Spring to Life is committed to ensuring the privacy of the information you give us, whether you are someone receiving therapy from us, or interested in hearing about or involved in any of our community projects. We endeavour to keep your personal information safe, only share it where and when necessary, and with your consent.
Spring to Life are a “data controller” for the purposes of the Data Protection Act 1998 and (from 25 May 2018) the EU General Data Protection Regulation 2016/679 (“Data Protection Law”). This means that we are responsible for, and control the processing of, your personal information.
The following document outlines how we collect, store and process information you give us, and highlights the rights you have in regards to this.
For more information, questions or to raise any concerns please contact us:
1) What information we hold and why we use it
The type of information we hold about you will depend on whether you receive therapy from us or whether you are involved in our community projects.
If you receive counselling or other types of personal therapy from us free of charge via the IAPT or FTB (Forward Thinking Birmingham) schemes, we will take the following information from you: personal contact details, GP information, physical and mental health history, sexuality, gender, religion. We also take and process information about your current mental health through a short questionnaire. All this information is a requirement to fund your therapy through the IAPT and FTB schemes. The mental health questionnaire is also to determine eligibility for therapy and measure changes throughout the therapeutic process.
If therapy is received through a private contract between ourselves and an organisation you are associated with, we will take your main contact details. This will be to arrange therapy appointments or to inform you of other opportunities. You can inform us at any point that you no longer wish to be contacted about these. We may also take details of next of kin, GP, care team (if applicable), and any health conditions you have have. This information is in the case of an accident or health incident, where relevant people can be contacted.
As well as us processing your information to deliver therapies, we may also use your contact details to inform you of other therapeutic and community opportunities offered by Spring to Life. This will be only with your consent, and after you give consent for this, you can withdraw the consent at any time.
For the various community projects we run, we hold a list of people who have actively chosen for us to update them about projects we hold. The information will be name, contact details, and any project you may already be part of.
This will be simply to update you on future events. If any point you wish to be removed from this list and not receive more updates, you can simply contact us. It may also be to connect you to projects in your area or of your interest.
2) Legal basis for holding your information
Every organisation who uses and processes personal information must have a lawful reason for doing so. One of these is termed ‘legitimate interests’, and it is what applies to Spring to Life and how we process your information. ‘Legitimate interests’ means that Spring to Life have a legitimate interest in using the information you give us. This interest is Spring to Life’s aim to promote and well-being for people and communities in the West Midlands.
Another core legal basis for Spring to Life to use your data is what is termed ‘special category data’. This is for information that is deemed as sensitive personal information, and could include things like physical and mental health history, sexual preference, religion, etc. The condition used within this legal basis is:
(h) (Article 9(2) of the GDPR ) “processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of Union or Member State law or pursuant to contract with a health professional and subject to the conditions and safeguards referred to in paragraph 3”.
3) How we store your information safely
Paper copies of information about you is stored securely in a locked filling cabinets at one of Spring to Life’s associate/therapist’s offices.
Data is also held in a secure online NHS database (DCRS), managed by the Living well Consortium. Electronic data is also held by us in an encrypted format (i.e. password protected), and within devices that are also password protected.
After completion of therapy Spring to Life shred your paper details except the ‘permission to hold data signature’ which is kept for the duration of the IAPT contract. IAPT data, which is down loaded onto the DCRS encrypted data base run by Living Well Consortium is kept for the duration of the IAPT service. Usually Therapists keep minimum records of your attendance for 7 years after which time this information will be destroyed. Therapists ‘Process Notes’ are their own practice notes and for their personal supervision purposes only.
If we hold your information for one of our projects, we will store your information for the duration of that project. With your consent we may retain your information to inform you of future projects.
4) Who do we share your information with
Spring to Life shares information within our organisation for the purposes of handing over relevant details to therapists involved in your treatment on a strictly‘need to know’ basis. Counsellors and other therapists who you see may, on rare occasions, have to share specific issues that you disclose to them if they regard you as posing any risk to yourself or others. In these cases we will share the information either with your GP, mental health care team, Social Services or in extreme circumstances the police. We will endeavour to inform you of our intention to share information before we do so.
Whenever we input information in the DCRS NHS database, it may get seen by staff at Living Well Consortium for the purposes of processing your information through the database. This is an umbrella organisation that we are part of and who have the same ethos as us. They will only use information to process it through the database.
Your data will never be shared with companies or other organisations without your consent.
5) Your rights
There are a number of key rights you have regarding our management of your personal information. (These are laid out by the European General Data Protection Regulation, and so also apply to any other organisation who hold your personal information). Any requests regarding these rights and your information can be made in writing or verbally via your Spring to Life therapist or by phoning the Spring to Life.
- The right to be informed
You have the right to be informed that we are collecting your data, why we are processing it, and who we may share it with. The information shall mostly be taken during people’s initial intake assessment with Spring to Life.
- The right of access
You have the right to obtain:
1. Confirmation that your data is being held by Spring to Life cic
- Access data about you held by Spring to Life cic.
- Other supplementary information.
This information will be provided free of charge, and within 28 of the request being made. We may charge if the request is excessive, repetitive, or unfounded. The fee will be based on the administrative cost of providing the information.
- The right to rectification
You can ask us, either verbally or in writing, to change inaccurate or incomplete information about you. The rectification will be done within 28 days from receipt of the request. If the request is complex or if it entails a number rectifications, the period can be extended to two months. In this case, the individual will be informed of this with an explanation of why this is the case.
- The right to erasure
You can make a request for information we hold to be erased where we no longer use it, you have withdrawn from treatment, or where we have no legal basis for holding it. For this to be done Spring to Life cic has to confirm your identity.
- The right to restrict processing
You can ask us to restrict the processing of the information, even though we may still hold it.
- The right to data portability
You have the right to obtain and reuse personal information we have of you across other services that you may be involved in.
- The right to object;
You can object to your data being processed where we are relying on a legitimate interest (or those of a third party already mentioned). You can also object to the processing of data for the purposes of marketing.
- The right not to be subject to automated decision-making including profiling.
Automated decision-making is when an organisation uses electronic/computer systems to make decisions based on your personal information without any human intervention. Unless you have given consent, it is your right not to be subject to this. Nevertheless Spring to Life does not currently carry out this type of decision-making.