Privacy Policy for Fortitudo Therapy

Introduction
Welcome to Fortitudo Therapy’s privacy policy. Fortitudo Therapy is committed to protecting your privacy and maintaining a high standard of confidentiality and data compliance. This policy explains how Fortitudo Therapy collects, processes, and protects your personal information.

1. Important Information and Who We Are

Purpose of this Privacy Policy
This privacy policy provides information on how Fortitudo Therapy collects and processes your personal data through your interactions with our website and our therapy services. The Fortitudo Therapy website is not intended for children, and we do not knowingly collect data from children through the website. Please read this policy alongside any other notices provided at data collection points so that you fully understand how and why we use your data. This policy supplements other notices and privacy policies; it does not override them.

Controller
Dr. Raminta Petrauskaite, founder of Fortitudo Therapy, is the data controller responsible for your personal data (referred to as “we,” “us,” or “our” in this notice).

Contact Details
If you have questions about this privacy policy or our privacy practices, please contact us:
Full name: Dr. Raminta Petrauskaite trading as Fortitudo Therapy
Email address: info@fortitudotherapy.co.uk

You may also contact the Information Commissioner’s Office (ICO; https://ico.org.uk/) at any time to report concerns. However, we would appreciate the chance to address your concerns first.

Changes to the Privacy Policy and Your Duty to Inform Us of Changes
This privacy policy is reviewed regularly. Please inform us of any changes to your personal data to ensure that the data we hold is accurate and current.

Third-Party Links
Our website may contain links to third-party websites, plug-ins, and applications. Clicking on these links or enabling these connections may allow third parties to collect or share data about you. Fortitudo Therapy is not responsible for the privacy practices of third-party websites. We encourage you to read their privacy policies.

2. The Data We Collect About You
Personal data refers to information from which an individual can be identified. Fortitudo Therapy may collect, use, store, and transfer different types of personal data, which includes:

• Identity Data: Name, date of birth, and gender.
• Contact Data: Email, telephone, and address.
• Financial Data: Bank account details and payment history.
• Transaction Data: Payment history related to our services.
• Technical Data: IP address, browser type and version, and other technology on devices used to access the website.
• Usage Data: Information about how you use our website and services.
• Sensitive Data: Health information, including previous medical and psychiatric conditions, medication details, and other relevant health information.

We process sensitive data only with your explicit consent, which is obtained through consent tick boxes on our registration forms or via email.

If You Fail to Provide Personal Data
If you fail to provide required personal data, we may not be able to perform the services requested. In this case, we may need to cancel your service.

3. How is Your Personal Data Collected?

• Direct interactions: Data you provide directly when completing forms or engaging in therapy sessions.
• Automated technologies or interactions: As you interact with our website, we may collect Technical Data about your equipment and browsing patterns through cookies.
• Third parties or publicly available sources: We may receive personal data from analytics providers such as Google Analytics.

4. How We Use Your Personal Data
Fortitudo Therapy will only use your data as permitted by law. Common uses include:

• Service Delivery: To deliver therapy services and manage fees and charges.
• Provide, Monitor, and Improve Therapeutic Services: To enhance the quality and effectiveness of our therapy interventions.
• Maintain Accurate Records of Treatment: To comply with regulatory and ethical standards.
• Safety Assurance: To ensure the safety of both yourself and others, in line with ethical responsibilities.
• Communications: To notify you of policy updates, confirm appointments, and address billing or treatment inquiries.
• Business Operations: For IT services, network security, and legal compliance.

Change of Purpose
Your data will only be used for the original purpose unless we reasonably need it for a compatible purpose. If needed for an unrelated purpose, we will inform you of the legal basis for this new use.

5. Data Sharing and Disclosure
Your personal data will be treated with strict confidentiality. We may need to share information in the following instances:

• Professional Supervision: In line with clinical supervision requirements to ensure quality of care (any identifying information is anonymised).
• Accounting and Financial Management: Personal data necessary for billing and financial record-keeping may be shared with our accounting service provider to ensure compliance with financial and tax regulations.
• Emergency Situations: If we believe you or others are at risk, we may contact relevant authorities.
• Legal Requirements: When required by law, such as in the case of subpoenas or court orders.

All third parties must respect your data’s confidentiality and comply with legal standards.

6. International Transfers
Data may be transferred outside the European Economic Area (EEA). In such cases, safeguards will be implemented to ensure data protection, such as using specific contracts approved by the European Commission.

7. Data Security
We have implemented security measures to prevent unauthorised access, accidental loss, or use of your personal data. For example:

• Paper records are stored in locked cabinets.
• Digital data is stored on secure, password-protected devices and encrypted cloud services.
• Communications are sent with encryption and password protection.

In the event of a suspected breach, you and the ICO will be notified as required.

8. Data Retention
Your personal data will be retained only as long as necessary to fulfil the purposes for which it was collected, including legal, regulatory, and reporting requirements. Therapy notes are retained for 7 years after service conclusion. Records may be anonymised and kept indefinitely for statistical purposes.

9. Your Legal Rights
You have rights regarding your personal data, including access, correction, erasure, and restriction. You may also withdraw consent for sensitive data processing, though this will require termination of therapy services.

How to Exercise Your Rights
If you wish to exercise any rights, please contact us. We may require further information for security reasons and aim to respond within one month.

10. Your Rights
Under GDPR, you have several rights regarding your personal data:

• Access: You can request a copy of the personal data we hold about you.
• Correction: You may request corrections if your data is inaccurate or incomplete.
• Deletion: In certain cases, you can request that we erase your personal data.
• Restriction: You can request that we limit the processing of your data.
• Data Portability: You can request that we provide your data in a structured, commonly used format.
• Object: You have the right to object to data processing, particularly for direct marketing or profiling.

If you wish to exercise any of these rights, please contact us using the details provided below.

11. Changes to This Policy
We may update this privacy policy from time to time to reflect changes in regulatory requirements or our privacy practices. Any updates will be posted on our website.

12. Contact Information
If you have any questions about this privacy policy or your data rights, please contact:
Fortitudo Therapy
Dr. Raminta Petrauskaite
Email: info@fortitudotherapy.co.uk
Phone: 07769348454

13. Complaints
If you believe that Fortitudo Therapy has not complied with data protection laws, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO).

ICO Contact Information:
Website: https://ico.org.uk/
Phone: 0303 123 1113

Effective Date: October 2024