Privacy Policy

At The Epione Clinic, we understand that we have a responsibility to protect and respect your privacy and look after your personal data. This Privacy Notice explains what personal data we collect, how we use your personal data, reasons we may need to disclose your personal data to others and how we store your personal data securely. Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR). For clarity, The Epione Clinic may be both data controller and data processor for your personal data under certain circumstances. In this document, “we”, “our”, or “us” refer to The Epione Clinic.

We must advise that this policy is subject to change, so please check our website on a regular basis for any further changes.

Who are we?

The Epione Clinic provides therapeutic rooms for talking and holistic therapists to rent on an ongoing basis in Salisbury. The Epione Clinic is a trading name of Epione (Salisbury) LLP, who have a registered address as 30, New Canal Street, Salisbury, SP1 2AQ. Our company number is OC451556 .

How the law protects you

Data protection laws state that we are only able to process personal data if we have valid reasons to do so. The basis for processing your personal data includes, but is not limited

to, your consent, correspondence of a license agreement, to enable billing and remittance, and to contact you for customer service purposes.

How do we collect personal data from you?

We collect personal data in the following ways:

1. Information we process because we have a contract with you: When you become a therapist at The Epione Clinic, a contract is formed between you and us. The service we provide to you necessarily entails you providing us with personal information. We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract. If you provide us with personal data about a third party, you warrant that you have obtained the express consent from the third party for the disclosure and use of their personal data. We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.

2. Information we process with your consent: Through certain actions when otherwise there is no contractual relationship between us, such as when you ask us to provide you with more information about our services, either as a potential client or therapist, you provide your consent to us to process information that may be personal information. Wherever possible, we aim to obtain your explicit consent to process this information. Sometimes you might give your consent implicitly, such as when you write to us requesting a response.

We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.

You may withdraw your consent at any time by writing to us at our registered office or by e-mail at info@theepioneclinic.co.uk. If you do so, we shall not be able to provide our services further.

3. Information we process for the purposes of legitimate interests: We may process information on the basis there is a legitimate interest, either to you or to us, of doing so. Where we process your information on this basis, we do after having given careful consideration to:

o whether we could achieve the same objective by other means

o whether processing (or not processing) might cause you harm

o whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so

For example, we may process your data on this basis for the purposes of:

o record-keeping for the proper and necessary administration of our business

o protecting and asserting your rights, our rights, or the rights of any other third party

o insuring against or obtaining professional advice that is required tomanage business risk

o protecting your interests where we believe we have a duty to do so

4. Information we process because we have a legal obligation: We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation. For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or

court order. This may include your personal information.

What type of data do we collect from you?

During initial enquiries, the personal data that we may collect from you may include your name, email address, phone numbers, and professional background. We collect the data you have given to us in order to reply with the information you need. We record your request and our reply in order to increase the efficiency of our business.

When joining us as a therapist at The Epione Clinic, we may also collect from you your home/work address, website and copies of your qualification certificates, insurance certificate, and professional membership Whether correspondence is from initial enquiries, or ongoing room rental, we record personally identifiable information associated with any correspondence we have with you so as to be able to track our communications with you to provide a high quality service.

Why do we collect your data?

We use information about you in the following ways:

Clients

 To provide customer care, including responding to your requests if you contact us with a query

 To carry out marketing and statistical analysis;

 To provide you with information about products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes;

 To inform you of service and price changes;

Therapists

 To process your license agreement;

 To help us identify you;

 To provide customer care, including responding to your requests if you contact us with a query;

 To administer accounts, process payments and keep track of billing and payments;

 To carry out marketing and statistical analysis;

 To review room rental applications;

 To provide you with information about products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes;

 To inform you of service and price changes;

 To comply with our contractual obligations we have with you.

How long will we keep your data?

Personal data collected from initial enquiries may be stored for up to 1 years so as to be able to affectively respond to you should you contact us again.

We will keep your personal data for the duration of the period you hold a Therapist’s License Agreement. We shall retain your data only for as long as necessary in accordance

with applicable laws. On ending your license agreement, we may keep your data for up to 1 years. We may keep it for research or statistical purposes. We assure you that your personal data shall only be used for these purposes stated herein.

We may not be able to delete your data before this time due to our legal and/or accountancy obligations.

Who has access to your personal data?

Your personal data is stored either as hard copy in a locked filing cabinet, or electronically with password protection, which is accessible to the owners of The Epione Clinic.

Where we store your personal data:

We follow accepted ISO standards to store and protect the personal data we collect, including the use of encryption if appropriate.

Do third parties have access to your data?

For the avoidance of doubt, we do not and never shall sell your personal data to third parties for marketing or advertising purposes. We may share your personal data if we are under a duty to disclose data in order to comply with any legal obligation or to protect the rights, property, or safety of The Epione Clinic, our customers, or others. This includes but is not limited to exchanging information with other companies and organisations for the purposes of fraud protection, credit risk reduction and dispute policies. However, we will take steps with the aim of ensuring that your privacy rights continue to be protected.

Your rights

In preventing the use or processing of your personal data, it may delay or prevent us from fulfilling our contractual obligations with you. You have the right to object to our use of your personal data, or ask us to delete, remove or stop using it if there is no need for us to keep it. This is known as your right to be forgotten. There may be legal and accountancy reasons why we will need to keep your data, but please do inform us if you think we are retaining or using your personal data incorrectly.

Our Privacy Notice shall be made clear to you at the point of collection of your personal data.

We will not contact you for marketing purposes unless you have given us your prior consent.

Accessing and updating your data

You must maintain the accuracy of your information and ensure all your details, including but not limited to, name, address, phone number, and e-mail address are kept

up to date at all times. You must do this by contacting the owners or by e- mailing info@theepioneclinic.co.uk.

You have the right to access the information we hold about you. Please email your requests so that we can obtain this information for you.

At any time you may review or update or request that we remove personally identifiable information that we hold about you. To obtain a copy of any information you may send us a request at info@theepioneclinic.co.uk. After receiving the request, we will tell you when we expect to provide you with the information. This will be within one month of the request. When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or

otherwise taking any action. This is important to safeguard your information.

Use of cookies

Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page

to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the

website so that it can be improved. Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely. Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use. Our website and online booking system uses cookies. They are placed by software that

operates on our servers, and by software operated by third parties whose services we use.

We use the following cookies: When you first visit our website, we ask you whether you wish us to use cookies. If you choose not to accept them, we shall not use them for your visit except to record that you have not consented to their use for any other purpose.

If you choose not to use cookies or you prevent their use through your browser settings,

you may not be able to use all the functionality of our website. We agree to take reasonable measures to protect your data in accordance with applicable laws.

Data Breaches

In the event of a data breach, we shall ensure that our obligations under applicable data protection laws are complied with where necessary.

Please e-mail any questions or comments you have about privacy to us at info@theepioneclinic.co.uk

Your right to make a complaint If you are not happy with our privacy policy or if you have any complaint with respect to how we process your personal information then you should tell us by email. Our address is info@theepioneclinic.co.uk. If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.

If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office. This

can be done at https://ico.org.uk/concerns/

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Tel: 0303 123 1113

Your Data Protection Rights under the GDPR you have the right to:

1. Access any of the information that we collect.

2. Know if your personal information has been forwarded to a third-party (such as a fellow healthcare professional, consultant or GP.)

3. Have any invalid information about you corrected.

4. Have your personal data deleted by us if requested.

5. Prevent further use (or processing) of your information.

6. Ask your therapist to send you (or your new therapist) your personal information in an open electronic format like a .csv file or text file.

7. Request that we and/or your therapist stops sending you any marketing information.

8. Ensure that any profiling that is undertaken using your personal data is fair, appropriate, statistically valid and transparent.

9. Expect your therapist to take appropriate measures to protect your data.

Be notified if critical information about you was inappropriately accessed and was deemed to be a critical breach.

10. Not to have your personal information transferred outside the EU.

11. Know how your personal information is being used by your therapist