if on a previous visit you went to our blog pages, we might find this out from your cookie and highlight similar stories on your second and subsequent visits.

Third Party Cookies

Please note that during your visits to our website you may notice some cookies that are not related to directly to us. When you visit a page with content embedded from YouTube, or one which has a “Share” button, you may be presented with cookies from these websites. We have no control of these cookies and you should check the third party websites for more information about these.

Don’t want us to use cookies?

We will not use cookies to collect personally identifiable information about you. However, if you wish to restrict or block the cookies which are set by this site, or indeed any other website, you can do this through your browser settings. The Help function within your browser should tell you how. Alternatively, you may wish to visit www.aboutcookies.org which contains comprehensive information on how to do this on a wide variety of browsers. You will also find details on how to delete cookies from your computer as well as more general information about cookies. For information on how to do this on the browser of your mobile phone you will need to refer to your handset manual.

Links to other policies

Please see further information held in our other policies, listed below:

• Information Sharing policy.
• Confidentiality Policy

References

The British Psychological Society Practice Guidelines 2017

https://explore.bps.org.uk/content/report-guideline/bpsrep.2017.inf115/chapter/bpsrep.2017.inf115.9#ch07lev1sec2

Accessed October 8th, 2023.