Privacy Policy
Wired to Thrive OT Privacy Notice
This privacy notice tells you what to expect us to do with your personal information.
If you have any concerns or queries regarding this policy, please contact: hello@wiredtothrive.com
What information we collect, use, and why
We collect or use the following information to provide client care and services:
· Name, address and contact details
· Gender
· Pronoun preferences
· Date of birth
· Next of Kin details including any support networks
· Emergency contact details
· Information about care needs (including disabilities, home conditions, medication and dietary requirements and general care provisions)
· Records of meetings and decisions
We collect or use the following information for safeguarding or public protection reasons:
· Name, address and contact details
· Emergency contact details
We collect or use the following personal information for information updates or marketing e.g. to update you on an upcoming webinar:
· Names and contact details
We collect or use the following personal information for dealing with queries, complaints or claims:
· Names and contact details
Lawful bases and data protection rights
Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:
· Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.
· Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.
· Your right to erasure - You have the right to ask us to delete your personal information. Read more about the right to erasure.
· Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.
· Your right to object to processing - You have the right to object to the processing of your personal data. Read more about the right to object to processing.
· Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability.
· Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.
If you make a request, we must respond to you without undue delay and in any event within one month.
To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.
Our lawful bases for the collection and use of your data
Our lawful bases for collecting or using personal information to provide client care and services are:
· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
· Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
· Legitimate interests - we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
· Record keeping required by professional standards such as those expected by the Royal College of Occupational Therapists. It is also part of professional standards to ensure these records are maintained and kept up to date. As a healthcare professional, it is important for me to keep notes about sessions and interventions, track goals and progress and maintain safeguarding records where relevant.
· Wired to Thrive will also use this information to communicate with clients, send appointment reminders and share resources or summaries relevant to OT coaching and therapy. This is beneficial for the client for several reasons. It allows the OT to complete an initial assessment, to get a holistic sense of how best to service the client\'s needs. This understanding may include understanding a client’s unique ADHD profile and co-occurring conditions, in order to work productively together co-create a plan. Assessing a client\'s occupational performance and daily functioning, identify their sensory processing differences (through relevant assessments) and identify mental health or trauma considerations.
· For ongoing support, it is also in the best interests of the client as data will be used to plan therapy or OT coaching interventions and track progress and outcomes. It is likely that a report, or several reports may be required in the course of our work together, therefore data collected will also be used to support this.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Our lawful bases for collecting or using personal information for safeguarding or public protection reasons are:
· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
· Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Our lawful bases for collecting or using personal information for information updates or marketing are:
· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:
· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
· Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
· Wired to Thrive may collect and use personal information where necessary to respond to enquiries, concerns, complaints, or potential claims relating to our services. This may include contact details, correspondence, and relevant information from session records where appropriate.
· Processing this information allows us to investigate issues, respond appropriately, improve our services, and meet our professional, legal, and insurance obligations.
· The lawful basis for this processing is our legitimate interests in managing and protecting our practice and providing a safe and accountable service, in accordance with the requirements of the UK General Data Protection Regulation and the Data Protection Act 2018.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Where we get personal information from
· Directly from you
· Family members or carers
· Other relevant parties e.g. educational organisations, places of work – with additional explicit consent only
How long we keep information
Adults
· Minimum: 7–8 years after the last contact
Children
· Until the client turns 25
For more information on how long we store your personal information or the criteria we use to determine this please contact us using the details provided above.
Who we share information with
Others we share personal information with
· Organisations we need to share information with for safeguarding reasons
Duty of confidentiality
We are subject to a common law duty of confidentiality. However, there are circumstances where we will share relevant health and care information. These are where:
· you’ve provided us with your consent (we have taken it as implied to provide you with care, or you have given it explicitly for other uses);
· we have a legal requirement (including court orders) to collect, share or use the data;
· on a case-by-case basis, the public interest to collect, share and use the data overrides the public interest served by protecting the duty of confidentiality (for example sharing information with the police to support the detection or prevention of serious crime);
· If in England or Wales – the requirements of The Health Service (Control of Patient Information) Regulations 2002 are satisfied; or
· If in Scotland – we have the authority to share provided by the Chief Medical Officer for Scotland, the Chief Executive of NHS Scotland, the Public Benefit and Privacy Panel for Health and Social Care or other similar governance and scrutiny process.
How to complain
If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.
If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113