As You Are Play and Creative Arts Therapy Privacy Policy

2. What information we collect, use, and why

We collect or use the following information to provide services and goods, including delivery:

• Names and contact details
• Addresses
• Date of birth
• Health information (including dietary requirements, allergies and health conditions)
• Website user information (including user journeys and cookie tracking)
• Records of meetings and decisions

We also collect or use the following special category information to provide services and goods, including delivery. This information is subject to additional protection due to its sensitive nature:

• Racial or ethnic origin
• Religious or philosophical beliefs
• Health information

We collect or use the following information to comply with legal requirements:

• Name
• Contact information
• Any other personal information required to comply with legal obligations
• Safeguarding information

3. 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 services and goods 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.
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.
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:

• To be able to provide the therapy service safely and ethically for the child and families.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

Our lawful bases for collecting or using personal information for legal requirements 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.
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.
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:

• To be able to provide the therapy service safely and ethically for the child and families.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

4. Where we get personal information from

• Directly from you
• Schools, colleges, universities or other education organisations
• Councils and other public sector organisations

5. How long we keep information

Until the child accessing therapy or other services becomes an adult at 18 years old plus six additional years until age 24 years, in accordance with the current law of limitation.

Enquiry data and initial meetings that do not lead to therapy or other services offered will be deleted after twelve months allowing people to review services.

6. Who we share information with

Joint data controllers

We have a joint controller relationship with PTUK Fortuna Database. We process your personal information with that joint controller for the following reason: Client notes onto the PTUK Fortuna secure database once therapy has begun.

Others we share personal information with

• Organisations we need to share information with for safeguarding reasons
• Organisations we’re legally obliged to share personal information with