1. Introduction

The purpose of this Data Privacy Policy is to provide you with a clear explanation of when, why and how I collect, store and use your personal and health information, as well as an explanation of your statutory rights. You must read this policy carefully and make sure you fully understand it, before you access or use any of my services. When I use your personal information, I am regulated by the Information Commissioner and by the General Data Protection Regulations. . This privacy notice provides information about the personal information I process about you as a data controller, in compliance with the General Data Protection Regulation (GDPR). By using my services, you agree that we may treat your information in the ways we describe in this policy. If you do not agree with any term of this Privacy Policy, then you may not use my services.

My ICO registration number is: ZB590632

2. How to contact me: 

Please contact me at drlucyturnpenny@proton.me with any questions or requests about the personal information I process. 

3.  Your rights:

I am committed to protecting your rights to privacy. They include:

• Right to be informed about what I do with your personal data
• Right to have a copy of all the personal information I process about you
• Right to rectification of any inaccurate data I process, and to add to the information I hold about you if it is incomplete
• Right to be forgotten and your personal data destroyed
• Right to restrict the processing of your personal data
• Right to object to the processing I carry out based on my legitimate interest

4. Information I collect

• I may collect and securely store the following types of personal data:
• First name or given name
• Family name or surname
• Address
• Telephone numbers
• Date of birth
• Gender (or preferred identity).
• Age
• Date of Birth
• Relationships & children
• Occupation
• Telephone number
• Email address
• Health insurance details
• Correspondence and Communication History

I also process personal data pursuant to my legitimate interests such as:

• Invoices and receipts
• Accounts and tax returns

5. Information relating to Patients/Clients 

If you become a patient / client I record all your treatment and details of your appointment so that I can plan your treatment correctly. In addition to the personal information above, I may also collect and securely store information regarding:

• Medical conditions (if relevant)
• Prescribed medication.
• Psychological history and current difficulties.
• Sexuality
• Offenses (including alleged offenses)

I may collect some of this information from your insurance company if you have one, and some of this information will be collected directly from you.

6. Web access 

I collect information about you when you register with me online or place any order for services. I also collect information when you voluntarily complete contact forms. I always try to minimise the amount of personal information that I require in order to provide a specific service or feature.

This website may use Cookies. Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved. Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely. Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use. Requests by your web browser to our servers for web pages and other content on our website are recorded.

Information such as your geographical location, your Internet service provider and your IP address may be recorded. Information about the software you are using to browse our website, such as the type of computer or device and the screen resolution may also be recorded.

I may use cookies and information provided by your web browser to track how people use my website to help improve the way I provide content to users.

7. Sharing your personal information with third parties.

I do not share your personal information with third parties without your knowledge and consent other than as stated in this Privacy Policy. However, if my professional opinion was that there was an immediate and serious risk that you might harm yourself or someone else then I may  share your personal information with a third party such as your GP, social services, or the emergency services without first obtaining your consent. This might be because it is not practically possible to obtain your consent or because attempting to do so might lead to a delay in accessing help and therefore endanger your life or that of another. 

If I become aware of your intent to cause harm to another person/organisation (e.g. terrorism), the law may require that I inform an authority without seeking your permission. In such a situation, the law may require that I share your personal information without your knowledge.

In situations where I share your personal information with third parties to protect you or another, I will only share your personal information insofar as it is relevant and necessary to protect you or someone else. I will inform you what personal information I shared and with whom.

It is possible that your personal information may be requested by a Court of Law, Coroners Office or Professional Body, in which circumstances you may have limited or no rights of refusal. I do not share your personal information with third parties for marketing purposes. 

8. Accessing information I hold about you. 

Individuals can find out if I hold any personal information by making a ‘subject access request’ or ‘Right of Access’ under the Data Protection Act and the General Data Protection Regulation. I will then supply to you:

• A description of all data I hold about you
• Information about how it was obtained (if not supplied by you)
• Information about why, and for what purposes, I am holding it
• What categories of personal data is concerned
• Information around who it could be disclosed to
• Information on the retention periods of the data
• A copy of the information in an intelligible electronic form unless otherwise requested.

To make a request to me for any personal information I may hold you need to put the request in writing by emailing: drlucyturnpenny@proton.me. I will endeavor to share this with you within 30 days of receiving a request.

9. Storage of your personal information.

I keep your personal information in electronic records.   This information is stored on computer devices using encryption and password protected systems. Minimal personal information is kept in phone and email communication. Personal data is retained, where necessary, in compliance with my professional indemnity and professional / legal regulations and then securely deleted. For clients under the age of 18, personal data is retained until their 26th birthday or seven years after our last contact, whichever is the later.

10. Changes to my privacy policy.

I keep my privacy policy under regular review and this privacy policy was last updated on 1st December 2023. 

 11. Complaints or queries

I try to meet the highest standards when collecting and using personal information. For this reason, I take any complaints I receive about this very seriously. I encourage people to bring it to my attention if they think that my collection or use of information is unfair, misleading or inappropriate. I would also welcome any suggestions for improving my procedures. You can contact me via email: drlucyturnpenny@proton.me. If you are not satisfied with the response from me or believe I am not processing your personal data in accordance with the law you have the right to raise your complaint with the Information Commissioner’s Office (ICO).

Contact information ICO:

Website: https://ico.org.uk/concerns/

Email: casework@ico.org.uk

Telephone: +44 (0) 303 123 1113