Seren Bay Limited Website Privacy Notice

 

   

1.   Introduction 

  

This privacy notice provides you with details of how we collect and process your personal data through your use of our sites www.serenbay.com and www.judithholden.com.

 

By providing us with your data, you warrant to us that you are over 13 years of age.

  

Seren Bay Limited is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

  

We have appointed a Data Protection Officer who is in charge of privacy related matters for us. If you have any questions about this privacy notice, please contact the Data Protection Officer using the details set out below.

 

Contact Details

 

Our full details are:

 

Full name of legal entity: Seren Bay Limited

 

Name or title of Data Protection Officer: Dr Judith Holden

 

Email address: info@serenbay.com

 

Postal address: Suite 106, Cornwall Buildings, 45 Newhall Street, Birmingham, B3 3QR

 

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at info@serenbay.com.

 

2.  What Data Do We Collect About You, For What Purpose and On What Ground We Process It 

 

Personal Data

Personal data means any information capable of identifying an individual. It does not include anonymised data.  Personal information includes: your full name or names, date of birth, age, address, email, telephone/SMS/WhatsApp number, emergency contact name and telephone number, GP contact details, health insurance details or payment details (if relevant).

 

With respect to the website/s, we may process the following categories of personal data about you:

 

• Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.

 

• Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground 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.

 

Sensitive Data

 

When you make contact with us, we may then need to collect sensitive data about you in order to deliver the services requested. The condition for processing this ‘special category data’ is that it is necessary for the purposes of the provision of health or social care or treatment. 

 

Sensitive information can include areas such as:  gender identity, sexual orientation, ethnicity, disability status, religious affiliation, political affiliation, family and relationship history and current status, education, occupational history and current status, psychological and psychiatric history, relevant medical conditions, medication, substance use, offending history (including allegations).  Sensitive data also encompasses information about children under the age of 18 years.

 

We require your explicit consent for processing sensitive data, so when you submit your details, we will send you a further communication asking for you to confirm your consent to this processing.

 

Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.

 

We will only use your personal data for the purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at info@serenbay.com. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.

 

We may process your personal data without your knowledge or consent where this is required or permitted by law.

 

We do not carry out automated decision making or any type of automated profiling.

 

3.  How We Collect Your Personal Data

 

We may collect data about you by you providing the data directly to us (for example by filling in forms on our site or by sending us emails). We may automatically collect certain data from you as you use our website by using cookies and similar technologies. Please see our cookie policy for more details about this.

 

We may receive data from third parties, such as referrers who make contact on your behalf.   

 

We may also receive data from Health Insurers and other parties linked to your referral.

 

4. Marketing Communications 

 

Seren Bay Limited does not engage in marketing communications.  We will only contact you in relation to your enquiry or referral. 

 

We do not share your personal data with any third party for their own marketing purposes.

 

5.  Disclosures Of Your Personal Data  

 

We may have to share your personal data with the parties set out below:

 

• Service providers who provide IT and system administration services.

• Professional advisers including accountants, lawyers, bankers, auditors and insurers.

• Government bodies that require us to report processing activities.

• Third parties to whom we sell, transfer, or merge parts of our business or our assets.

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We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

 

6.  International Transfers   

 

We are subject to the provisions of the General Data Protection Regulations that protect your personal data. Where we transfer your data to third parties outside of the UK, we will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data. Examples of such transfers could include arranging online appointments via the Zoom or Teams platforms.  As such:

 

• We may transfer your personal data to countries that the United Kingdom regulatory authorities have approved as providing an adequate level of protection for personal data by; or

• If we use US-based providers that are part of a UK regulator approved privacy framework, we may transfer data to them, as they have equivalent safeguards in place; or

• Where we use certain service providers who are established outside of the UK, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe.

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If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time. 

 

7.  Data Security  

 

We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.

 

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.

 

8.  Data Retention  

  

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
 

When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

 

For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.

  

In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

 

Her Majesty’s Revenue and Customs (HMRC) requires electronic invoices to be retained for seven years.  Invoices are deleted thereafter.

 

Adult client records are retained for seven years in compliance with professional indemnity requirements and professional regulations. If the client dies during therapy or coaching, records will be retained for seven years as per health industry standards.  Electronic files will be deleted and physical files securely shredded at the beginning of the calendar year thereafter. 

 

For young people under 18 years, records will be kept until the client’s 26th birthday.

 

When an assessment, therapy, or coaching has been undertaken, it is not possible to comply with a request to delete a client’s personal information during the above time periods. 

 

If you make an initial enquiry with no further contact, your details will be deleted within six months.

 

Where audio or video recordings of therapy or coaching sessions have been made for training and supervision purposes, these will be deleted when they have served their purpose or when you withdraw your consent, whichever is sooner.

 

Basic contact details held on a mobile phone will be deleted within six months of the end of assessment, therapy, or coaching concluding.

 

Where it is not necessary to retain the data for seven years, it is destroyed as soon as possible.  Court bundles for example, are destroyed once the Final Hearing has concluded. 

 

 

9.  Your Legal Rights  

 

Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.

 

You can see more about these rights at:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

 

If you wish to exercise any of the rights set out above, please email us at info@serenbay.com.

 

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.

  

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

  

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.

 

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

 

10. Third-Party Links  

 

This website 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 website, we encourage you to read the privacy notice of every website you visit.

 

11. Cookies  

 

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please follow this link.