Privacy Policy

Shine Therapy Services Ltd (‘we’, ‘us’ or ‘our’) is committed to protecting and respecting your privacy. This policy provides details about the types of personal information we collect about you and about how we use it. It also provides information on your rights. 

Scope of Policy

This policy applies to anyone we interact with, via any means, in relation to our services (e.g. anyone who enquires about, commissions or accesses any of our services, etc).

We have separate policies for employees / job applicants and our suppliers.

The types of personal information we collect

We may collect and process two types of personal information:

General

  • Identity (name, date of birth, gender)
  • Contact (address, email address and telephone numbers)
  • Education (setting attended and background on attainment, behaviour and additional needs, etc)
  • Billing (invoicing details, payment history, etc)
  • Details of any complaints, disputes or incidents
  • Still or video imagery (with or without sound)
  • Information on use of our website (see Cookies Policy)

Special Category

  • Health (medical information, including diagnosed conditions, care and treatment plans, emerging health concerns, etc).

How we collect personal information

We collect personal information from you and from third parties. These third parties may include:

  • Parents or guardians
  • Family members, or someone else acting on your behalf
  • Health care providers (eg GPs, consultant paediatricians, education psychologists, community nurses, occupational therapists, speech and language therapists, physiotherapists, etc)
  • Education providers (eg teachers, teaching assistants, SENCOs, etc)
  • Local Authorities (e.g. adoption support workers, social workers, SEND officers, family support workers, etc)
  • Case managers and medico – legal professionals
  • Health insurance providers
  • Others organisations acting on your behalf (eg charities, not-for profit companies, etc)

Personal information may be collected through:

  • Our website, social media platforms (eg Facebook, etc) and ticketing platforms (eg Eventbrite, etc)
  • By email, letter, phone or in person, or through completion of referral, consent or other forms
  • Reference to third party documentation (eg assessment reports, clinical case notes, education records, etc)
  • Photographic or video recording equipment including cameras, mobile phones and tablets.

How we process your personal information

We may process your personal information for the following purposes:

Purpose

Indicative actions

Enquiries

To identify scope of works, generate fee quotes, formulate contracts and provide advice or guidance, etc.

Clinical

To provide health care services, including all aspects of consultation, assessment, therapy or other clinical input, etc.

Administration

To process billing, manage appointments or event bookings, maintain records, monitor performance, deal with complaints, disputes or incidents, etc.

Marketing

To promote services or events and to share information (eg newsletters, etc).

We must have a lawful reason for processing your personal information. For the processing purposes of ‘administration’ and ‘enquiries’ we may apply the lawful basis of contract, legitimate interests and legal obligation.  For the processing purposes of ‘clinical’, and the action of any other purpose which involves the processing of special category data, we may apply the lawful basis of:

  • It being necessary for the purposes of preventive or occupational medicine, medical diagnosis, to provide health or social care or treatment, or to manage health-care or social-care systems.
  • Explicit consent having been provided.
  • It being necessary to establish, exercise or defend legal claims.
  • It being necessary to protect the public against dishonesty, malpractice or other seriously improper behaviour.

In respect of ‘marketing’ we may apply the legal basis of consent or legitimate interests depending upon the circumstances.

Sharing your personal information

In delivering our services to you we may share your personal information with third parties, typically those listed above.

For business administration we may share your personal information with third party providers of electronic marketing platforms, document and record management systems, ticketing platforms, event venues, catering suppliers, training partners or providers, delivery companies and debt collection agencies.

In dealing with any complaints, disputes or incidents we may share your personal information with insurers, legal advisors, and professional or regulatory bodies.

We may also share your personal information with other third parties where we believe that it is necessary to assist in the prevention or detection of a criminal act, or is otherwise in the overriding public interest (eg  prevention of fraud, reporting or assisting in the investigation of a safeguarding concern, etc).

We do not share your personal information with third parties for marketing their own goods or services to you.

How long we hold personal information

We will hold your personal information for as long as reasonably necessary to fulfil the purposes set out in this policy and in accordance with any relevant legislation or best practice guidance from professional or regulatory bodies, insurers, etc. 

The period of retention will vary depending upon the nature of the personal information and what we do with it.

Protecting your personal information

We have appropriate policies and technical security measures in place to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

Your rights

You have rights regarding your personal information and how we use it. These rights may be limited to certain defined circumstances and we may not be able to comply with your request. We will always respond to any request and if we are unable to comply we will explain why.

The rights relevant to our business practices include:

  • Right to access: to request details of the personal information we hold on you and to be provided with copies of that information.
  • Right to rectification: to request that inaccurate personal information is rectified or completed if it is incomplete.
  • Right to erasure (‘the right to be forgotten’): to request that personal information is deleted.
  • Right to restrict processing: to request that your personal information is only used for certain purposes.
  • Right to object: to request that we do not use your personal information for direct marketing.
  • Right to withdraw consent: to withdraw consent to further use of personal information.

We will aim to respond to any request as soon as possible, generally within one month of its receipt. If the request may take longer to deal with we will explain why. There is no fee for the processing of requests, unless it is clearly unfounded or excessive, or you require additional copies.

We may issue direct marketing by post, phone or email. If you no longer wish to receive emails from us, you can select the ‘unsubscribe’ link that appears in all emails we send. For non – email marketing please contact us as below.

Amendments

We will amend this policy to keep it up to date with relevant legislation or best practice guidance, or to reflect changes in our business practices. You should revisit this policy occasionally to ensure that that you are happy with any amendments that have been made.

Contact

If you have any queries or comments in respect of this policy, have any concerns about how we process your personal information, or wish to exercise any of your rights, please get in touch using the website contact form or the contact details below:

The Business Manager

Shine Therapy Services Ltd

PO BOX 1341

Preston

PR2 0TN

T: 07725193837

E: admin@shinetherapyservices.co.uk

If you would like to contact the Information Commissioner’s Office (ICO) please visit their website at www.ico.org.uk.