Play Therapy UK Privacy Notice - For Registrants, Clients and General Users
accordance with de facto web site standards.
We will only collect
information in accordance with the Data Protection Act 1998. Our contact
details are listed below. PTUK's Privacy Statement follows: Play Therapy UK
(ICO registration ZA107748) (“PTUK”) takes your privacy very seriously. This
Privacy Notice is intended to set out your rights and answer any queries you
may have about your personal data. If you need more information, please
Data Controller Jeff Thomas at: firstname.lastname@example.org
Our personal information handling policy and procedures have been developed in
line with the requirements of the 1995 European Union Data Protection Directive
(Directive 95/46/EC) and the General Data Protection Regulation (in force from
25 May 2018) and applicable national law.
What information do we collect?
We collect and process
personal data about you and if you are a registrant your clients and clinical
supervisor when you communicate with us and our services and when you purchase
goods and services from us. The personal data we process includes:
- your name;
- your PTUK membership number and
- your home or work address, email
address and/or phone number;
- your job title;
- your professional revalidation
- your payment and delivery details
for our journals, professional documents, certificates, including billing and
delivery addresses and credit card details, when you make purchases from us;
- information related to the browser
or device you use to access our web site;
- internet browser cookies and
operating system data;
- and/or any other information you
How do we use this information and what is the legal basis for this use?
We process the personal data listed in section 1
above for the following purposes:
- as required to establish and
fulfil a contract with you, for example, if you make a purchase from us or
enter into an agreement to provide or receive services. This may include
verifying your identity, taking payments, communicating with you, providing
customer services and arranging the delivery or other provision of products or
services. We require this information in order to enter into a contract with
you and are unable to do so without it;
- to comply with applicable law and the
requirements of the Professional Standards Authority in the accreditation of
the ‘Register of Play and Creative Arts Therapists’;
- in accordance with our legitimate
interests in protecting PTUK’s legitimate professional interests and legal
rights, including but not limited to, use in connection with legal claims,
compliance, regulatory and investigative purposes (including disclosure of such
information in connection with legal process or litigation);
- with your express consent to
respond to any comments or complaints we may receive from you, and/or in accordance
with our legitimate interests including to investigate any complaints received
from you or from others, about our web site or our products or services;
- we may use information you provide
to personalise (i) our communications to you; (ii) our web site; and (iii)
products or services for you, in accordance with our legitimate interests;
- to monitor use of our web sites
and online services. We may use your information to help us check, improve and
protect our products, content, services and web sites, both online and offline,
in accordance with our legitimate interests;
if you provide a credit or debit
card, we may also use third parties (such as POS payment providers) to check
the validity of the sort code, account number and card number you submit in
order to prevent fraud, in accordance with our legitimate interests and those
of third parties;
- we may monitor any customer
account to prevent, investigate and/or report fraud, terrorism,
misrepresentation, security incidents or crime, in accordance with applicable
law and our legitimate interests;
- in circumstances where you contact
us by telephone, calls may be recorded for quality, training and security
purposes, in accordance with our legitimate interests; and
- we may use your information to
invite you to take part in market research or surveys.
Legitimate interest – PTUK need to communicate the facts that the
recipients need to have to comply with their professional and training
obligations to enable safe and effective therapeutic practice with children and
meet the standards of the ‘Register of Play and Creative Arts Therapists’
accredited by the Professional Standards Authority. The Register’s occupation
title of the recipient is included in the communication. Recipients may also include those who have an
influence upon the current and future work of our registrants in the matter of
children’s emotional well-being and mental health.
With whom and where will we share your personal data?
We may also share your personal data with the below
- our professional advisors such as
our auditors and external legal and financial advisors;
- other registrants and other
Professional Standards Authority Accredited Registers;
- personal data may be shared with
government authorities and/or law enforcement officials if required for the
purposes above, if mandated by law or if needed for the legal protection of our
legitimate interests in compliance with applicable laws;
- personal data may also be shared
with third party service providers who will process it on behalf of PTUK for
the purposes above. Such third parties include, but are not limited to,
providers of PTUK hosting, email services, maintenance, call centre operation
and identity checking;
- in the unlikely event that our organisation
or any part of it is sold or integrated with another organisation, your details
will be disclosed to our advisers and those of any prospective purchaser and
will be passed to the new owners of the organisation.
How long will you keep my personal data?
We will not keep your
personal information for any purpose for longer than is necessary and will only
retain the personal information that is necessary in relation to the purpose.
We are also required to retain certain information as required by law or for as
long as is reasonably necessary to meet regulatory requirements, resolve
disputes, prevent fraud and abuse, or enforce our terms and conditions.
Where you are a registrant,
we will keep your information and those required for annual revalidation for your
lifetime to provide evidence for the public and yourself in the event of a
complaint against you.
Where you are a prospective registrant and you have expressly
consented to us contacting you, we will only retain your data (a) until you
unsubscribe from our communications; or, if you have not unsubscribed, (b) while
you interact with us and our content; or (c) for 5 years from when you last
interacted with us or our content.
In the case of any contact
you may have with our support services team, we will retain those details
for as long as is necessary to resolve your query and for two years after the
query is closed.
We will retain your data
for a short time beyond the specified retention period, to allow for
information to be reviewed and any deletion to take place. In some instances,
laws may require PTUK to hold certain information for specific periods other
than those listed above.
Where are my data stored?
Your data are stored on
PTUK’s server located in the UK which is not directly connected to the
Internet. The personal data that we collect from you may be transferred to, and
stored outside the European Economic Area (“EEA”). It may also be
processed by staff operating outside the EEA who work for us or for one of our
suppliers, in which case the third country's data protection laws will have
been approved as adequate by the European Commission or other applicable
safeguards are in place.
What are my rights in relation to my personal data?
If the information we hold about you is inaccurate
or incomplete, you can notify us and ask us to correct or supplement it. You also have the right, with some exceptions
and qualifications, to ask us to provide a copy of any personal data we hold
Where you have provided your data to us and it is
processed by automated means, you may be able to request that we provide it to
you in a structured, machine readable format.
If you have a complaint about how we have handled
your personal data, you may be able to ask us to restrict how we use your
personal data while your complaint is resolved. In some circumstances you can
ask us to erase your personal data (a) by withdrawing your consent for us to
use it; (b) if it is no longer necessary for us to use your personal data; (c)
if you object to the use of your personal data and we don't have a good reason
to continue to use it; or (d) if we haven't handled your personal data in
accordance with our obligations.
Where can I find more information about PTUK’s handling of my data?
Should you have any queries
regarding this Privacy Notice, about PTUK's processing of your personal data or
wish to exercise your rights, you can contact PTUK’s Data Controller using this
email address: email@example.com.
If you are not happy with
our response, you can contact the Information Commissioner's Office: https://ico.org.uk/
Issued: May 9th 2018