Important Privacy Policy

Western House Consulting Rooms Ltd understands that your personal data is entrusted to us and we fully appreciate the importance of protecting and respecting your privacy. To this end we comply with the data protection law in force in the UK (“Data Protection Laws”) and with all applicable clinical confidentiality guidelines including those published from time to time by our Medical and Professional organisations.

This Privacy Policy sets out the basis on which we collect and process personal data about you including our practices regarding the collection, use, storage and disclosure of personal data that we collect from you and/ or hold about you, and your rights in relation to that data.

Please read the following carefully to understand how we process your personal data. By providing your personal data to us or by using our services, website or other online or digital platform(s) you are accepting or consenting to the practices as described or referred to in this Privacy Policy.

For the purpose of Data Protection Laws, the data controller is Western House Consulting Rooms Ltd, with registered address at: Graham & Associates Ltd, Century Business Centre Manvers Way, Rotherham, South Yorkshire, S63 5DA, a Registered Company Number: 06745942 (England & Wales). ICO registration number ZA767945.

In this policy, “we”, “us” and “our” refer to Western House Consulting Rooms Ltd.
Credit: This policy was created using a template from SEQ legal.

1. HOW WE USE YOUR PERSONAL DATA

1.1. In this Section we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.

1.2. We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

1.3. We may process your account data (“account data”). The account data may include your name and email address. The source of the account data is you. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

1.4. We may process your information included in your personal profile (“profile data”). The profile data may include your name, address, telephone number, email address, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and providing our services. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

1.5. We may process your personal data that are provided in the course of the use of our services (“service data”). The service data may include; name, address, telephone number(s), email address, gender, date of birth, relationship status, insurance details, hobbies and interests, profession, payment details and employment details. The source of the service data is either you, medical referrer, solicitor, your employer or insurance provider. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

1.6. We may process your sensitive data that are provided in the course of the use of our services (“sensitive data”). The sensitive data may include; physical/Mental Health or condition, Injury type, treatment type and notes, race, ethnic origin, sexual life or orientation, religious belief or similar. The source of the sensitive data is either you, medical referrer, solicitor, your employer or insurance provider. The sensitive data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for collecting this data is either consent or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract. The legal basis for processing is either consent or for medical purposes and is undertaken by — (a) a health professional, or (b) a person who in the circumstances owes a duty of confidentiality which is equivalent to that which would arise if that person were a health professional. (2) In this paragraph, “medical purposes” includes the purposes of preventative medicine, medical diagnosis, medical research, the provision of care and treatment and the management of healthcare services.

1.7. We may process information that you post for publication on our website or through our services (“publication data”). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent.

1.8. We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.

1.9. We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction data”). The transaction data may include your contact details, and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.

1.10. We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.

1.11. We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

1.12. We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-ofcourt procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

1.13. We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

1.14. In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

1.15. Please do not supply any other person’s personal data to us, unless we prompt you to do so.

2. PROVIDING YOUR PERSONAL DATA TO OTHERS

2.1. We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-ofcourt procedure.

2.2. In the usual course of our business we will disclose your personal data (to the extent necessary) to certain organisations that we use to support the delivery of our services. This may include the following; third party organisations and individuals that we use to support the delivery of our services, this may include business partners, suppliers and subcontractors for the performance of any contract we enter into with you, organisations providing IT systems support and hosting in relation to the IT systems on which your information is stored, third party debt collectors for the purposes of debt collection, delivery companies for the purposes of transportation, third party service providers for the purposes of storage of information and confidential destruction, third party marketing companies for the purpose of sending marketing emails, subject to obtaining appropriate consent.

2.3. We use the services of independent consultants and practitioners who carry out assessments, procedures, treatments and classes at our Clinics. They may need to share your personal data and medical records with Western House Consulting Rooms ltd and we may need to share the same with them to provide the services.

2.4. We may disclose, with your consent, your personal data to your insurance company; employer; solicitor, GP/Consultant, Private/Medical Clinic, NHS or other specified company insofar as reasonably necessary for the performance of the services, your personal medical interest, continuity of care and for administration of our business.

2.5. If the information is sensitive personal data related to your health this will only be disclosed to those involved with your treatment or care, payment for eg insurance company, or in accordance with UK laws and guidelines of professional bodies or for the purpose of clinical audits (unless you object). We will only use your sensitive personal data for the purposes for which you have given us your explicit consent to use it or for your personal medical interest and continuity of care.

2.6. Financial transactions relating to our website and services may be handled by our payment services providers. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.

2.7. In addition to the specific disclosures of personal data set out in this Section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-ofcourt procedure.

2.8. Where you do not provide consent or wish to restrict the processing of your data for contractual purposes, we may not be able to provide the service as we require such information as part of the service to protect yourself, protect staff under health and safety and to ensure your continuity of care, and administration of our business, notably through payment of invoices from third parties.

3. SECURITY & TRANSFERS OF YOUR PERSONAL DATA

3.1. We protect all personal data we hold about you by ensuring that we have appropriate organisational and technical security measures in place to prevent unauthorised access or unlawful processing of personal data and to prevent personal data being lost, destroyed or damaged. We conduct assessments to ensure the ongoing security of our information systems.

3.2. Any personal data you provide will be held for as long as is necessary having regard to the purpose for which it was collected and in accordance with all applicable UK laws.

3.3. Personal data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Where we transfer your personal data outside the EEA, we will ensure that there are adequate protections in place for your rights, in accordance with Data Protection Laws. By submitting your personal data, and in providing any personal data to us, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this Privacy Policy.

3.4. At your request, we may occasionally transfer personal information to you via email, or you may choose to transfer information to us via email. Email is not a secure method of information transmission; if you choose to send or receive such information via email, you do so at your own risk. We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.

3.5. We will store all your personal data within externally hosted software on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.

3.6. You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

4. RETAINING AND DELETING PERSONAL DATA

4.1. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

4.2. We will retain your personal data as follows:
4.2.1. Personal data will be retained for a minimum period of 8 years following the last interaction date, and for a maximum period of 10 years following the last interaction date.

4.3. In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based applicable law.

4.4. Notwithstanding the other provisions of this Section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

5. SUBJECT ACCESS REQUEST

5.1. Data Protection Laws give all individuals the right to make a ‘Subject Access Request’ to obtain a copy of any information that any organisation holds about them. Applicants would need to provide proof of identity or right of access in order to access any information held.

6. AMENDMENTS

6.1. We may update this policy from time to time by publishing a new version on our website.

6.2. You should check this page occasionally to ensure you are happy with any changes to this policy.

7. YOUR RIGHTS

7.1. In this Section 7, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

7.2. Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.

7.3. You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

7.4. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

7.5. In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: [the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed]. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: [for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims].

7.6. In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

7.7. You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

7.8. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

7.9. You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

7.10. To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

7.11. If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement. For the UK the ICO are the relevant body and further information can be found at https://ico.org.uk/concerns/.

7.12. To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

7.13. You may exercise any of your rights in relation to your personal data by written notice to us.

8. COOKIES USED BY OUR SERVICE PROVIDERS

8.1. Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

8.2. We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.