Sensory foOTsteps

SENSORY FOOTSTEPS LIMITED – PRIVACY POLICY

Sensory Footsteps Limited, a company registered in England and Wales, with company number 13966133 (we, us or our), understands that protecting your personal data is important. This Privacy Policy sets out our commitment to protecting the privacy of personal data provided to us, or otherwise collected by us when providing our website and occupational therapy services (Services) or when otherwise interacting with you.

It is important that you read this Privacy Policy together with any other detailed privacy notices we may provide when we are collecting or processing personal data about you so that you understand our privacy practices in relation to your data.

The information we collect

Personal data: is information that relates to an identified or identifiable individual.

Where you are a parent or guardian of a client of ours:

We may collect, use, store and disclose different kinds of personal data about you which we have listed below:

· Identity Data including first name, last name, relationship to our client and CCTV footage captured on or around our premises.

· Contact Data including billing address, delivery address, email address and telephone numbers.

· Financial Data including bank account and payment card details (through our third party payment processor, Square).

· Transaction Data including details about payments to you from us and from you to us and other details of products and services you have purchased from us or we have purchased from you.

· Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.

We may also collect, use, store and disclose different kinds of personal data about your child which we have listed below:

· Identity Data including first name, last name, gender, date of birth, family make up (including number of family members), CCTV footage captured on or around our premises and languages spoken.

· Contact Data including residential address, school name and school address.

· Special Categories of Personal Data is a special category of personal data that includes details about an individual’s race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about their health and genetic biometric data. In providing our Services, we may collect and process special categories of personal data about your child’s health, including information about their symptoms, medical history and diagnosis, any medications or allergies, developmental history, feeding habits, behavioural and social skills, sleeping habits, and hobbies and interests.

· Visual Data including photographs and videos of your child recorded during a session with us.

Where you are a client of ours over the age of 18:

· Identity Data including first name, last name, gender, date of birth, family make up (including number of family members), CCTV footage captured on or around our premises and languages spoken.

· Contact Data including billing address, delivery address, email address and telephone numbers.

· Financial Data including bank account and payment card details (through our third party payment processor, Square).

· Transaction Data including details about payments to you from us and from you to us and other details of products and services you have purchased from us or we have purchased from you.

· Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.

· Visual Data including photographs and videos of you recorded during a session with us.

· Special Categories of Personal Data is a special category of personal data that includes details about an individual’s race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about their health and genetic biometric data. In providing our Services, we may collect and process special categories of personal data about your health, including information about their symptoms, medical history and diagnosis, any medications or allergies, developmental history, feeding habits, behavioural and social skills, sleeping habits, and hobbies and interests.

Where you are a user of our website:

· Technical and Usage Data including internet protocol (IP) address, your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour, information about your access and use of our website, including through the use of Internet cookies, your communications with our website, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider.

· Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.

· Professional data including where you are a worker of ours or applying for a role with us, your professional history such as your previous positions and professional experiences.

How we collect personal data

We collect personal data in a variety of ways, including:

· Directly: We collect personal data which you directly provide to us, including when you sign up to our services, through the ‘contact us’ form on our website or when you request our assistance via email, or over the telephone.

· Indirectly: We may collect personal data which you indirectly provide to us while interacting with us, such as when you use our website, in emails, over the telephone and in your online enquiries.

· From third parties: We collect personal data from third parties, such as from your referring third party, your parents or guardians, your healthcare practitioners, your school or other local authority (as applicable) and details of your use of our website from our analytics and cookie providers and marketing providers. See the “Cookies” section below for more detail on the use of cookies.

Purposes and legal bases for processing

We collect and process personal data about you only where we have legal bases for doing so under applicable laws. We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please reach out to us if you need further details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose of use / disclosure

Type of Data

Legal Basis for processing

To provide our Services to you or your child, including to manage your appointments, assess your progress, and record clinical documentation.

· Identity Data

· Contact Data

· Transaction Data

· Special Categories of Personal Data

· Visual Data

· Performance of a contract with you

· Consent

· Legitimate interests: to streamline the processes for our administrative tasks and improve our Services to you

To aid in training and educating members of staff.

· Identity Data

· Special Categories of Personal Data

· Visual Data

· Consent

· Legitimate interests: to develop our business and improve our Services to you

To use CCTV cameras for security, safety and quality assurance purposes.

· Identity Data

· Legitimate interests: to ensure the safety and security of our patients, staff and our premises

To contact and communicate with you about our Services including in response to any support requests you lodge with us or other enquiries you make with us.

· Identity Data

· Contact Data

· Performance of a contract with you

To contact and communicate with you about any enquiries you make with us via our website.

· Identity Data

· Contact Data

· Legitimate interests: to ensure we provide the best client experience we can offer by answering all of your questions.

For internal record keeping, administrative, invoicing and billing purposes.

· Identity Data

· Contact Data

· Financial Data

· Transaction Data

· Performance of a contract with you

· To comply with a legal obligation

· Legitimate interests: to recover debts due to us and ensure we can notify you about changes to our terms of business and any other administrative points.

For analytics, market research and business development, including to operate and improve our Services, associated applications and associated social media platforms.

· Technical and usage Data

· Legitimate interests: to keep our website updated and relevant, to develop our business, improve our Services and to inform our marketing strategy

For advertising and marketing, including to send you promotional information about our events and experiences and information that we consider may be of interest to you.

· Identity Data

· Contact Data

· Technical and usage Data

· Marketing and communications Data

· Legitimate interests: to develop our Services and grow our business

If you have applied to work with us; to consider your application.

· Identity Data

· Contact Data

· Professional Data

· Legitimate interests: to consider your employment application

To comply with our legal obligations or if otherwise required or authorised by law.

· All relevant Personal Data

· To comply with a legal obligation

If you have consented to our use of data about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your data because we or a third party have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using our services. Further information about your rights is available below.

Our disclosures of personal data to third parties

We may disclose personal data to:

· third parties who refer you to us, including your healthcare practitioners, school or local authority;

· our employees, contractors and/or related entities;

· IT service providers, data storage, webhosting and server providers such as WriteUpp, Google Workspace, Powerdiary and GoDaddy;

· AI scribe software providers such as Heidi Health;

· marketing or advertising providers such as GoDaddy;

· electronic health record systems (including practice management software) such as Writeupp;

· professional advisors, bankers, auditors, our insurers and insurance brokers;

· payment systems operators such as Square or Stripe;

· our existing or potential agents or business partners;

· anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;

· courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;

· courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;

· third parties to collect and process data, such as Google Analytics (To find out how Google uses data when you use third party websites or applications, please see www.google.com/policies/privacy/partners/ or any other URL Google may use from time to time), Facebook Pixel or other relevant analytics businesses; and

· any other third parties as required or permitted by law, such as where we receive a summons.

Google Analytics: We have enabled Google Analytics Advertising Features including Remarketing Features, Advertising Reporting Features, Demographics and Interest Reports, Store Visits, and Google Display Network Impression reporting. We and third-party vendors use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as Google advertising cookies) or other third-party identifiers together.

You can opt-out of Google Analytics Advertising Features including using a Google Analytics Opt-out Browser add-on found here. To opt-out of personalised ad delivery on the Google content network, please visit Google’s Ads Preferences Manager here or if you wish to opt-out permanently even when all cookies are deleted from your browser you can install their plugin here. To opt out of interest-based ads on mobile devices, please follow these instructions for your mobile device: On android open the Google Settings app on your device and select “ads” to control the settings. On iOS devices with iOS 6 and above use Apple’s advertising identifier. To learn more about limiting ad tracking using this identifier, visit the settings menu on your device.

CCTV Footage

We operate CCTV cameras at our premises to monitor the safety and security of our premises, clients and staff. Our CCTV systems do not use facial recognition technology or biometrics. The images captured are securely stored and only accessed on a need-to-know basis. Any CCTV images captured will be stored securely for 30 days before being automatically overwritten, unless required for investigative or legal reasons. We will only share CCTV footage with third parties who have a need to access such CCTV footage, such as Law Enforcement Agencies, and only where we have a lawful basis for sharing the CCTV footage.

Overseas transfers

Where we disclose personal data to the third parties listed above, these third parties may store, transfer or access personal data outside of the United Kingdom, including to Australia. The level of data protection in countries outside of the United Kingdom may be less comprehensive than what is offered in the United Kingdom. Where we transfer your personal data outside of the United Kingdom, we will perform those transfers using appropriate safeguards in accordance with the requirements of applicable data protection laws and we will protect the transferred personal data in accordance with this Privacy Policy. This includes:

· only transferring your personal data to countries that have been deemed by applicable data protection laws to provide an adequate level of protection for personal data; or

· including standard contractual clauses in our agreements with third parties that are overseas.

Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Your rights and controlling your personal data

Your choice: Please read this Privacy Policy carefully. If you provide personal data to us, you understand we will collect, hold, use and disclose your personal data in accordance with this Privacy Policy. You do not have to provide personal data to us, however, if you do not, it may affect our ability to provide our Services to you and your use of our Services.

Information from third parties: If we receive personal data about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal data about somebody else, you represent and warrant that you have such person’s consent to provide the personal data to us.

Access, correction, processing and portability:You may request details of the personal data that we hold about you and how we process it (commonly known as a “data subject request”). You may also have a right in accordance with applicable data protection law to have your personal data rectified or deleted, to restrict our processing of that information, to object to decisions being made based on automated processing where the decision will produce a legal effect or a similarly significant effect on you, to stop unauthorised transfers of your personal data to a third party and, in some circumstances, to have personal data relating to you transferred to you or another organisation.

Unsubscribe: To unsubscribe from our e-mail database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.

Withdraw consent: Where we are relying on consent to process your personal data, you have the right to withdraw your consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Storage and security

We are committed to ensuring that the personal data we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures, to safeguard and secure personal data and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

While we are committed to security, we cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk.

We may use cookies on our website from time to time. Cookies are text files placed in your computer's browser to store your preferences. For more information about the cookies we use, please see https://sensoryfootsteps.co.uk/cookie-policy Links to other websites

Our website may contain links to other party’s websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal data which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.

Amendments

We may change this Privacy Policy from time to time. We will notify you if we make a significant change to this Privacy Policy, by contacting you through the contact details you have provided to us and by publishing an updated version on our website.

For any questions or notices, please contact us at:

Sensory Footsteps Limited, a company registered in England and Wales, with company number, 13966133.

Email: enquiries@sensoryfootsteps.co.uk

Last update: 5 July 2024

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