
Connect, Reflect, Grow - Privacy Policy
Our contact details
Name: Connect, Reflect, Grow - Supervision
Contact: Rebecca Woods
Address: Available on request
Phone Number: 07468 980957
E-mail: hello@connectreflectgrow.co.uk
This Statement outlines the type of personal information we collect and process. Personal information is any information that relates to an identified or identifiable individual.
We are registered with the Information Commissioner’s Office (ICO) and our registration number is ZB285925
Our purpose for processing personal information is to fulfil the contractual obligations of clinical supervision, including record keeping.
The type of personal information we collect
We currently collect and process the following information:
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Personal identifiers, contacts and characteristics (for example, name and contact details)
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Information relating to your job role /place of work
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Information discussed during supervision sessions, which will be written up in the form of supervision notes.
How we get the personal information and why we have it
Most of the personal information we process is provided to us directly by you & is processed for one of the following reasons:
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To enable supervision sessions to be booked and facilitated
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To enable supervision notes (or related information) to be sent to you following completion of sessions
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Contractual obligations of clinical supervision not outlined above
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On occasion, personal information we process is provided to us by a relevant third party (e.g. UMHAN – University Mental Health Advisor’s Network). In these instances, personal information (e.g. name, contact details) are received by us only after you have made contact with the third party, and consented to your personal information being shared with Connect, Reflect, Grow. We use this information for the reasons outlined above.
Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing personal information are:
1) Your consent.
You are consenting for your contact details, together with general information about your work role and place of employment, to be shared with Connect, Reflect, Grow. You are also consenting to follow the conditions as set out in the supervision contract.
You can remove your consent at any time. You can do this by contacting Connect, Reflect, Grow.
2) We have a contractual obligation.
Please refer to the Connect, Reflect, Grow supervision contract, specifically “Documentation” and “Confidentiality.”
3) We have a legal obligation.
Rebecca Woods is an Occupational Therapist and is registered with the Health and Care Professions Council (HCPC). Occupational Therapist is a designated title protected by law within the United Kingdom, and all registrants of the HCPC are required to follow and meet standards of conduct, performance and ethics.
Supervisees will also be members of a Professional Body which will entail following and meeting standards of conduct, performance and ethics.
Should any information be disclosed during the supervision process pertaining to the safety of clients/staff/other associated individuals, information may need to be shared by the supervisor and /or supervisee with relevant third parties / external agencies. Please refer to “confidentiality” within the Connect, Reflect, Grow supervision contract.
4) Legitimate interests
Connect, Reflect, Grow may on occasion engage in marketing (including promoting our services) or our own internal processes. In these instances, your contact details would be needed so that we can communicate with you. Information will only be shared on a needs-to-know basis, and your interests, rights and freedoms will be considered at all times.
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We may on occasion have need to share information disclosed as part of clinical supervision, in line with our Confidentiality Clause:
If concerns are identified during supervision, the supervisor will have a duty of care within their code of ethics and conduct to act accordingly and raise these concerns. This would usually involve raising concerns and actions with the supervisee but in instances of safeguarding, child protection and safe practice this may involve sharing concerns with the supervisee’s employer / relevant external statutory agency.
Connect, Reflect, Grow will endeavour to always empower and support supervisees within this process.
Special Category Data
Clinical supervision may involve processing information pertaining to the physical or mental health of supervisees or the clients they support. This is known as Special Category Data. Special category data is personal data that needs more protection because it is sensitive.
Purposes
Whilst providing clinical supervision, it may on occasion be deemed necessary to share information relating to the mental or physical health of clients or supervisees with relevant individuals and/or external agencies. This could include an employer or healthcare provider, for example.
When processing such information, Connect, Reflect, Grow would rely on the following lawful bases:
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the legal obligation Rebecca Woods is subject to as a HCPC registered Occupational Therapist
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to protect the vital interests of the data subject (supervisee or client) or of another person as appropriate.
(UK GDPR Article 6:1 c and d)
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to carry out the obligations or exercise specific rights of either myself as Supervisor or the Supervisee within our fields of employment
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to protect the vital interests of the supervise or client, or another natural person, where the supervisee or client is physically or legally incapable of giving consent
(UK GDPR Article 9:2 b and c)
Connect, Reflect, Grow would also rely on the following specific public interest conditions:
DPA (Data Protection Act) 2018
Schedule 1, Part 2, Chapters 17 & 18
How we store your personal information
Your information is securely stored electronically and is password protected.
We keep copies of supervision notes for 3 years. We will then dispose of your information by deleting all associated files.
Your data protection rights
Under data protection law, you have rights including:
Your right of access - You have the right to ask us for copies of your personal information.
Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.
Your right to object to processing - You have the the right to object to the processing of your personal information in certain circumstances.
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, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
Please contact us at hello@connectreflectgrow.co.uk if you wish to make a request.
Glossary
Data controller
A person, agency or public authority who alone, or when joined by others, determines the purposes of personal data and the means of processing it (Rebecca Woods)
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Date processor
A person, public authority or agency who processes personal data on behalf of the controller (Supervisor)
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Data subject
Any living individual whose personal data is collected, held or processed by an organisation (Supervisee or Client/s)
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DPA
Data Protection Act (2018) controls how personal information is used by organisations, businesses, or the government. Implementation of the UK GDPR (General Data Protection Regulation).
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HCPC
Health and Care Professions Council (UK statutory regulator for 15 health and social care professions)
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Natural person
Living and breathing individual human being
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Personal data or information
Any information related to an identified or identifiable natural person
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Processing
Gathering, processing or use of personal data by a processor
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Special category data
Personal data containing sensitive information e.g., health related
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UK GDPR
General Data Protection Regulation – legal framework within the UK guiding collection and processing of personal data
Vital interests
Things that are essential for someone’s life (vital interests are most often associated with provision of medical care).
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How to complain
If you have any concerns about our use of your personal information, you can make a complaint to us at Connect, Reflect, Grow.
E-mail: hello@connectreflectgrow.co.uk
You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk
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