Who we are and how we process your personal data
Motivation Highland complies with its obligations under the General Data Protection Regulation (GDPR) by keeping personal data up to date; by storing (and destroying it) securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.
We use your personal data for the following purposes:
· To deliver the services that clients have requested;
· To contact those clients as necessary in accordance with the services they have requested;
· To contact clients via surveys to ascertain their opinions on the service they received from us;
· To maintain our own accounts and records.
N.B. In the event that our recorded data is utilised for research purposes, our own supervision or for the instruction or tuition of students, all such data will be sufficiently anonymised to the extent that individual clients cannot be identified. Should a client indicate that their data should not be used for these purposes, we would refrain from using that data.
Individual client data will never be passed to a third party without the express consent of the respective client, always provided that such confidentiality is neither inconsistent with the therapist’s own safety or that of the client, the client’s family members or other members of the public, nor in contravention of any legal action or legal requirement.
In accordance with Motivation Highland’s need to maintain the possibility of access to client data as a result of returning clients or those who may wish to lodge a complaint in respect of our professional services to either our professional body or our insurers (i.e. in all cases perhaps after a long period of time has elapsed), Motivation Highland will retain client data for a minimum period of 7 years. For clients under the age of 18, data will be retained until their 25th birthday.
Our Lawful Basis for processing client personal data
The client has given clear consent for Motivation Highland to process their personal data for a specific purpose. Further, the processing is necessary for both the client’s and Motivation Highlands’s own legitimate interests.
Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
· The right to request a copy of your personal data which Motivation Highland (Data Controller) holds about you;
· The right to request that Motivation Highland (Data Controller) corrects any personal data if it is found to be inaccurate or out of date;
· The right to request your personal data is erased where it is no longer necessary for Motivation Highland (Data Controller) to retain such data;
· The right to withdraw your consent to the processing at any time;
· The right to request that the data controller provide the data subject with his/her personal data and where possible and applicable, to transmit that data directly to another data controller (known as the right to data portability). [N.B. This only applies where the processing is based on consent or is necessary for the performance of a contract with the data subject and in either case the data controller processes the data by automated means].
· The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
· The right to object to the processing of personal data, (where applicable) [N.B. This only applies where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics]
· The right to lodge a complaint with the Information Commissioners Office. (See below).
The client has the right to complain to the Independent Commissioner’s Office (ICO) if they think there is a problem with the way we are handling their data (see https://ico.org.uk/concerns/handling/).