Privacy policy

As of January 2023

Table of contents

Identity and contact details of the data controller
Contact details of the data protection officer
General information on data processing
Rights of the data subject
Assessment for Adults
Assessments for Students of Universities and Colleges
Assessment for Children
Use of cookies
Contact via Email
Contact form
Application via Email
Hosting
Q-Interactive
CCTV

I. Identity and contact details of the data controller

The Data Controller responsible in accordance with the purposes of the UK General Data Protection Regulation (UK GDPR) and other data protection regulations is:

CF Psychology Group Limited

Pinero House, 115A Harley Street

London, W1G 6AR

United Kingdom

0207 101 3751

enquiries@cfpsychology.co.uk

www.cfpsychology.co.uk

II. Contact details of the data protection officer

The designated Data Protection Officer is:

DataCo International UK Limited

Suite 1, 7th Floor, 50 Broadway

London, United Kingdom

SW1H OBL

Telephone: +442035146557

Email: privacy@dataguard.co.uk

www.dataguard.co.uk

III. General information on data processing

1. Scope of processing personal data

We are an educational psychology practice comprising of a team of highly skilled practitioner psychologists who are experts in assessing the learning needs of children, young people and adults. This privacy policy applies in line with services rendered as part of our educational psychology practice and website users. The Clients and Users are identified as data subjects.

We only process the personal data of our Clients and Users to the extent necessary to provide a functioning website with our content and services. The regular processing of personal data only takes place with the consent of the Clients and Users. Exceptions include cases where prior consent cannot be technically obtained and where the processing of the data is permitted by law.

As part of our service, psychologists may discuss Client’s personal information in supervision with a supervisor, who is another psychologist, for the purpose of ensuring that their practice is safe and effective, and as mandated by their professional bodies. We do not reveal names when we share information in supervision. Supervisors do not share our client’s personal information with anyone else.

If applicable, we will from time to time write to referrers and stakeholders, such as parents, named individuals in schools, colleges or universities and other agencies, for example, following an assessment of learning abilities or emotional well-being. We will always obtain consent and discuss the content of such letters or reports before sending them.

2. Legal basis for data processing

Where consent is appropriate for processing personal data, Art. 6 (1) (a) UK GDPR serves as the legal basis to obtain the consent of the data subject for the processing of their data.

As for the processing of personal data required for the performance of a contract of which the data subject is party, Art. 6 (1) (b) UK GDPR serves as the legal basis. This also applies to processing operations required to carry out pre-contractual activities.

When it is necessary to process personal data in order to fulfil a legal obligation to which our company is subject, Art. 6 (1) (c) UK GDPR serves as the legal basis.

If vital interests of the data subject or another natural person require the processing of personal data, Art. 6 (1) (d) UK GDPR serves as the legal basis.

When it is necessary to process personal data for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller, Art. 6 (1) (e) UK GDPR serves as the legal basis.

If the processing of data is necessary to safeguard the legitimate interests of our company or that of a third party, and the fundamental rights and freedoms of the data subject do not outweigh the interest of the former, Art. 6 (1) (f) UK GDPR will serve as the legal basis for the processing of data.

3. Data removal and storage duration

The personal data of the data subject will be erased or restricted as soon as the purpose of its storage has been accomplished. Additional storage may occur as permitted under UK Law. Restriction or erasure of the data also takes place when the storage period expires, unless there is a need to prolong the storage of the data for the purpose of concluding or fulfilling a respective contract.

IV. Rights of the data subject

When your personal data is processed, you are a data subject within the meaning of the UK GDPR and have the following rights:

1. Right to information

You may request to us as the data controller to confirm whether your personal data is processed by them.

If such processing occurs, you can request the following information from the data controller:

The purpose for which the personal data is processed.
The categories of personal data being processed.
The recipients or categories of recipients to whom the personal data have been or will be disclosed.
The planned duration of the storage of your personal data or, if specific information is not available, criteria for determining the duration of storage.
The existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning you or to object to such processing.
The existence of the right to lodge a complaint with a supervisory authority.
Where personal data are not collected from you any available information as to their source.
The existence of automated decision-making including profiling under Article 22 (1) and Article 22 (4) UK GDPR and, in certain cases, meaningful information about the data processing system involved, and the scope and intended result of such processing on the data subject.

You have the right to request information on whether your personal data will be transmitted to a third country or an international organization. In this context, you can then request for the appropriate guarantees in accordance with Art. 46 UK GDPR in connection with the transfer.

2. Right to rectification

You have a right to rectification and/or modification of the data, if your processed personal data is incorrect or incomplete. The data controller must correct the data without delay.

3. Right to the restriction of processing

You may request the restriction of the processing of your personal data under the following conditions:

If you challenge the accuracy of your personal data for a period that enables the data controller to verify the accuracy of your personal data.
The processing is unlawful, and you oppose the erasure of the personal data and instead request the restriction of their use instead.
The data controller or its representative no longer need the personal data for the purpose of processing, but you need it to assert, exercise or defend legal claims; or
If you have objected to the processing pursuant to Art. 21 (1) UK GDPR and it is not yet certain whether the legitimate interests of the data controller override your interests.

If the processing of personal data concerning you has been restricted, this data may – with the exception of data storage – only be used with your consent or for the purpose of asserting, exercising or defending legal claims or protecting the rights of another natural or legal person or for reasons of important public interest of the United Kingdom.

If the processing has been restricted according to the aforementioned conditions, you will be informed by us as the data controller before the restriction is lifted.

4. Right to erasure

a) Obligation to erase

If you request from us as the data controller to delete your personal data without undue delay, they are required to do so immediately if one of the following applies:
Personal data concerning you is no longer necessary for the purposes for which they were collected or processed.
You withdraw your consent on which the processing is based pursuant to Art. 6 (1) (a) and Art. 9 (2) (a) UK GDPR and where there is no other legal basis for processing the data.
According to Art. 21 (1) UK GDPR you object to the processing of the data and there are no longer overriding legitimate grounds for processing, or you object pursuant to Art. 21 (2) UK GDPR.
Your personal data has been processed unlawfully.
The personal data must be deleted to comply with a legal obligation in the UK.

b) Exceptions

The right to deletion does not exist if the processing is necessary:

to exercise the right to freedom of speech and information;
to fulfil a legal obligation required by UK Law or to perform a task of public interest or in the exercise of public authority delegated to the representative.
for reasons of public interest in the field of public health pursuant to Art. 9 (2) (h) and Art. 9 (2) (i) and Art. 9 (3) UK GDPR.
to enforce, exercise or defend legal claims.

5. Right to data portability

You have the right to receive your personal data given to us as the data controller in a structured and machine-readable format. In addition, you have the right to transfer this data to another person without hindrance by the data controller who was initially given the data, if:

the processing is based on consent in accordance with Art. 6 (1) (a) UK GDPR or Art. 9 (2) (a) UK GDPR or performance of a contract in accordance with Art. 6 (1) (b) UK GDPR and
the processing is done by automated means.

In exercising this right, you also have the right to transmit your personal data directly from one person to another, insofar as this is technically feasible. Freedoms and rights of other persons shall not be affected.

The right to data portability does not apply to the processing of personal data necessary for the performance of a task in the public interest or in the exercise of official authority delegated to us as the data controller.

6. Right to object

For reasons that arise from your particular situation, you have, at any time, the right to object to the processing of your personal data pursuant to Art. 6 (1) (e) or 6 (1) (f) UK GDPR; this also applies to profiling based on these provisions.

If the personal data relating to you are processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data in regard to such advertising; this also applies to profiling associated with direct marketing.

If you object to processing for direct marketing purposes, your personal data will no longer be processed for these purposes.

7. Right to complain to a supervisory authority

Without prejudice to any other administrative or judicial remedy, you shall have the right to complain to a supervisory authority, in the Member State of your residence, or your place of work or place of alleged infringement, if you believe that the processing of the personal data concerning you violates the UK GDPR. If you are located in the United Kingdom, you shall have the right to complain to the ICO if you are unhappy with how we have used you data and/or believe that the processing of the personal data concerning you violates the applicable law. The ICO´s address: Information Commissioner´s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF Helpline number: 0303 123 1113 ICO website: https://www.ico.org.uk

The supervisory authority to which the complaint has been submitted shall inform the complainant of the status and results of the complaint, including the possibility of a judicial remedy pursuant to Art. 78 UK GDPR.

V. Assessment for Adults

1. Description and scope of data processing

These are assessments for over 18 year olds, who want to find out if they have a learning difficulty or need an assessment for professional exams, college or university courses.

Assessments can be conducted either in person or remotely via video conferencing.

The following information is collected as part of the assessment:

First name
Surname
Address
Email address
Date of Birth
Previous psychological and physical well-being
Current and previous educational and psychometric data
Current and previous social, educational and family circumstances

2. Purpose of data processing

We collect information in order to provide psychological formulations, recommendations and interventions. This information is confidential.

3. Legal basis for data processing

The legal basis for the processing of personal data Art. 6 (1) (a) UK GDPR. We have explicit consent of our Clients, this is also the case for Special Category data pursuant to Article 9 (1) (a) UK GDPR.

4. Duration of storage and possibility of objection and removal

The data will be stored for a minimum period of 7 years in accordance with The British Psychological Society Practice Guidelines, Third Edition, 2017.

5. Objection and removal

The Client can withdraw consent to the processing of their personal data and the service at any time. There will be additional elements for consideration when terminating the service. In the first instance, please contact us at enquiries@cfpsychology.co.uk

VI. Assessment for Students of Universities and Colleges

1. Description and scope of data processing

These are assessments for students who require evidence of a specific learning difficulty Disabled Student Allowance (DSA) applications and exam concessions (e.g. extra time in exams) for undergraduate and postgraduate study.

Assessments are conducted remotely via video conferencing. The assessments can be funded either by students or by institutions.

The following information is collected as part of the assessment:

First name
Surname
Address
Email address
Phone number
Date of Birth
Student ID
University Name
University Address
Previous psychological and physical well-being
Current and previous educational and psychometric data
Current and previous social, educational and family circumstances

2. Purpose of data processing

We collect information in order to provide psychological formulations, recommendations and interventions. This information is confidential.

3. Legal basis for data processing

The legal basis for the processing of personal data Art. 6 (1) (a) UK GDPR. We have explicit consent of the Student, this is also the case for Special Category data pursuant to Article 9 (1) (a) UK GDPR.

4. Duration of storage and possibility of objection and removal

The data will be stored for a minimum period of 7 years in accordance with The British Psychological Society Practice Guidelines, Third Edition, 2017.

5. Objection and removal

The Student can withdraw consent to the processing of their personal data and the service at any time. There will be additional elements for consideration when terminating the service. In the first instance, please contact us at enquiries@cfpsychology.co.uk

VII. Assessments for Children

1. Description and scope of data processing

These are assessments Children where parents are concerned about their Child’s learning and want to find the cause of the problem.

Assessments can be conducted either in person or remotely via video conferencing.

The following information is collected as part of the assessment:

Child’s First name
Child’s Surname
Child’s Date of Birth
Parent/Guardian First name
Parent/Guardian Surname
Parent/Guardian Email address
Parent/Guardian phone number
Address
Name of School
Name of teachers/ SENCo
Previous psychological and physical well-being
Current and previous educational and psychometric data
Current and previous social, educational and family circumstances

2. Purpose of data processing

We collect information in order to provide psychological formulations, recommendations and interventions. This information is confidential.

3. Legal basis for data processing

The legal basis for the processing of personal data Art. 6 (1) (a) UK GDPR. We have explicit consent of the Parent or Guardian, this is also the case for Special Category data pursuant to Article 9 (1) (a) UK GDPR.

4. Duration of storage and possibility of objection and removal

The data will be stored for a minimum period of 7 years or until the 26th birthday in accordance with The British Psychological Society Practice Guidelines, Third Edition, 2017 and NHS Records Management Code of Practice, 2021.

5. Objection and removal

The Parent or Guardian can withdraw consent to the processing of their personal data and the service at any time. There will be additional elements for consideration when terminating the service. In the first instance, please contact us at enquiries@cfpsychology.co.uk

VIII. Use of cookies

1. Description and scope of data processing

When you visit our website, we use technical tools for various functions, in particular cookies, which can be stored on your device. When you visit our website for the first time and at any time later, you have the choice of whether you generally permit the setting of cookies or which individual additional functions you would like to select. You can make changes in your browser settings or via our consent manager. Cookies are text files or information in a database that are stored on your hard drive and assigned to the browser you are using so that certain information can be passed to the entity that sets the cookie. Below we describe what kind of cookies we use:

We use technically necessary cookies, which are required for the technical structure of the website. Without these cookies, our website cannot be displayed (completely correctly) or the support functions are not possible.

The following data is stored and transmitted in the technically necessary cookies:

Log-in information
Storage of search queries
Functionality of the website

2. Purpose of data processing

The purpose of using technically necessary cookies is to ensure the functionality of our website. Some functions of our website cannot be offered without the use of cookies. For these, it is necessary that the browser is recognized even after a page change.

We need technical necessary cookies for the following purposes:

Storage of search terms

3. Legal basis for data processing

The legal basis for the processing of personal data using non-technical cookies is Art. 6 (1) (a) UK GDPR.

4. Duration of storage and possibility of objection and removal

Cookies are stored on the user's device and transmitted to our site by the user. Therefore, you as a user also have full control over the use of cookies. You can deactivate or restrict the transmission of cookies by changing the settings in your Internet browser. Cookies that have already been saved can be deleted at any time. This can also be done automatically. If cookies are deactivated for our website, it is possible that not all functions of the website can be used to their full extent.

If you use the Safari browser version 12.1 or higher, cookies will be automatically deleted after seven days. This also applies to opt-out cookies, which are used to prevent the use of tracking mechanisms.

IX. Contact via Email

1. Description and scope of data processing

You can contact us via the email address provided on our website. In this case the personal data of the user transmitted with the email will be stored.

The data will be used exclusively for the processing of the conversation.

2. Purpose of data processing

If you contact us via email, this also constitutes the necessary legitimate interest in the processing of the data.

3. Legal basis for data processing

If the user has given consent, the legal basis for processing the data is Art. 6 (1)(a) UK GDPR.

The legal basis for the processing of data transmitted while sending an email is Art. 6 (1) (f) UK GDPR. If the purpose of the email contact is to conclude a contract, the additional legal basis for the processing is Art. 6 (1) (b) UK GDPR.

4. Duration of storage

The data will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected. For personal data sent by email, this is the case when the respective conversation with the user has ended. The conversation ends when it can be concluded from the circumstances that the matter in question has been conclusively resolved.

The additional personal data collected during the sending process will be deleted after a period of seven days at the latest.

5. Objection and removal

The user has the possibility to withdraw consent to the processing of their personal data at any time. If the user contacts us by email, he can object to the storage of his personal data at any time.

In this case, all personal data stored while establishing contact will be deleted.

X. Contact form

1. Description and scope of data processing

A Contact form is available on our website, which can be used for electronic contact. If a user makes use of this option, the data entered in the input mask will be transmitted to us and stored.

When sending the message the following data will also be stored:

Email address
Last name
First name
Telephone / mobile phone number
Date and time of contact
Is the assessment for an adult or child?
Message

2. Purpose of data processing

The processing of the personal data from the input mask as well as if you contact us by mail serves us exclusively for the purpose of establishing contact.

The other personal data processed during the sending process serve to prevent misuse of the Contact form and to ensure the security of our information technology systems.

3. Legal basis for data processing

The legal basis for the processing of data transmitted while sending an email is Art. 6 (1) (f) UK GDPR. Our legitimate interest is to provide you with the best possible response to the request you send to us via the contact form. If the purpose of the email contact is to conclude a contract, the additional legal basis for the processing is Art. 6 (1) (b) UK GDPR.

4. Duration of storage

The data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected. For the personal data from the input mask of the Contact form and those sent by email, this is the case when the respective conversation with the user has ended. The conversation ends when it can be inferred from the circumstances that the facts in question have been conclusively clarified.

5. Objection and removal

If the user contacts us via the input mask in the contact form or via e-mail, the user can object to the storage of his or her personal data at any time.

In this case, all personal data stored while establishing contact will be deleted.

XI. Application via Email

1. Scope of processing personal data

You can send us your application via email. We process your email address and the information you provide in the email.

In addition, we offer an applicant/talent pool.

Title
First name
Last name
Telephone / mobile phone number
Email address
Information on education and training
Curriculum vitae
Certificates

2. Purpose of data processing

The processing of personal data from the application form serves us solely to process your application.

3. Legal basis for data processing

The legal basis for the processing of the data is the initiation of the contractual relationship at the request of the data subject, Art. 6 (1) (b) Alt. 1 UK GDPR.

4. Duration of storage

After completion of the application procedure, the data will be stored for up to two months. Your data will be deleted after two months at the latest. In the event of a legal obligation, the data will be stored within the framework of the applicable provisions.

5. Objection and removal

You can withdraw consent to the processing of your personal data at any time.

In this case, all personal data stored while establishing contact will be deleted.

XII. Hosting

The website is hosted on servers of a service provider commissioned by us.

Our service provider is:

123Reg

The servers automatically collect and store information in so-called server log files, which your browser automatically transmits when you visit the website. The stored information is:

Browser type and version
Used operating system
Referrer URL
Hostname of the accessing computer
Time and date of the server request
IP address of the user's device

This data will not be merged with other data sources. The data is collected on the basis of Art. 6 (1) (f) UK GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimization of his website - and server log files are therefore recorded.

The server of the website is geographically located in the United Kingdom.

XIII. Q-Interactive

1. Description and scope of data processing

Q-Interactive, part of Q-Global is Pearson’s web-based system for assessments and reporting.

The following information is collected as part of the assessment and available on Q-Interactive:

First name
Surname, first three initials
Current educational and psychometric data

2. Purpose of data processing

This is an essential tool for assessment and processing as part of the service.

3. Legal basis for data processing

The legal basis for the processing is consent pursuant to Art. 6 (1) (a) UK GDPR. In addition, the processing is necessary for the realisation of the contractual obligation of the service according to Art. (6) (1) (b) UK GDPR.

4. Duration of storage and possibility of objection and removal

The data will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected.

5. Objection and removal

XIV. CCTV

1. Description and scope of data processing

For assessments in person, these take place within our Consulting Rooms in Harley Street.

The following is captured on CCTV:

Static and moving images of individuals

In limited circumstances, the data may be shared with others where it is necessary as a requirement by law, to assist with police investigations. There are no planned regular sharing with any external organisation.

2. Purpose of data processing

The CCTV in the Consulting Rooms are installed for the following reason:

to ensure the health and safety of employees, service users and visitors to the sites
to assist in safeguarding incidents
to detect, prevent or reduce the incidence of crime
to prevent and respond effectively to all forms of possible harassment and disorder
to reduce the fear of crime
to create a safer environment
to provide emergency services assistance
to assist with health and safety and other serious occurrences, including employment issues, for example, disciplinary investigations, where appropriate to do so
for the defence of the practice or its employees with regards to legal or insurance claims

3. Legal basis for data processing

The legal basis for the processing of personal data by CCTV is Art. 6 (1) (a) UK GDPR, Consent.

4. Duration of storage and possibility of objection and removal

The data will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected.

5. Objection and removal

The Client can opt for a virtual appointment instead. To discuss this please contact us at enquiries@cfpsychology.co.uk

This privacy policy has been created with the assistance of DataGuard.

Privacy policy

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