Privacy Policy

Hello there!

Thank you for checking out our privacy policy.  At Evolve Rehabilitation & Therapy we take our client’s privacy seriously.  We’re committed to protecting your privacy and handling your information in a responsible way while you use our website and services. We want you to understand that this is a safe place for you to discuss your feelings and concerns, and 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’re fully in the loop about how and why we use your information.

Who’s in charge of your data?

We are registered with the ICO as a data controller and our registration number is ZB268383.  Our data controller is Dr Clare Churchman and she can be contacted by email at hello@evolverehabtherapy.co.uk

Not happy with something?

Let’s chat and try to fix it. You’ve also got the right to talk to the Information Commissioner’s Office (ICO) at (www.ico.gov.org.uk), but we hope to resolve any issues directly.

What type of data do we collect about you?

‘Personal data’ is information that identifies you. If we’ve removed your identity (by making the data anonymous), it won’t be classed as personal data. We might collect, use, store, and share various types of personal data about you as follows:

• Identity details such as your name, title, date of birth and gender.
• Contact details such as your 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.
• Information about transactions like details about payments to and from you, and other details of services you have purchased from us.
• Usage information about how you use our website and services.
• Marketing information such as your preferences on receiving marketing from us, along with your communication preferences.
• Performance and Physical Data: information about physical and fitness performance metrics, movement analysis data (including video recordings with explicit consent), training history, injury details, and relevant lifestyle information.
• Health Data: Includes information about your health, including information about your existing and previous medical health conditions, physical assessment and examination findings, information about physical disabilities, impairments or limitations,  imaging results, diagnostic tests or medical reports relevant to physiotherapy or sports therapy treatment, medication details, psychiatric history and any other relevant health information to enable us to carry out our services to you. 
• Supervisee Data: Includes name, contact details, professional registration details, supervision session notes.

We do not routinely request any other Special Category Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership and genetic and biometric data). However, any such information you choose to share during sessions will form part of your confidential health record. We do not collect any information about criminal convictions and offences.

Consents for Health Data:  We require your specific consent to process health and performance data so, when you submit your details, we will ask you to confirm your consent to this processing.  Please note that if you do not consent to us processing your health data, we will be unable to provide our services to you, as this information is essential for us to deliver safe and effective treatment.

How do we collect your personal data?

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 enquire about and/or apply for our services;
• When you fill in any new client onboarding forms;
• When you complete any forms before or during an appointment;
• Verbally during discussions and therapy sessions;
• Correspondence with us via post, phone, email or otherwise;
• When you correspond with us via social media;
• When you subscribe to our service;
• When you attend one of our supervision sessions;
• When you request marketing communications to be sent to you; or
• When you give us feedback or contact us.

We may also receive information about you from third parties, such as your GP, members of your support team (e.g. sports coach, physio, performance lifestyle coach, etc.) or family members.

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, which can be accessed here.

What are the purposes for which we use your personal data?

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

• To register you as a new client.
• To provide our psychology therapy, physiotherapy, sports therapy, consultancy and supervision services and to process and deliver any orders, 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.
• To email you.
• To send you relevant marketing information about our 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 to you and measure or understand the effectiveness of the content we serve to you.
• To use data analytics to improve our website, services, marketing, client relationships and experiences.
• To make suggestions and recommendations to you about services that may be of interest to you.

We use email to correspond with our clients and those working with them (hello@evolverehabtherapy.co.uk).  Our clients email address and correspondence will be stored temporarily in a password protected Outlook email account and transferred into the client’s health record on WriteUpp, after which the information will be deleted from the email account.

If you use the contact form on our website, this information will be sent to the same email address.  We also use telephone, text and WhatsApp to correspond with clients who have consented to this type of contact. This means that clients’ telephone numbers may be stored on pin protected mobile phones used by us whilst they are receiving treatment. It will be deleted once their episode of care has ended.

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’ll ask for your consent, especially for collecting health 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’d like more information on the specific legal ground we are relying on, on occasions where we rely on more than one legal ground, please feel free to contact us.

Do we use 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 here to learn more.

AI Usage

Artificial Intelligence (AI): We may use AI tools to assist with the provision of our services, including transcription of therapy sessions, data analysis, drafting documents, responding to enquiries, etc. Any AI tools we employ are used in compliance with applicable data protection laws, including the UK General Data Protection Regulation (UK GDPR).

When using AI tools, we ensure:

• Personal data is processed lawfully, fairly, and transparently.
• Data minimisation principles are upheld, meaning we only provide AI tools with the information strictly necessary for the intended purpose.
• Robust security measures are in place to protect your personal data during any processing involving AI tools.
• When using AI tools, we ensure that personal data is retained only for as long as necessary to fulfil the purposes outlined in our policy, after which it is securely deleted or anonymised.

We have listed below the specific AI tools we are using within our business, the purpose, the types of data we are collecting and our legal basis for this processing.

For further enquiries on our AI usage or to exercise your rights, please contact us using the details provided in this policy.

Do we use your 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 or clicking on the ‘unsubscribe’ button on our marketing communications.  Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our practice).

Do we use 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.

Do we ever share your personal data?

We take the security of your data seriously and only allow certain people to access it.  Health professionals have a duty of confidentiality to their clients, which means that we will always be in conversation with you about what you would like to share and what you would like to remain confidential. However, we do have a responsibility to share information with authorities in exceptional circumstances if we have legitimate concerns about your safety or the safety of others.

We may also share your personal data with the parties set out below for the purposes as stated further above.

• Associate Healthcare Practitioners: we work with associate healthcare practitioners (such as psychologists, physiotherapists, and sports therapists) who provide services as part of Evolve. We may share your relevant health and contact information with these associates to enable them to provide you with treatment and ensure continuity of care. All associates are bound by the same professional duties of confidentiality and data protection standards as outlined in this policy.
• Service providers, acting as processors who provide IT and system administration services.
• We use a cloud-based electronic health record system called WriteUpp to store the information that we need to provide you with a service. WriteUpp is ISO27001 certified and complies with this globally recognised information governance and security standard. Your data is encrypted and stored within the E.U, which is covered by the GDPR. You can find out more information about your data in WriteUpp here: How Do You Handle Patient Confidentiality & Data Security? | WriteUpp Helpdesk
• We use a password protected cloud based financial system called FreeAgent to store and use information relevant to our payments. This information includes your name and contact details but not your medical information. You can find out more about FreeAgent’s compliance with GDPR here: FreeAgent and GDPR compliance – FreeAgent
• We use Zoom to record our online sessions (if this is something we have discussed, and you have consented to). This is a GDPR compliant video conferencing platform. We have a password protected Zoom account and will set up your appointments should we decide together to use this. You can read more about Zoom’s privacy policy here: European Union’s General Data Protection Regulation (GDPR) | Zoom
• We use Dropbox to store the recordings of sessions (if this is something we have discussed, and you have consented to). Dropbox is a cloud storage facility that complies with the most widely accepted standards and regulations (i.e. ISO 27001) and is GDPR compliant. You can find out more about Dropbox here: DBX GDPR Compliance Journey_2020_updated.pdf
• 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 or healthcare professionals on an athlete national program, 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 a Health and Care Professions Council (HCPC) and Society of Sports Therapists (SST) accredited clinicians, we are obliged to consult with another 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, sports coach or other relevant people who are supporting you. We will always get 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.  We would discuss this with you wherever possible.  This may include situations where we have reason to believe that a child, young person, vulnerable or incompetent adult is at risk of neglect, abuse or other serious harm, or where we are required to disclose information under a court order or other legal process.
• If you are referred to another psychologist, physiotherapist, sports therapist or other healthcare professional for specialist care or assessment, your relevant information may be shared with them to ensure continuity of care and appropriate treatment.
• HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
• Debt collection agencies in the event that payment is not received for services rendered. This will be done to recover any outstanding debts, and the debt collectors will process your data solely for this purpose.

Do we ever transfer your data internationally?

Some of the secure platforms and software we use to provide our services store data on servers located outside the United Kingdom (for example, in the United States or other countries). This means that when we use these platforms, your personal information may be stored internationally. This is common practice for many widely-used, secure systems like cloud storage, video conferencing, and electronic health record platforms.

Don’t worry – we only use platforms and service providers that have strong security measures and data protection standards in place. We make sure your data is protected when stored internationally by:

• Only using service providers based in countries that the UK government has approved as providing adequate data protection; or

• Ensuring our service providers have signed special contracts approved by the UK Information Commissioner’s Office that require them to protect your data to the same standards as if it were stored in the UK.

Examples of services we use that may store data outside the UK include Zoom, Dropbox, WriteUpp.

If you’d like more detailed information about where your data is stored or the specific protections in place, please feel free to contact us.

How secure is your data with us?

As healthcare professionals, we are bound by the ethics and guidance of our respective professional bodies, as well as UK law on data protection and UK GDPR. The information we need and the notes we take form a legal record of treatment and must be retained safely and securely and for no longer than is necessary.

We have strong security measures in place to keep your personal information safe.  Any third party software or systems we use are all UK GDPR compliant and have strong privacy protections in place.  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, when we’re legally required to.

What is our process for retaining your data?

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 25^th 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.

If you contact us with an initial enquiry and share personal details, but do not then become a client, we will delete your personal information after four weeks. If you confirm you do not want to pursue a service within those four weeks we will destroy the information immediately.

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’s 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.

What are your legal rights in relation to your data?

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’s 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 won’t 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 us longer than a 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, just get in touch.

Thanks for reading our privacy policy. If you have any questions, please don’t hesitate to contact us.