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Privacy Policy

Privacy policy

This privacy policy applies between you, the User of this Website and WPF Therapy Limited, the owner and provider of this Website. WPF Therapy Limited takes the privacy of your information very seriously. This privacy policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website. Please read this privacy policy carefully.

Definitions and interpretation

  1. In this privacy policy, the following definitions are used:
Datacollectively all information that you submit to WPF Therapy Limited via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Act 1998;
Cookiesa small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below (Cookies);
WPF Therapy Limited, or usWPF Therapy Limited, a company incorporated in England and Wales with registered number 1214251 whose registered office is at Kamen House, 23 Magdalen Street, London, SE1 2EN;
UK and EU Cookie Lawthe Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011;
User or youany third party that accesses the Website and is not either (i) employed by WPF Therapy Limited and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to WPF Therapy Limited and accessing the Website in connection with the provision of such services; and
Websitethe website that you are currently using, www.wpf.org.uk, and any sub-domains of this site unless expressly excluded by their own terms and conditions.

2.    In this privacy policy, unless the context requires a different interpretation:

a.   the singular includes the plural and vice versa;

b.   references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;

c.   a reference to a person includes firms, companies, government entities, trusts and partnerships;

d.   “including” is understood to mean “including without limitation”;

e.   reference to any statutory provision includes any modification or amendment of it;

f.   the headings and sub-headings do not form part of this privacy policy

Scope of this privacy policy

  1. This privacy policy applies only to the actions of WPF Therapy Limited and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.

Data collected

  1. We may collect the following Data, which includes personal Data, from you:
  • Name
  • Date of Birth;
  • Gender;
  • Job Title;
  • Profession;
  • Contact Information such as email addresses and telephone numbers;
  • Demographic information such as post code, preferences and interests;
  • Other information relevant to customer surveys and/or offers

in each case, in accordance with this privacy policy.

Our use of Data

  1. For purposes of the Data Protection Act 1998, WPF Therapy Limited is the “data controller”.
  2. We will retain any Data you submit for 12 months.
  3. Unless we are obliged or permitted by law to do so, and subject to any third-party disclosures specifically set out in this policy, your Data will not be disclosed to third parties. This does not include our affiliates and / or other companies within our group.
  4. All personal Data is stored securely in accordance with the principles of the Data Protection Act 1998. For more details on security see the clause below (Security).
  5. Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:
  6. internal record keeping;
  7. improvement of our products / services;
  8. transmission by email of promotional materials that may be of interest to you;
  9. contact for market research purposes which may be done using email, telephone, fax or mail. Such information may be used to customise or update the Website;
  10. in each case, in accordance with this privacy policy.

Third party websites and services

  1. WPF Therapy Limited may, from time to time, employ the services of other parties for dealing with certain processes necessary for the operation of the Website. The providers of such services have access to certain personal Data provided by Users of this Website.
  2. Any Data used by such parties is used only to the extent required by them to perform the services that we request. Any use for other purposes is strictly prohibited. Furthermore, any Data that is processed by third parties will be processed within the terms of this privacy policy and in accordance with the Data Protection Act 1998.

Links to other websites

  1. This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.

Controlling use of your Data

  1. Wherever you are required to submit Data, you will be given options to restrict our use of that Data. This may include the following:
  2. use of Data for direct marketing purposes; and
  3. sharing Data with third parties.

Functionality of the Website

  1. To use all features and functions available on the Website, you may be required to submit certain Data.
  2. You may restrict your internet browser’s use of Cookies. For more information see the clause below (Cookies).

Accessing your own Data

  1. You have the right to ask for a copy of any of your personal Data held by WPF Therapy Limited (where such Data is held).

Security

  1. Data security is of great importance to WPF Therapy Limited and to protect your Data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure Data collected via this Website.
  2. If password access is required for certain parts of the Website, you are responsible for keeping this password confidential.
  3. We endeavour to do our best to protect your personal Data. However, transmission of information over the internet is not entirely secure and is done at your own risk. We cannot ensure the security of your Data transmitted to the Website.

Cookies

  1. This Website may place and access certain Cookies on your computer. WPF Therapy Limited uses Cookies to improve your experience of using the Website and to improve our range of services. WPF Therapy Limited has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.
  2. All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.
  3. Before the Website places Cookies on your computer, you will be presented with a pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling WPF Therapy Limited to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.
  4. This Website may place the following Cookies:

Type of Cookie Purpose

  • Strictly necessary cookies – These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
  • Analytical/performance cookies – They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality cookies – These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  1. You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.
  2. You can choose to delete Cookies at any time; however, you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.
  3. It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.

General

  1. You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.
  2. If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.
  3. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
  4. This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.
  • TRAINING

We will collect and process personal data about you for the purposes described below. Personal data may contain “special categories of data” as described under the GDPR. Such “special categories of data” will include information about your race or ethnic origin, religious beliefs or other beliefs, physical or mental health or sexual orientation. When you register with us as a student or trainee you can decide if you wish to share with WPF Therapy certain types of “special categories of data”. The online registration process will provide you with more information.

Please note, that there is certain information that you are REQUIRED to provide.  If you do not provide the full information requested, we may not be able to process your application.

This information will be made clear through the application and selection process.  If you have any questions about this prior to applying, please contact the Training Administration team on 020 7378 2050.

Collection of Data

During your registration/enrolment on a training or workshop your information may be used to provide tailored training, support services, mailings and updates on training or workshop and other professional activities relevant to your training and to meet WPF Therapy’s contractual obligations of providing a service.

Length of Time Records Will Be Kept 

CategoryDescriptionMinimum PeriodMaximum Period
Recruitment dataExpression of interest in courses and open day information12 months after cessation of relationship
Application dataApplication forms, interview information

12 months after cessation of relationship (unsuccessful applicants only)

6 years after student leaves (successful applicants))

DBS DisclosureInformation relating to criminal records6 months after checking
Core academic dataTranscript like information and basic verification information relating to the individualPerpetuityPerpetuity
Financial DataInformation relating to student debt and student payments6 years after student leaves6 years after student leaves
Reference data in addition to core academic dataContents of student file e.g. attendance date, e-mails etc1 year after student leaves6 years after student leaves
Appeals and complaints/anticipated or ongoing legal actionAcademic and disciplinary appeals, student complaints1 year after student leaves for all students / traineesFor Cases: 6 years after exhaustion of internal process or after the student leaves.
Course informationProgramme and Module specificationsPerpetuityPerpetuity
Quality AssuranceStudent surveys, module reviews, programme reviews, minutes of meetings, Exam papers etcCurrent academic year plus 1None unless individuals are identified
Student assessments and evidence submitted for mitigation, disability notification.Assessments, exam scripts, and any item that identifies the student e.g. mitigating circumstances minutes, exam board minutes1 year after student leaves6 years after student leaves
Learning resources that identify students / traineesCurrent academic year plus 1
Learning resources that don’t identify students / traineesLecture slides, recordings and hand-outsIn accordance with systems policy, based on available space and system performanceIn accordance with systems policy, based on available space and system performance

  

  • THERAPY CLINIC

 We will hold the following information:

  1. Your personal and contact details as requested when you registered with the Clinic
  2. Financial information relating to the sessions attended and payments made
  3. Copies of letters and communications between you and us
  4. Assessment report
  5. GP details
  6. PHQ9/GAD7 scores?
  7. Session notes
  8. Session reports – after first session, every 6 months and closing reports
  9. Supervision process notes (anonymised notes presented to a senior colleague for safety and quality purposes)

This data will be gathered with your consent and in the legitimate interest of assisting us in fulfilling the Contract for Therapy.  It may also be necessary for us to hold and process this data in the interests of any safeguarding and risk factors.

Length of Time Records Will Be Kept

Individual DataClinic notes/assessmentsIn accordance with systems policy, based on available space and system performance6 years

Collection of Data

 Your data will be used for the following purposes:

  • To ensure we can contact you regarding your therapy sessions
  • For the Allocation Team to review and discuss your anonymised assessment report ensuring we provide the appropriate therapy and therapist
  • For the finance team to ensure payments for sessions are up to date.
  • For your therapist to discuss case notes at their clinical supervision meetings. It is an ethical requirement for all therapists to have supervision to ensure their work is safe and effective.
  • To carry out anonymised research
  • To discuss anonymised case material at training seminars.
  • WPF Therapy is a training organisation and psychotherapists-in-training occasionally use session material in an anonymised format for essay writing and presentations and discussions in seminars, to help them develop into high quality, safe and effective practitioners. All psychotherapists-in-training and training staff are bound by the WPF Therapy Confidentiality Policy.

Your rights as a data subject

You have the right to:

  • withdraw consent where that is the legal basis of our processing;
  • access your personal data that we process;
  • rectify inaccuracies in personal data that we hold about you;
  • be forgotten, that is your details to be removed from systems that we use to process your personal data;
  • restrict the processing in certain ways
  • obtain a copy of your data in a commonly used electronic form; and
  • object certain processing of your personal data by us.

Disclosures

Where necessary we may disclose to external bodies, relevant items of your personal data as set out below.

Disclosure to:Details:
Professional bodiesFor the purposes of confirming your qualifications and the accreditation of your course.  These professional bodies will include UKCP, BPC, BACP
WPF Therapy ValidationFor student & trainees attending a WPF Therapy validated course, information on assessment will be provided to the validating University
Therapy Clients General Practitioner (GP) or safeguarding authorities

WPF Therapy may from time to time make other disclosures without your consent. However, these will always be in accordance with the provisions of the General Data Protection Regulation and your interests will be considered.

Unwanted communication

We will from time to time communicate with you by email, post and telephone. If, at any stage, you are concerned about the content of these communications, e.g. unwanted marketing information, or wish to change the method of communication that we use please unsubscribe to general email communications. If you are unsuccessful in unsubscribing from our communications and/or remain concerned, please contact our Data Protection Officer.

Please see https://ico.org.uk for further information on the above rights.

You have a right to complain to the Information Commissioner’s Office about the way in which we process your personal data. Please see https://ico.org.uk/.

Further information can also be obtained from the Information Commissioner’s Office.

You can contact us at any time to:

  • Request access to information that we hold about you
  • Correct any information that we hold about you
  • Delete information that we have about you.

**Please allow 14 working days for us to respond to your questions.

If you have any additional questions about WPF Therapy’s collection and storage of data, please contact our Data Protection Officer Yetunde Aroloye by email: dataprotection@wpf.org.uk

Changes to this privacy policy

WPF Therapy Limited reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations.

A copy of this privacy policy can be downloaded here.