Privacy Policy

1. Background

This privacy notice applies to all personal information which is processed by Neurofeedback Scotland; it lets you know what happens to any personal data that you give to us, or any that we may collect from or about you. It applies to all services and ways we collect your data.  The following is a description of the types of personal information we hold and consider relevant for the services we provide:

• Personal contact details – title, full name, current contact details ie. Home or mobile number, address, email address
• Your age, date of birth, gender as you describe it, religious affiliation if any, sexual orientation, nationality, marital status, family make-up and history, lifestyle and social circumstances, professional insights about you
• Records of your contact with us via phone, email, post, online contact form
• Details of payment methods, wherever they are encrypted
• Marketing to you and analysing data – this will include a history of communications via our website and to our offices, information you have provided regarding interest in other services we provide.  We may wish to use data for research, funding purposes etc. but will always request your explicit permission even if this data is anonymised
• Information obtained from third parties: we require details of any involvement of other medical/therapy practitioners in your care for example psychiatrist, general practitioner, psychologist regarding your mental and physical health and personal circumstances, this may include alternative therapies, prescribed medication or social drug use.  We may need to be in communication with these third parties to provide best care
• Criminal records information, information about your home, financial health, employment status, residency/citizenship where these contexts are relevant to your health and treatment

2. Data Protection

The source of your personal information comes from you directly, any family members, medical/psychological/therapeutic practitioners, social work, educational institutions, other members of Neurofeeback Scotland. 

This information is collated: 

• By email, by post, by telephone or in person;

The information is stored:

• In emails, in password protected computer files with back up, in paper files in locked cabinets

3. What do we use your personal, anonymised data for?

• Assess your conditions/psychological problems, the possible source of those problems, determine the best course of action
• Keep records up to date
• For research and analysing statistics related to best practice, and for professional development, supervision, training, for example

4. Legal grounds for retaining, processing and sharing your information:

• To comply with our statutory bodies (ie. supervision)
• To comply with insurance providers (ie.in event of claim or complaint)
• for anonymised management, auditing, and accounting
• to comply with our legal obligations where we consider your actions will cause harm to yourself or others, or where a client may be in danger
• if we are subpoenaed by the courts

5. Do we share your personal information with other organisations?

Only in above circumstances (See section 4) or in case of emergency and/or with your explicit permission

6. How and when can you withdraw your consent?

We rely on your consent to process personal data, and to conduct the services we provide.  For our service provision we will ask you to sign a consent form.  You can withdraw this at any time by contacting us directly and on request we will remove all data from the various storage locations.

7. Is your personal information transferred outside the UK or the EEA?

We are based in Scotland, UK but on rare occasions we will share your anonymised data with trainers, other professionals outside the UK.  This is a requirement of our supervision and personal development and again your express consent will be requested.

8. Changes to your personal information

Please tell us if any of your information changes so that we can update our records

9. Do you have to provide your personal information to us?

We are unable to provide you with our services without personal information, however the nature and extent of your disclosures are at your discretion.

10(a). Is there monitoring regarding processing, filing your personal information?

We self-monitor the storage of information in accordance with the requirements of our governing bodies – the British Psychological Society, Health & Care Professions Council and Play Therapy UK (see below). 

10(b). How long is information held for?

Under Common Law, we are allowed to keep records for six years to protect ourselves from a claim of breach of contract or personal injury.  All information which we keep for this period of time will be securely locked or password protected where relevant. 

11. What are your rights under data protection laws?

• To be informed about how we keep and process your information
• To have this information corrected if inaccurate
• To object to processing of personal information
• To restrict processing or to request erasure of personal information
• To request access to your information
• To move, copy or transfer personal information
• Right not to be subjected to automated decision-making
• You have the right to complain to British Psychological Society, Health Care Professions Council and Play Therapy UK

12.Changes to this privacy notice

We may change this privacy notice from time to time by updating this page to reflect changes in the law and/or our privacy practices. We encourage you to check this privacy notice for changes whenever you visit us or our website.

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