PRIVACY AND COOKIES NOTICE
Bloomfield Health Limited (we or us) is a company registered in England and Wales under company number 13208428 with registered office address The Stables, 23b Lenten Street, Alton, Hampshire, England, GU34 1HG.
Our contact details are:
Email: enquiries@bloomfieldhealth.com Telephone:+ 44 20 7458 4640 Post: Bloomfield Health Limited, Queen Square Private Consulting Rooms 23 Queen Square London WC1N 3BG United Kingdom
What is the purpose of this document?
We are committed to protecting and respecting your privacy. This privacy notice sets out the basis on which we process any personal data we collect about users of our psychiatric therapy services and our website at www.bloomfieldhealth.com (oursite) and how that information will be processed by us.
This privacy notice applies to: users of our psychiatric therapy services, visitors to our site; and all individual contractors, clinicians and service providers who provide services to or for or in association with our business (you).
We are a data controller. This means that we are responsible for deciding how we hold and use personal information about you, and for explaining this clearly to you.
Please read this privacy notice carefully to understand what we do with your personal information and what rights you have in relation to our activities.
What is personal data and our lawful basis for processing
Personal data, or personal information, means any information relating to an individual from which that person can be identified. There are special categories of more sensitive personal information which require a higher level of protection (see further at section 3.4, below).
We will only use your personal information when the law allows us to. Our principle lawful basis for processing is set out in the table below. However, some of our grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
We may only rely on our legitimate interests (or those of a third party) to process your personal information, if your interests and fundamental rights do not override those interests. Where we rely on legitimate interests for our processing, we have set out the relevant interest, below.
Generally, we do not rely on consent as a legal basis for processing your personal data although, if you are a private individual, we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent where this is required or permitted by law.
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 perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
Data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data includes first name, last name, title and date of birth.
Contact Data includes billing address, home address, telephone numbers and email address.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you.
Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our site.
Appointment Data includes information about which of our services you use and when and how you use our services.
Health Data includes information about your mental and physical wellbeing and any treatment that we prescribe. This is likely to include special category personal data (see section 3.4 below). Marketing and Communications Dataincludes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Contact Data to calculate the percentage of users accessing our services from different locations. 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 policy.
You are not required to provide to us any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data) or information about criminal convictions and offences and we do not seek to collect such information about you from other sources. However you may choose to provide to us special category personal information, for example during appointments with our therapists when you may be asked questions pertaining to these topics.
We may also process personal information (including special category information):
relating to a health condition or disability in order to meet our legal obligation to make reasonable adjustments in the provision of our services;
to ensure meaningful equal opportunity and diversity and inclusion monitoring and reporting;
where it is needed to protect your vital interests (or someone else's interests) and you are not capable of giving your consent;
where it is necessary to establish, exercise or defend a legal claim;
where you have manifestly made the information public; or
otherwise with your explicit consent.
How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact, Financial and Marketing and Communications Data by speaking with us in person, filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
register to use our services;
attend appointments with our therapists;
create an account on our site;
subscribe to our service or publications;
request marketing to be sent to you; or
give us feedback, make a complaint or contact us.
We collect Identity, Contact and Technical Data from our Social Media accounts:
Facebook: Bloomfield Health /https://www.facebook.com//NAME>
Twitter: @bloomfieldheal /https://www.twitter.com/bloomfieldheal
Instagram: @Blomfield_health_ https://www.instagram.com/Blomfield_health_
Linkedin: Bloomfield Health
YouTube: Blomfield Health
Automated technologies or interactions. As you interact with our site, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see section 10, below, for further details.
Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
Technical Data from analytics providers such as Google based outside the EU;
Contact, Financial and Transaction Data from providers of technical and payment services such as Stripe based outside the UK.
Identity and Contact Data from publicly available sources such as Companies House based inside the UK.
Purposes for which we will use your personal data
Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
To register you as a new patient | (a) Identity Data (b) Contact Data | Performance of a contract with you |
To provide you with psychiatric therapy services including during consultations and appointments and within your patient record | (a) Health Data (b) Contact Data | (a) Performance of a contract with you (b) Necessary for the provision of health care or treatment |
To process and manage your appointments including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us | (a) Identity Data (b) Contact Data (c) Financial Data (d) Transaction Data (e) Appointment Data (f) Marketing and Communications Data | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
To manage our relationship with you which will include notifying you about changes to our terms or privacy policy | (a) Identity Data (b) Contact Data (c) Marketing and Communications Data | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how individuals use our products/services) |
To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity Data (b) Contact Data (c) Technical Data | (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity Data (b) Contact Data (c) Appointment Data (d) Marketing and Communications Data (e) Technical Data | Necessary for our legitimate interests (to study how patients use our services, to develop our services, to grow our business and to inform our marketing strategy) |
To use data analytics to improve our site, services, marketing, patient relationships and experiences | (a) Technical Data (b) Appointment Data | Necessary for our legitimate interests (to define types of patients for our services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy) |
To make suggestions and recommendations to you about services that may be of interest to you | (a) Identity Data (b) Contact Data (c) Technical Data (d) Appointment Data (e) Marketing and Communications Data | Necessary for our legitimate interests (to develop our services and grow our business) |
Automated decision-making
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention.
We do not envisage that any serious decisions will be taken about you using automated means, however we will notify you in writing if this position changes.
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your Identity, Contact, Technical and Appointment Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us or purchased products from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time by email.
Sharing your information
We share your personal information with third party contractors and service providers to the extent necessary to provide services to you in accordance with our contract with you.
If you are a patient we may share your personal information with other clinicians or parties involved in your care, unless you request us not to. However we may proceed with such data sharing, even if you have asked us not to, due to emergencies, safeguarding risks, clinical risks, or impaired capacity, in particular where we consider you to be a risk to yourself or to other people. This data sharing is in accordance with the Mental Health Act 1983, the Mental Capacity Act 2005, the Children Act 1989 and guidance from the General Medical Council and Royal College of Psychiatrists.
We may share your information with other third parties as follows:
our regulators, professional advisors, insurance provider and auditors;
HMRC or other government or law enforcement agencies;
if we sell any business or assets, in which case we may disclose your personal information to the prospective buyer of such business or assets;
payment service providers when you pay for our services;
if we have a legal obligation to do so; and
for the purposes of fraud protection and credit risk reduction.
The categories of third parties listed above use your personal data for their own purposes and are responsible for their own compliance with data protection legislation.
We also share your data with third-party service providers who provide services to our business, such as our clinical patient records system providers, website host server, IT support and maintenance service, cloud storage provider and email exchange server, payment service providers and other businesses that provide certain services on our behalf. All of our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes.
Data security
We have put in place:
appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed; and
procedures to deal with any suspected data security breach, and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Transferring information outside the EEA
Any personal information that you submit to us will be held on secure servers, based within the UK and Australia.
If we are required to transfer your information outside the UK or EEA, we have put in place appropriate measures to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the EU and UK laws on data protection.
If you are based outside the UK or EEA we may transfer personal information to the correspondence address you provide to us to the extent necessary to complete your order. We will take all reasonable steps to ensure that such transfers are secure. By instructing us from outside the UK or EEA you agree that such transfer is necessary for us to complete your order.
We use Google Analytics to evaluate the performance of our site and improve the service we offer you. We may transfer information about you outside the UK or EEA for this purpose. We will only do so where permitted by law.
We use European Commission approved standard contractual clauses to help protect your personal information when it may be transferred to third countries.
How long will we keep your personal information for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
We keep basic information about our patients (including Contact, Identity, Financial, Appointment and Transaction Data) for 10 years after they cease being our patients. We keep Health Data for 20 years or for 8 years after the death of the relevant data subject, whichever is shorter.
In some circumstances you can ask us to delete your data: see your rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Your rights
You have the following rights:
to be told what we are doing with your personal information (we do this by providing you with this privacy notice);
to withdraw your consent to us processing your special category personal data;
to correct or update the personal information we hold about you.
to object to the processing of your personal information;
to request a copy of the personal information we hold about you;
to ask us to delete the information that we hold about you where there is no good reason for us continuing to process it;
to ask us to stop processing your personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground and where there is no good reason for us continuing to process it;
to ask us to restrict how we use your personal information for a period of time if you claim that it is inaccurate and we want to verify the position or in some limited other circumstances;
to ask us to send your personal information to another organisation in a computer-readable format;
to complain to the Information Commissioner's office if you are unhappy with our use of your personal data: you can do this at https://ico.org.uk/concerns/.
Do contact us straight away if you consider that we are not handling your personal information properly so we can try and sort the problem out.
If we delete your personal information or restrict our use of it, we will not be able to provide our services to you.
If you want to exercise any of your rights, please contact us at the address above. We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights).
Cookies policy
We make use of cookies on our site.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive. Our site uses cookies to distinguish you from other users of our site. This helps us to provide you with a good experience when you browse our site and also allows us to improve our site.
Essential cookies are necessary for running our site.
Analytical/performance cookies allow us to recognise and count the number of visitors and see how they navigate when using our site. They also help us improve how our site functions, e.g. in order to ensure that all users can easily find what they are looking for.
Functional cookies are used to recognise you when come back to visit our site. They also allow us to personalise our site’s content for you and remember your preferences. These could be, for example, your choice of language and region.
Targeting cookies are used to register your visit on our site, the pages you have visited and the links you clicked on. We use this information to make our site and the advertisements shown on it more relevant to you. We may also share this information with third parties for the same reasons.
Third party cookies. Please note that some third parties may also utilise their own cookies, over which we have lit we have little or no control. You can find out about their use of cookies by visiting the third parties' websites.
Further details of our use of cookies is available on our website at www.bloomfieldhealth.com.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
If you want to find out more information about cookies, go to http://www.allaboutcookies.org or to find out about removing them from your browser, go to http://www.allaboutcookies.org/manage-cookies/index.html.
Third-party links
Our site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our site, we encourage you to read the privacy policy of every website you visit. Last Updated June 2021
