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Privacy Policy

This Privacy Policy forms part of the RSCPP Terms and Conditions.

 

Introduction

Our aim is to respect your privacy and comply with the General Data Protection Regulation (GDPR).

The Data Controller

RSCPP Ltd is the Data Controller for any personal data you give to us. Our full details are:

Address: Kings Parade, Lower Coombe Street, Croydon, CR0 1AA, UK
Email: data@rscpp.co.uk

RSCPP Ltd is registered with the Information Commissioner's Office (Z1034729).

 

Summary

  • We keep to a minimum the information we hold about you
  • We use your data to provide our services to you, respond to your enquiries, manage our relationship with you, meet our legal obligations, and improve our website
  • We delete your data when it is no longer needed for these things, as of 25 May 2018
  • We give your information to the requested Therapist or Customer, as well as telecommunication suppliers who facilitate data transfer to the requested person
  • You have privacy rights
  • We take security seriously
  • We use cookies on our website
  • We are happy to answer your questions about any of this
  • This privacy policy was last updated on 24 May 2018

 

Want more detail?

I am a Web Site Visitor [link]

I am a Customer [link] (in addition to a Web Site Visitor [link])

I am a Therapist [link] (in addition to a Web Site Visitor [link])

 

Web Site Visitor 

What information we collect

We collect information about your computer and your visits to and use of this website (including your IP address, geographical location if entered by you, browser type and version, operating system, referral source, length of visit, page views, website navigation paths and onsite searches made).

Why we need it

We monitor demand based on location, therapy, issue, price, time preference and so on, so that we can ensure we have the right mix of Therapists on our web site to fulfil future Web Site Visitor and Customer requirements.

What we do with it

We analyse it and look for patterns for example, to see where we need to find more Therapists to fulfil future demand, or to see where we can make usability improvements on desktop vs mobile. When we have unusual spikes in traffic we IP address logs it to learn if this is from real web site users, or from an automated search engine bots looking at our web site.

How long we keep it

We keep these logs indefinitely so we can look at trends over time.

How we keep it secure

We use a Symantec (Thawte) Secure Socket Layer (SSL) 256 Bit Encryption Certificate to provide encrypted communications to and from the Website, AES Encryption to store sensitive data, a server with an IPtable firewall, SHA1 One Way Encoded password protection, computer firewalls and anti virus software, and backup files to prevent loss of data in a catastrophe. RSCPP cannot guarantee the Website is secure and virus-free as the internet is not secure and virus-free. RSCPP investigates any breach of security should one occur.

We take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.

Who we share it with

We don’t share specific insights or individual Website Visitor’s information with anyone external.

We may share aggregated information on rscpp.co.uk when they are of public interest, such as news of increases of Web Site Visitors looking for help for a certain issue, or information on which day of the week most people look for therapy.

We share insights into general Customer demand with Therapists so that they can learn and expand their offerings to meet demand. For example, we may share that in Central London, evening sessions are most in demand to encourage Therapists to meet this.

Where we store and process it?

The majority of personal information is stored by us in the UK, and processed in the UK or in the European Economic Area ("EEA"). But there are some occasions where your information may leave the EEA in order to use a third party supplier to fulfil part of our service.

We have additional protections on your information if it leaves the EEA ranging from secure ways of transferring data to ensuring we have a contract in place with that third party.

How we use Cookies

We use cookies to identify you as a unique Web Site Visitor, to provide you with a consistent experience from webpage to webpage, and to monitor web site usage. You can find out more on our Cookie Policy webpage.

Links to Other Sites

Our web site contains links to other web sites. We are not responsible for the privacy practices of such other websites. When you leave our website please be sure to read the privacy statements of each and every website that collects personal data about you. This privacy policy applies solely to information collected by RSCPP Ltd.

What are your rights

You are in complete control. You can object or withdraw your consent to the use of your personal data at any time. Though in some cases we may not be able to provide your requested service where the information processing is an integral part of the service. We will tell you if this is likely to be the case.

Subject to some legal exceptions, you have the right to:

request a copy of the personal information RSCPP holds about you;
to have any inaccuracies corrected;
to have your personal data erased;
to place a restriction on our processing of your data;
to object to processing; and
to request your data to be ported (data portability).

To learn more about these rights please see the ICO website.

Please address any such requests to the RSCPP Data Controller as listed above.

If you are dissatisfied with our response you can complain to the Information Commissioner's Office via https://ico.org.uk/

 

Customers

Customers are individuals who contact a Therapist through our service. The information below is in addition to the Website Visitor information above.

What information we collect

When a Customer makes an enquiry to a Therapist we collect the Customer’s name, mobile number and/or email address and optional message for the Therapist.

We later collect information from the Therapist about arrangements, cancellations and the quantity of attended sessions so that we can administer our business. The Therapist may also update the Customer’s contact details to ensure they are kept up to date.

Why we need it

We need to know this basic contact information to pass on to the Therapist to whom the enquiry is being made, in order that they can follow up the enquiry with the Customer in a well-informed manner.

We need information about enquiry progression so that we can administer our business; we promote Therapists for free and only charge Therapists a fee when a Web Site Visitor becomes a paying Customer. We do not collect any personal information that is not needed in order to fulfil our service to you.

What we do with it

The personal contact data is relayed to the Therapist by email and SMS so that the Therapist can fulfil the contact request from the Customer. When a phone call is made by the Customer, it is made to an RSCPP number and routed through to the Therapist.

The Therapist uses either the telephone number or email address provided by the Customer to make contact and supply of those details is deemed as permission to use them; if you don’t want a communication method to be used, please don’t provide it.

The personal data is stored in our system so that the Therapist can later update us on the progress of the enquiry and we can relay communications on to the Customer. We relay the enquiry details on to the Therapist so that they can respond to the enquiry. We do not store the optional message other than in our email logs for 30 days.

Our system has been designed to handle all enquiries with as little as possible human interaction from us. An enquiry is only seen by our staff in exceptional cases when a Therapist or Customer raises a situation outside of our normal enquiry workflow and manual action is required. When this happens, our trained staff access personal data to handle the exceptional situation, and will communicate with the Customer when necessary.

The Therapists that a Customer contacts is an independent third party from RSCPP. We relay your contact details to them as you have requested. Therapists are responsible for your personal data once they receive it, and you should contact them if you have questions about how they handle personal data.

How long we keep it

From 25 May 2018 we keep personal contact data only for as long as is required to carry out the purpose for which it was given; to arrange therapy and to request feedback on the services provided by RSCPP and the Therapist. We remove personal contact data two months after an enquiry is closed in our system, this happens when either:

1) the Therapist makes a final update to the enquiry that Therapy will not take place
2) after 1 or 2 therapy sessions when Therapists pay us based on attendance of 2 sessions
3) after the final session has taken place when Therapists pay us based on attendance of all sessions

Two months after this point, we send notice to the Customer that we are deleting their personal contact data, whilst also sending a final invite to leave a review and an optional invite to join our marketing mailing list.

We are required by UK law to keep copies of all invoices for a minimum of 6 years; the Customers full name, only, will remain on our invoice to the Therapist in their records, and in our own.

Who we share it with

We pass your personal data directly to the Therapist who you request contact with.

Suppliers provide us with the telecommunication capability to relay phone calls and send SMS messages and their systems therefore handle your data to fulfil this communication. We only share the appropriate level of personal data to enable us and the supplier to provide the requested service. We take all reasonable steps to ensure your data is handled safely and securely and in accordance with our and the suppliers’ obligations under GDPR and the law. Contact us on data@rscpp.co.uk if you want to find out more about our telecommunication suppliers.

 

Therapists

Therapists are individuals who apply to promote their service on rscpp.co.uk. The information below is in addition to the “Website Visitor” information above.

Therapists should also read the Customers Privacy information [link] above so they are aware of the information contained within it.

What information we collect

Therapists provide information such as their location, therapies offered, issues covered, fees, working hours, insurance registrations, languages spoken, professional body registrations, courses completed so that we can show these details to Web Site Visitors and/or Customers. This information is provided directly by the Therapist, and supply of it denotes permission to publish it.

Therapists provide information such as their administration address, clinical supervisor and clinical insurance to meet our criteria for information that we hold in order to work with a Therapist; these are not shown to Web Site Visitors (unless the administration address is the same as a consulting address).

We store records of interaction between Therapists and us such as a login audit, correspondence, enquiry updates and performance statistics.

Why we need it

We need public facing information to that we can promote Therapists to Web Site Visitors. We need Administration information to run our business, to know how we should contact a Therapist, and to fulfil our criteria that a Therapist must have insurance and a supervisor. We need records of interaction to administer our business.

What we do with it

When a Therapists’ application to be listed on rscpp.co.uk has been approved, we display their Web Profile information on our web site and it is publicly visible. We use information about a Therapists location, therapies offered, issues covered, fees, availability, private health insurance registrations and languages spoken to provide search functionality for Web Site Visitors to use.

Information provided by Therapists in the Administration section is not displayed on the public facing Web Site and is used to perform administrative functions.

Records of interaction are used to manage our relationships with Therapists.

How long we keep it

We keep Therapist information indefinitely; even when a Therapist leaves rscpp.co.uk. If a Therapists wants to return later then all of their information is ready to be used again. When a Therapist asks to leave rscpp.co.uk, we remove their public facing data. We only remove Therapists’ data entirely from our database when explicitly requested by the Therapist. When we remove Therapists’ data by request, we keep a secure offline copy of the web profile and administration information provided by the Therapist for legal reasons for 7 years (as evidence in case a Web Site Visitor or Customer makes a complaint against us or a Therapist). We also keep an online copy of invoices for accounting reasons for 6 years. We store records of interaction indefinitely.

Who we share it with

When a Therapist Web Profile is active, we publish it on rscpp.co.uk and it is publicly available.

Suppliers provide us with the telecommunication capability to relay phone calls and send SMS messages and their systems therefore handle your data to fulfil this communication. We only share the appropriate level of personal data to enable us and the supplier to provide the requested service. We take all reasonable steps to ensure your data is handled safely and securely and in accordance with our and the suppliers’ obligations under GDPR and the law. Contact us on data@rscpp.co.uk if you want to find out more about our telecommunication suppliers.

Payment Security

RSCPP’s country of merchant domicile is the UK and accepts card payments from UK cardholders and UK Residents using Visa, Visa Delta, Visa Debit, Visa Electron, MasterCard and UK Maestro. RSCPP uses Verified by Visa (VbV) and MasterCard SecureCode (MSC) collectively known as 3D Secure which affect Visa, Visa Delta, Visa Electron, MasterCard and UK Maestro payments. VbV/MSC may email registrants confirmation stating registration was via 'RSCPP Ltd'. RSCPP uses Sage Pay which employs internet facing web servers certified by Verisign and encrypted and digitally-signed data transfer from the Website to Sage Pay. RSCPP transactions appear on cardholder's statements as 'www.rscpp.co.uk 0800 5345 305' with a unique transaction ID. RSCPP only stores the last four digits of card numbers and card types, cardholders names, billing addresses, contact telephone numbers and transaction IDs in case of refunds for 18 months in compliance with Sage Pay and Lloyds TSB Cardnet standard procedures, and does not supply either with cardholders email addresses, nor email a receipt to a cardholder unless requested to do so by a cardholder.

 

Customer and Therapist Interaction

The Customer and Therapist agree not to communicate clinical material to RSCPP (other than for the purpose on onwards referral) as it is a matter between the Customer and the Therapist, agree to be responsible for keeping their individual personal data private and secure, and agree that if either fail to comply or cause a problem as a result of failure to comply either cannot hold RSCPP responsible.

The Therapist agrees to comply with GDPR and any data requirement of their professional body and to inform the Customer what the requirement is if they ask. If the Customer requires a copy of their clinical information they should contact the Therapist directly. During clinical supervision the Therapist must not disclose any information that would identify the Customer.

When the Therapist introduces other Therapists to RSCPP via the Website, RSCPP shall consider this to be the Therapist's permission to contact the other Therapists.

 

General

RSCPP emails are confidential and privileged and are intended solely for the intended recipient and are subject to the Terms and Conditions and Privacy and Cookies Policy of this Website. An unintended recipient must not disclose, copy or distribute information in any email or take any action in reliance on its contents as to do so is strictly prohibited and may be unlawful but must inform RSCPP of any email by replying to any email before deleting it.

RSCPP does not accept any responsibility for any damage whatsoever that is caused by viruses being passed and/or for any loss arising from unauthorised access to, or interference with, any internet communications by any third party, or from the transmission of any viruses.

Any views, opinions or other information presented in emails from RSCPP are solely those of the author and do not necessarily represent those of RSCPP or relate to the business of RSCPP, are personal to the sender and are not given or endorsed by RSCPP.

Any views, opinion or other information written spoken or communicated by the Therapist to the Customer, are personal to the Therapist, are solely those of the author, do not represent those of RSCPP, are not given or endorsed by RSCPP, and do not relate to the business of RSCPP.

RSCPP will never contact any party to ask them for their registered email address, password, or payment card details.

If RSCPP is sold or integrated into another business the Customer’s data and Therapist's data may be disclosed to the prospective purchaser's advisors under stringent confidentiality terms and subsequently to the new owners but only for the purposes of maintaining the supply of the Website and/or the Clinical Services in succession to RSCPP.

RSCPP and the Customer and the Therapist all have the right to privacy and RSCPP expects both the Customer and the Therapist not to publish in the public domain, including the web, any information which passes between them except as may be required by law.

The parties agree to keep confidential any and all information concerning each other whether disclosed in writing, verbally or in relation to the matters provided for in this agreement ("the Information"). The parties further agree in particular not to disclose all or any part of that Information to any third party (except as may be required by mandatory rule of law or order of court of competent jurisdiction or as required for performance of their obligations under this agreement).

Notwithstanding the above, in the event that either RSCPP or the Therapist considers that there is a threat to the Customer's or a third party's safety during the provision of either the Website or the Clinical Services, both RSCPP and the Therapist reserves the right to contact the Customer's GP or the authorities and disclose such information as either RSCPP or the Therapist deem necessary in order to protect the Customer's or a third party's safety. The Customer must therefore keep both RSCPP and the Therapist informed of any changes in their contact details. The Customer must keep the Therapist informed of any changes in their personal information. The Customer is advised to inform their GP that they are receiving Clinical Services.

Nothing in this clause shall prevent the free disclosure of information in the public domain at any time, information which was already in a party’s possession, or which is received by a party from an independent source outside obligations of confidence.