Privacy Policy
Your privacy is of paramount importance to this practice.
Privacy Policy and GDPR
Dr. Herman Holtzhausen Privacy Policy and GDPR (General Data Protection Compliance)
This Service collects Personal Data from its Clients.
OWNERS AND DATA CONTROLLERS
Dr Herman Holtzhausen for Dr Herman Holtzhausen and/or Stamfordpsychotherapist
Orion House, 14 Barn Hill, Stamford, Lincolnshire, PE9 2AE
Owners’ contact email: herman@stamfordpsychotherapist.co.uk
TYPES OF DATA COLLECTED
Among the types of Personal Data that are being collected are name, date of birth, address, contact details, significant medical history, and third party emergency contact details. In addition, and as part of the Services Dr Herman Holtzhausen provides through Client engagement, additional personal information is routinely gathered and may form part of a client-specific record.
Unless specified otherwise, all Data requested by Dr Herman Holtzhausen is mandatory and failure to provide this Data may make it unfeasible to provide the contracted Service. In cases where we specifically state that some Data is not mandatory and therefore optional, a Client is free not to communicate this Data without consequences to the availability or the functioning of the Service. A Client who is uncertain about which Personal Data is mandatory and what the purpose for the collection of that data is can seek clarification from the Owner.
A Client is responsible for any third-party Personal Data obtained and confirm that they have the third party’s consent to provide the Data to the Owner.
MODE AND PLACE OF PROCESSING THE DATA
METHODS OF PROCESSING
The Owner takes appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the Data.
The Data processing is carried out using paper copy, computers and/or IT enabled tools, and is done in accordance with organisational procedures and modes strictly related to the purposes indicated.
In addition to the Owner, in some cases, the Data may be accessible to other persons involved in the day-to-day administration or system administration of the Service or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies). If required and necessary, these parties may act as Data Processors on behalf of the Owner. Strict measures will be taken to ensure that only information relevant to that function is shared and to ensure that confidentiality is not breached and data is processed securely.
LEGAL BASIS OF PROCESSING
The Owners may process Personal Data if one of the following applies:
- the Client has given their consent for one or more specific purposes. Note: Under some legislations the Owners may be allowed to process Personal Data until the Client objects to such processing (“opt-out”).
- provision is necessary for the performance of an agreement with the Client and/or for any pre-contractual obligations thereof;
- processing of Data is necessary for compliance with a legal obligation to which the Owners are subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owners;
- processing is necessary for the purposes of the legitimate interests pursued by the Owners or by a third party.
In any case, the Owners will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
PLACE
The Data is processed at the Owners’ operating offices and in any other places where the parties involved in the processing are located.
Depending on the Client’s location, data transfers may involve transferring the Client’s Data to a country other than their own.
A Client is entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organisation governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, a Client can request more information from the Owners.
RETENTION TIME
Personal Data shall be processed and stored for 7 years for the purpose they have been collected for and will be destroyed when this period has lapsed.
Therefore:
- Personal Data collected for purposes related to the performance of a contract between the Owners and the Client shall be retained until such contract has been fully performed and for a period of 7 years thereafter.
- Personal Data collected for the purposes of the Owners’ legitimate interests shall be retained as long as needed to fulfil such purposes. Clients may find specific information regarding the legitimate interests pursued by contacting the Owners.
The Owners may be allowed to retain Personal Data for a longer period whenever the Client has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owners may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
THE PURPOSES OF PROCESSING
The Data concerning the Client is collected to allow the Owners to provide its Services. The data held is for Dr. Herman Holtzhausen use only and will not be shared with an employer without the consent from the Client.
A Client can request further detailed information about such purposes of processing and about the specific Personal Data used for each purpose.
THE RIGHTS OF A CLIENT
A Client may exercise certain rights regarding their Data processed by the Owners.
In particular, the Client has the right to do the following:
- Withdraw their consent at any time
A Client has the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data
A Client has the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
- Access their Data
A Client has the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing, and obtain a copy of the Data undergoing processing.
- Verify and seek rectification.
A Client has the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data.
A Client has the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owners will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed.
A Client has the right, under certain circumstances, to obtain the erasure of their Data from the Owners.
- Receive their Data and have it transferred to another controller.
A Client has the right to receive their Data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the Client’s consent, on a contract which the Client is part of or on pre-contractual obligations thereof.
- Lodge a complaint.
A Client has the right to bring a claim before their competent data protection authority.
DETAILS ABOUT THE RIGHT TO OBJECT TO PROCESSING
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owners or for the purposes of the legitimate interests pursued by the Owners, a Client may object to such processing by providing a ground related to their particular situation to justify the objection.
A Client must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification.
HOW TO EXERCISE THESE RIGHTS
Any requests to exercise a Client’s rights can be directed to the Owners through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owners as early as possible and within one month.
ADDITIONAL INFORMATION ABOUT DATA COLLECTION AND PROCESSING
LEGAL ACTION
The Client’s Personal Data may be used for legal purposes by the Owners in Court or in the stages leading to possible legal action arising from improper use of the related Services.
The Client declares to be aware that the Owners may be required to reveal personal data upon request from public authorities.
ADDITIONAL INFORMATION ABOUT A CLIENT’S PERSONAL DATA
In addition to the information contained in this privacy policy, this Service may provide the Client with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
INFORMATION NOT CONTAINED IN THIS POLICY
More details concerning the collection or processing of Personal Data may be requested from the Owners at any time. Please see the contact information elsewhere in this document.
CHANGES TO THIS PRIVACY POLICY
The Owners reserves the right to make changes to this privacy policy at any time by giving notice to a Client and within this Service and/or – as far as technically and legally feasible – sending a notice to a Client via any contact information available to the Owners.
Should the changes affect processing activities performed on the basis of the Client ’s consent, the Owner shall collect new consent from the Client, where required.
DEFINITIONS AND LEGAL REFERENCES
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Client
The individual using this Service who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Data Controller [or Owner], as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Service. The Data Controller, unless otherwise specified, is the Owner of this Service.
Service
The service provided by this Company, Dr Herman Holtzhausen Ltd, as described in the terms agreed with the Client’s employer.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Legal information
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
This privacy policy relates solely to this Service, if not stated otherwisewithin this document.