The Midlands Dissociation & Depersonalisation Centre (MDDC) takes clients’ privacy seriously.  We are committed to protecting your privacy and handling your information in a responsible way while you use our website and services. MDDC wants you to understand that this is a safe place for you to discuss your concerns, and that we operate in a highly confidential environment. This policy sets out how data is collected and processed through the use of our website and when you use our services.

We encourage you to read this policy alongside any other privacy notices we might provide, so you are fully informed about how and why we use your information. 

Data controller

The controller of your data is Dr Emma Cernis, trading as the Midlands Dissociation & Depersonalisation Centre and can be contacted on: info@midlands-ddc.com

Concerns & complaints about data security 

Please speak to us if you have any concerns about the security of your data. You also have the right to contact the Information Commissioner's Office (ICO) at (www.ico.gov.org.uk), but we hope to resolve any issues directly.

Types of data collected 

‘Personal data' is information that identifies you. If we have removed your identity (by making the data anonymous), it will not be classed as personal data. We may collect, use, store, and share various types of personal data about you as follows:

• Identity details such as first and last name, username or similar identifier, marital status and title, date of birth, gender, and ethnicity.

• Contact details such as your postal or billing address, email address, and telephone number.

• Technical information such as your internet protocol (IP address), your login data, browser type, version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access our website. 

• Financial information such as your bank account and payment card details (if paying for our services online).

• Information about transactions like details of payments to and from you, and other details of products and services you have purchased from us. 

• Account details such as your username, password, purchases or orders made by you, and your interests, preferences, feedback, and survey responses.

• Usage information about how you use our website, products, and services.

• Marketing information such as your preferences on receiving marketing from both us and third-parties, along with your communication preferences.

• Special Category Data:  Includes information about your health, including information about your existing and previous medical health conditions, medication details, psychiatric history, and any other relevant health information to enable us to carry out our services to you.  We do not collect any other Special Category Data about you (this includes details about your religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Consents for health data:  We require your specific consent to process Special Category Data so, when you submit your details, we will ask you to confirm your consent to this processing.

Methods of personal data collection

We use different methods to collect data from and about you. The majority of the time, our information is collected directly when you contact us in the following ways:

• When you fill in any new client onboarding forms;

• When you complete any forms before or during an appointment;

• Verbally during discussions;

• Correspondence with us via post, phone, email, or otherwise;

• When you apply for our services or any of our products;

• When you subscribe to our service or publications; 

• When you request marketing communications to be sent to you; or

• When you give us feedback, or contact us. 

Another method we may use to collect data includes the use of automated technologies or interactions, like website cookies or other similar technologies. This includes information about your equipment, browsing actions and patterns and information about your browsing activity if you visit another website that uses the same cookies as us. This means we receive information about how you use these third-party websites.

This data collection helps us to improve user experience, and to gather information about how you use our website. For more information, please refer to our Cookie Policy. 

We may also receive data from third-parties such as:  

• Technical information from Analytics providers such as Google. 

• Advertising networks such as Meta advertising.

• Search information providers such as Google.

What happens if you do not provide us with the required data?

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us - but we will notify you if this is the case at the time. 

Purposes for using your personal data

The purposes for which we will be using your data include:

• To register you as a new client.

• To provide our services, including: a) to manage payments, fees and charges and b) to collect and recover money owed to us.

• To manage our relationship with you e.g., to notify you about changes to our terms of this privacy policy or to ask you to leave a review and/or take a survey.

• To send you relevant marketing information about our products and services.

• To administer and protect our practice and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).

• To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.

• To use data analytics to improve our website, products/services, marketing, client relationships and experiences.

We rely on one or more of the following lawful conditions to process your data as outlined above: 

• To fulfil our contract with you;

• For our legitimate interests; or

• To comply with legal obligations. 

In some scenarios, we will ask for your consent, especially for collecting sensitive data. We may process your personal data for more than one lawful reason at a time, depending on the specific purpose for which we are using your data.  If you would like more information on the specific legal ground we are relying on, or occasions where we rely on more than one legal ground, please feel free to contact us. 

Cookies

Cookies help make our website work better for you, remembering your preferences and improving your experience. You can control cookie settings in your browser.  Cookies make your browsing experience on our site as smooth as possible, because they remember your preferences. 

Our website uses cookies to distinguish you from other users of our website. Please refer to our Cookie Policy to learn more.

Data for marketing purposes

If we send you marketing communications and you no longer wish to receive them, you can opt out anytime by contacting us.  Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow the M-DDC). 

Third-party links

Our website might link to third-party websites, tools and apps. Clicking on these links may allow third parties to collect or share your data.  We do not control said websites and are not responsible for said websites’ privacy policies. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Sharing of your personal data 

We take your data security seriously and only allow certain people to access it.  We may share your personal data with the parties set out below for the purposes stated above.

• Service providers, acting as processors who provide IT and system administration services.

• Professional advisers including healthcare professionals, lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

• If you are referred by your health insurance provider then we may need to share details about your appointment schedule with your insurer for the purposes of billing and to provide treatment updates.

• As an HCPC accredited clinician, we are obliged to consult with another mental health professional for supervision purposes.  This is to ensure we reflect and improve on our clinical skills.  When discussing clients in supervision we only refer to clients by their first name and identifiable information is minimised.

• Sometimes we may need to share details with your GP or a social worker.  We will always ask for your consent prior to doing this.  When the information concerns risk of harm to you or another person then we may need to disclose information about you without your consent for your own safety or for the safety of someone else.  

• HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.

All of the above third parties have a requirement to respect the security of your personal data. We do not permit them to use your personal data for their own purposes – they are only permitted to process your data for specified purposes in line with our instructions. 

International transfer of data

We may transfer your data outside of the United Kingdom/EEA, but only when we can be sure it is protected.

Many of our external third parties are based outside the United Kingdom/EEA (e.g., Google for use of Google Drive) and so their processing of your personal data will involve a transfer of data outside the United Kingdom.

Whenever we transfer your personal data out of the United Kingdom, we make sure it is protected by at least implementing one of the following safeguards:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the United Kingdom

• Where we use certain service providers, we may use specific contracts approved by the UK Information Commissioner’s Office and the European Commission which give personal data the same protection it has in Europe. 

Please contact us if you want further information on the specific process used by us when transferring your personal data out of the United Kingdom. 

Data security

We have strong security measures in place to keep your personal information safe. Only authorised individuals who have a need to know are granted access to your data, such as our employees or trusted partners. They will process your data in accordance with our confidentiality terms.

In the rare circumstances that there is a personal data breach, we have procedures in place and will notify you, along with any applicable regulator, according to law.

Data retention process

We only keep your data as long as necessary for the reasons we collected it. 

By law we have to keep medical information about patients for 7 years after treatment has finished. For any children we treat, we are obliged to retain the medical information until the child’s 25th birthday. By law we have to keep basic information about our clients (including contact, identity, financial and transaction data) for six years after they cease being patients, for tax purposes. 

For information that does not fall under the definition of ‘basic’, to determine the appropriate retention time, we look at what kind of data it is, how sensitive it is, the risks if it is misused, why we need it, and if there are other ways to achieve the same goals. We also consider applicable legal, regulatory, tax, accounting, and other requirements.

Your legal rights

You have the following rights regarding your personal data: 

Access: You can request a copy of the personal data we hold about you. This is known as a "data subject access request." 

Correction: If the personal data we have about you is incomplete or incorrect, you can ask us to correct it. 

Erasure:  You can ask us to delete your personal data. It is important to note, however, that there might be legal reasons that prevent us from fulfilling this request. If such reasons exist, we will inform you when you make your request. 

Objection: In certain situations, you have the right to object to the processing of your personal data.

Restriction of Processing: You can request that we restrict the processing of your personal data under specific circumstances. 

Data Portability: You have the right to request the transfer of your personal data directly to you or to a third party of your choice. 

Withdrawal of Consent: At any point where we rely on your consent to process your personal data, you have the right to withdraw this consent. Withdrawal of consent will not affect the legality of the processing done before the consent was withdrawn. Should you withdraw your consent, we might be unable to provide you with certain products or services. We will inform you if that is the case when you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us. 

We will not charge any fees for you to request access to your personal data. However, a reasonable fee may be charged if your request is clearly unjustified, repetitive or excessive. We also reserve the right to not comply in this scenario. We try to respond to all legitimate requests within one month. Occasionally it could take longer than one month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. 

Changes and Contact

We regularly review our privacy policy. Please keep us updated if your personal data changes. If you have any questions or need to exercise your rights, please get in touch.

Thank you for reading our privacy policy.

If you have any questions please do not hesitate to contact us.