Introduction

A Step at a Time is a private therapy business offering a range of therapies to private clients by appointment only. Sessions are individual or through programmes for both children and adults including provision for Lego®-Based Therapy and Therapy Dog Sessions. This privacy policy outlines A Step at a Time’s procedures for collecting, storing and processing personal data to comply with the EU General Data Protection Regulations (GDPR).

Your privacy is very important to us and we will only ever collect your information to help improve the service we give to you. Under the data protection principles this policy ensures that information:

• Is used fairly and lawfully
• Is only used for the specified purposes
• Is kept for no longer than required
• Is kept safe and secure
• Is not transferred or shared without explicit consent from the client

What this privacy policy covers:

A Step at a Time is committed to protecting the privacy of its clients in accordance with its obligations under the data protection legislation. From the 25th May 2018 A Step at a Time is also required to be compliant with the General Data Protection Regulations and to register with the ICO (Information Commissioners Office).

This privacy policy explains which information A Step at a Time collects about you and how it will be used.

What we collect

A Step at a Time collects information in two ways:

• Personal data is collected through contracted client treatment sessions which are recorded on each client’s individual files.
• Email addresses and names are collected when a client signs up for or purchases any online product which is either free or payable, including newsletters.

Why we need to collect information:

A Step at a Time is required to collect information from the individuals we work with to deliver the service being requested and to comply with any legal and professional responsibilities that ensure the appropriate delivery of the service. This is a contractual requirement.

What we do with the information we gather and How long do we keep it:

Personal Data

In conjunction with the legal and insurance requirements of A Step at a Time all adult (18yrs+) client files are kept in a secured unit for a period of 5 years after their treatment. Files include client notes, relevant forms or treatment notes, an outline of session content and any correspondence provided by the client. After which time these files are confidentially destroyed by the owner.

Email Data

Any information collected through an individual signing up for newsletter, gift or payable item is added to the A Step at a Time mailing list.

Clients who contact A Step at a Time with regards to booking treatment sessions by email will be responded to. Once a session has been booked relevant information is printed and placed on the client file, emails are then deleted from the system.

Website contact forms

These are printed where relevant and added to client files, then deleted once contact has been made.

Social media

If you have opted to ‘like’ or ‘follow’ A Step at a Time on any social media channels I do not hold data about this outside of the social media setting.

Who we share this information with and your choices:

A Step at a Time will not sell your data. We will not share your data for marketing purposes unless you have actively consented to this. The only exception is in the circumstances where a client or a client’s parent has requested that we contact anther professional involved in their care, for instance a school or doctor. This is always completed with consent from the party.

The only exception to this is in the circumstances where it is:

• deemed that a client has a risk to their own health, or the health of another in which relevant parties would be contacted, where possible with the consent of the client involved.
• If during my contact time with a client I become aware that there is a safeguarding risk to eitherthe client or another person in which case I will contact the relevant parties dependent on the situation.
• Where I am required to comply with legal requirements (e.g. a court order)

Direct Marketing:

We will only contact you by email or text message if you actively consent to this, either through:

• The purchase of an online product
• Actively signing up for a newsletter through our website
• Requesting that you are added to a mailing list through the selection of authorisation on ourtreatment contract.

Email subscriptions:

If you wish to unsubscribe from email communications from A Step at a Time or Adventures of Brian you can do so by clicking on the unsubscribe link at the bottom of any email received.

Contact to Third Parties:

In some circumstances a client or parent of a client will require that we share the information from the treatment session with a professional third party, for instance a solicitor, lawyer, social services or the child’s educational facility. These requests are managed on an individual basis and firstly take account of our insurance and legal requirements, parental responsibility and our requirements to safeguard the children and young people we work with. Requests must be made in writing and information shared will be posted by signed delivery to the required address. Information will not be provided by email.

Under 18s:

We collect and manage personal data of under 18’s. We will only keep this data for the purpose in which it was collected. Child data for those under the age of 18 years is kept for a period of 5 years after the treatment, unless otherwise specified by the parents in writing.

We will always ensure that we have the consent from the parent or guardian of the child before collecting and processing this information. Children under the age of 18 are not permitted to schedule or attend a treatment session without the consent of a parent or legal guardian. Parents are required to attend the first treatment session to sign the parental consent forms.

Making payments:

A Step at a Time makes every effort to maintain customer confidentiality when
securing an online payment. This includes ensuring the security of your credit card
details. No credit card details will ever be stored by A Step at a Time and online
payment systems require the customer to enter their data. When making an online payment clients utilize a secure internet site (Simplero – indicated by the https:// in the address bar). A Step at a Time will never ask you for your credit card or CVC number.

Erasing Information:

You have the right to request that we erase any personal information we hold, where A Step at a Time has no compelling reason to continue processing this data. Records must be kept for 5 years in accordance with insurance requirements. Any written requests to erase information will be treated on individual basis and be considered in consultation with the insurance requirements of A Step at a Time. In some circumstances client files will need to be held on legal basis. Unless otherwise stipulated by law files will be retained for a period of 5 years at which point they will be confidentially destroyed.

Requesting your information:

Under the General Data Protection Regulations, you have the right to request a copy of the personal information we hold about you.

If you think we have incorrect information or your details have changed, or you would like a copy of the information we hold about you- You may request details of personal information which we hold about you under the Data Protection Act 1998. A small fee may be payable. This fee will not exceed £10, or the prevailing statutory maximum. If you would like a copy of the information held on you, please write to:
Nicky Edwards (Owner) – info@astepatatime.org.uk

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