Assembly (trading name of Family Emotional Health Limited) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after users’ and clients’ personal data and tell you about your privacy rights and how the law protects you.
Key points:
Why do we use your data? We use information about you for the purpose of providing you with our services. We use your sensitive data: As a user, we will use information about your health, racial and ethnic origin, sexual orientation and religion.
Sharing data: We may share your data with third parties, including other healthcare providers who may contribute to your care, your GP, statutory bodies concerned with the regulation of your care, and other agencies who may be involved in your care.
Security: We respect the security of your data and treat it in accordance with the law. International transfer: We work with international medical providers where we may transfer data with the patient’s express consent.
Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
IMPORTANT INFORMATION AND WHO WE ARE
1.1. Under the General Data Protection Regulation and Data Protection Act 2018, we are required to explain to our users why we collect information about you, how we intend to use that information and whether we will share this information with anyone else.
1.2. This statement applies to all our users and also prospective users.
1.3. We may update this statement at any time, and we will provide you with a new privacy statement when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
1.4. It is important that you read this statement so that you know how and why we use information about you. It is also important that you inform us of any changes to your personal information so that the information which we hold about you is accurate and up to date.
1.5. We are Assembly and Ayse Tanyeri is a “data controller” for the information which we hold about you. This means that we are responsible for deciding how we hold and use the personal information which we hold about you.
1.6. We have appointed a Data Protection Officer (“DPO”) who is responsible for overseeing what we do with your information and monitoring our compliance with data protection laws.
CONTACT DETAILS
1.7. Our full details are:
Full name of legal entity: Family Emotional Health Limited which is a company registered in England and Wales under the company number 14078663 and whose registered address is:
Euston House
24 Eversholt Street
NW1 1DB
ICO Registration number: ZB525887
DPO email address: ayse@getassembly.co.uk
Postal address: Family Emotional Health Limited, Euston House 24 Eversholt Street NW1 1DB
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
WHY ARE WE COLLECTING YOUR INFORMATION?
2.1. We ask for information about you so that we can make sure we provide you with the best care and service as our user.
2.2. Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to provide you with the service you require, but we will notify you if this is the case at the time.
TYPES OF PERSONAL INFORMATION WE USE
3.1. We are collecting information about you which is relevant to your usage. This includes:
3.1.1. personal details (such as name, date of birth, gender);
3.1.2. contact details (such as your address, personal telephone numbers and personal email address);
3.1.3. financial information (such as your bank account details and information about your financial circumstances);
3.2. SPECIAL CATEGORIES OF PERSONAL DATA
Some of the information which we collect about you may be “special categories of personal data”. Special categories of data require a greater level of protection. The special categories of personal data about you which we may collect include:
3.2.1. information about you or your child’s racial or ethnic origin;
3.2.2. information about you or your child’s religious beliefs;
3.2.3. information about you or your child’s sex life and sexual orientation;
3.2.4. healthcare information, including:
3.2.4.1. any disabilities or special requirements which you or your child may have;
3.2.4.2. medical records relating to you or your child;
3.2.4.3. you or your child’s medical history; and
3.2.4.4. records required by care regulators.
3 3.4. AGGREGATED DATA
We also collect, use and share anonymised and aggregated data (“Aggregated Data”) such as statistical or demographic data for our own internal and marketing purposes. Aggregated Data can be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
SOURCE OF YOUR PERSONAL INFORMATION
4.1. The above information which we collect about you will be obtained through a variety of sources which include:
4.1.1. from you directly both prior to and during product usage;
HOW AND WHY WE USE YOUR PERSONAL DATA
5.1. In accordance with the data protection laws, we need a “lawful basis” for collecting and using information about you for any particular purpose.
5.2. We have set out below the different purposes for which we collect and use your personal data, along with the lawful bases on which we will rely.
Why we use your information
Our lawful basis for using your information
Provision of services: To provide you with safe, appropriate and personalised service as one of our users and ensure that we meet your individual requirements.
It is necessary to perform our contract with you.
It is necessary to meet legal / regulatory obligations.
It is necessary for our legitimate interests (where they are not overridden by your rights).
It is necessary for the protection of your vital interests. It is necessary for us to provide you with healthcare.*
Finance: Administering payments for your treatment by us.
It is necessary for our legitimate interests (where they are not overridden by your rights).
It is necessary to perform our contract with you.
Admin: Administrative matters which are necessary for the day to day functioning of our organisation. This may occasionally include the prevention, detection and investigation of fraud and corruption.
It is necessary to perform our contract with you.
It is necessary to meet legal / regulatory obligations.
Why we use your information
Our lawful basis for using your information It is necessary for our legitimate interests (where they are not overridden by your rights). It is necessary for us to provide you with healthcare.* It is necessary to perform our contract with you.
Analysis and monitoring: Analysing the quality of product delivered to our users as part of our continuing service improvement. It is necessary for our legitimate interests (where they are not overridden by your rights). It is necessary to meet legal / regulatory obligations. It is necessary for us to provide you with healthcare.*
Research: We may process your personal data for academic research purposes under the following conditions:
Data Minimization: We will only collect and process the minimum amount of personal data necessary for academic research purposes. This means that we will not process any unnecessary personal information that is not required for the research.
Anonymization: Where possible, we will anonymize your personal data before processing it for academic research purposes. This means that your personal data will be stripped of any identifiable information, so that it cannot be linked back to you.
Security Measures: We will take appropriate technical and organizational measures to protect your personal data while it is being processed for academic research purposes. This includes the use of encryption and access controls to prevent unauthorized access to your personal data.
Research Ethics: We will ensure that any academic research carried out using your personal data is done so in accordance with the highest ethical standards. This includes obtaining any necessary ethical approvals and ensuring that the research is conducted in a manner that is respectful of your privacy and rights. By using our products and services, you acknowledge and consent to the processing of your personal data for academic research purposes in accordance with this privacy policy. If you have any questions or concerns about the processing of your personal data for academic research purposes, please contact us using the details provided in this privacy policy. | The processing of your personal data for academic research purposes will only be carried out where we have a lawful basis to do so. This may include your explicit consent, compliance with a legal obligation, or the pursuit of our legitimate interests.
Complaints: Handling any complaints made, concerns raised. It is necessary to perform our contract with you. It is necessary for our legitimate interests (where they are not overridden by your rights). It is necessary to meet legal / regulatory obligations. It is necessary for us to provide you with healthcare.* It is necessary to perform our contract with you.
Safeguarding and regulation: We use your personal data for the purpose of safeguarding and regulation of healthcare. It is necessary to meet legal / regulatory obligations. It is necessary for our legitimate interests (where they are not overridden by your rights). It is necessary for us to provide you with healthcare.*
Communication: We will need to use your personal information to communicate with you before, during and after your treatment. For example, when you telephone us, we may record those calls for monitoring and training purposes. It is necessary to perform our contract with you. It is necessary for our legitimate interests (where they are not overridden by your rights).
Marketing: We will use your personal information to notify you of details of our products and services which we think will be of benefit or interest to you. It is necessary for our legitimate interests (where they are not overridden by your rights).
Improving our services: We may ask you to voluntarily complete patient or client surveys to help us improve the services which we provide to you. We rely on your explicit consent for us to use your personal data.*
* This is an additional lawful basis which we need to rely on in order to use special categories of data such as information about your health
COMPLYING WITH DATA PROTECTION LAW
6.1. We will comply with data protection law when using your personal information. At the heart of data protection laws are the “data protection principles” which say that the personal information we hold about you must be:
6.1.1. used lawfully, fairly and in a transparent way;
6.1.2. collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
6.1.3. relevant to the purposes we have told you about and limited only to those purposes;
6.1.4. accurate and kept up to date;
6.1.5. kept only as long as necessary for the purposes we have told you about; and
6.1.6. kept securely.
SHARING YOUR PERSONAL INFORMATION
7.1. We will share your personal information with third parties where we have a lawful basis for doing so.
7.2. The types of organisations with whom we share your personal data are as follows:
7.2.1. Regulators / Safeguarding authorities / Commissioners: We also share your personal data with these public bodies where we are required to do so by law.
7.2.2. The Police and other law enforcement agencies: In limited circumstances we may be required to share your personal data with the police if required for the purposes of criminal investigations and law enforcement.
7.2.3. IT service providers: We may use external IT providers who may have access to your personal data from time to time as is necessary to perform their services.
7.2.4. Attorneys: Where it is lawful to do so, we may share your personal information with any individual who has authority to act on your behalf such as those granted power of attorney.
7.2.5. Next of kin: we may share your personal information with your next of kin (if we are aware of their contact details) in an emergency
7.3 In addition we may share your personal data with properly authorised employees within Assembly where it is necessary to meet our legal/regulatory obligations or is otherwise necessary for our legitimate interests including our clinical governance, audit or IT security requirements.
TRANSFERRING INFORMATION OUTSIDE THE UNITED KINGDOM AND THE EEA
8.1 Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
8.1.1. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
Please contact us at ayse@getassembly.co.uk If you want further information on the specific mechanism used by us when transferring your personal data out of THE UNITED KINGDOM AND THE EEA.
CAN WE USE YOUR INFORMATION FOR ANY OTHER PURPOSE?
9.1. We typically will only use your personal information for the purposes for which we collect it. It is possible that we will use your information for other purposes as long as those other purposes are compatible with those set out in this policy. If we intend to do so, we will provide you with information relating to that other purpose before using it for the new purpose.
9.2. We may also use your personal information for other purposes where such use is required or permitted by law.
STORING YOUR INFORMATION AND DELETING IT
10.1. We will only retain your personal information for as long as necessary to fulfil the purposes for which we have collected it or to fulfil another lawful purpose (as described above). When we no longer have a lawful purpose for holding your data, we will securely destroy your personal information in accordance with our data retention policy. Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us at ayse@getassembly.co.uk.
10.2. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
YOUR RIGHTS
11.1. Under certain circumstances, by law you have the right to:
11.1.1. Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
11.1.2. Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
11.1.3. Request erasure of your personal information in certain circumstances. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
11.1.4. Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) or public interest as our lawful basis for processing and there is something about your particular situation which leads you to object to processing on this ground. You also have the right to object if we are processing your personal information for direct marketing purposes.
11.1.5. Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
11.1.6. Request the transfer of your personal information to another party in certain circumstances.
11.2. If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact our Data Protection Officer in writing.
RIGHT TO WITHDRAW CONSENT
12.1. In the limited circumstances where we are relying on your consent as our lawful basis to process your data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact our Data Protection Officer. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
AUTOMATED DECISION MAKING
13.1. You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
RIGHT TO COMPLAIN TO THE ICO
14.1. You have the right to complain to the Information Commissioner’s Office (the “ICO”) if you are not satisfied with the way we use your information. You can contact the ICO by writing to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.