PRIVACY POLICY

Last updated 3rd June 2016

 

Data Protection and Privacy

“Data Protection Acts” means legislation in force in the UK from time to time intended to protect data relating to individuals and their privacy.

IMPORTANT: As owners of this website we are committed to the privacy and confidentiality of any information entered into this website. We shall take reasonable steps to protect the information collected from you and other web users and use such information only for the purpose for which it was provided. By entering personal data and/or by using this website you give your consent that all personal data entered may be processed in the manner and for the purposes described below. Personal and Clinical Data (as defined herein) entered onto this site may also form part of your medical records and can be used as appropriate by your healthcare provider (e.g. NHS).

Scope of Privacy Policy

This Privacy Policy (“Privacy Policy”) describes the current policies and practices with regard to Personal and Clinical Data (“Personal and Clinical Data”) entered into CCBT to the extent that such Personal and Clinical Data is protected by applicable European data protection laws. The term “Personal and Clinical Data” refers to personally identifiable information about you, such as your name, job description, health related data, birthdate, e-mail address or mailing address, as well as personal clinical data that you may enter into the website, such as GP details, transcripts of therapy sessions, questionnaire scores and messages.

Notification of changes to Privacy Policy

Due to, among other things, changes to the website, changes in the law and the changing nature of technology, our data practices will change from time to time. If and when our data practices change, we will update this Privacy Policy, to reflect the changes. Each time you visit this website or any CCBT website it is your responsibility to review the most current Terms of Use and any other policies, restrictions, conditions and notices on this website or any CCBT website you access. By accessing, browsing, and/or using this website or any CCBT website, you accept and agree to be bound by the most current Terms of Use and any other policies, restrictions, conditions and notices on this website or such other CCBT website.

CCBT may use and disclose your activity information unless restricted by this policy or by law.

 

Collection of Personal and Clinical Data including e-mail addresses

When you choose to register on CCBT we request personal information about you such as your name, e-mail address and telephone number. We may also ask for demographic information such as age and gender. As mentioned above, you will also be required to provide, and / or we will store, certain clinical data that is sensitive information. The information you provide is electronically stored in our databases.

We and you undertake to one another, where applicable:

  • to comply at all times with the Data Protection Acts;
  • to obtain and/or maintain all necessary registrations and/or notifications required by the Data Protection Acts; and
  • not to do or permit anything to be done which may cause the other to be in breach of the Data Protection Acts including, without limitation, the improper collection, use, disclosure or loss of data held on any computer or other equipment or held by way of manual or other non-computerised systems and any kind of improper use, disclosure or abuse of computer passwords.

We are committed to protecting your privacy but we cannot guarantee the security of information disclosed by you online, and you must assume the entire risk for using the website. Please therefore be careful and responsible when maintaining the secrecy of any password and/or account information online.

All information submitted by you, including your address and your email address, is automatically encrypted using the Secure Socket Layer (SSL) protocol, the industry standard for the transfer of sensitive data on the internet.

In the event that CCBT is or is proposed to be sold or integrated into another business, your details may be disclosed to our prospective purchaser’s advisers and subsequently to the new owners.

On request by you, by a court of law or any other body entitled thereto by law, we will supply information on your stored data and correct, delete or prevent the further use of the data held.

Use of Personal and Clinical Data

Your Personal and Clinical Data is only used for the following purposes:

  • To help provide an effective standard of personal care.
  • To help your healthcare provider (e.g. NHS) assess, monitor and improve the services provided.
  • To allow us to administer this website efficiently.

Use of Clinical Data

The information that you enter into CCBT is completely confidential and will not be made available to anyone, except in the following circumstances:

  • Monitoring of your progress through the website. It will be clear when entering information, which information will be available.
  • We may require access to this data to help support you to use the website.
  • We may provide access to a third party contracted by us, to help to support you use the website. Before disclosing Personal and Clinical Data to a third party, we contractually require the third party to take adequate precautions to protect that data and to comply with applicable law.

Data Retention

We will retain personal data on behalf of individuals indefinitely for clinical and operational purposes.

Individuals can request that we delete their data. This means:

  • We will overwrite or delete personally identifiable information, including without limitation name, email address, mobile number, postal address and NHS number.
  • We will retain non-identifiable information, such as ethnicity, disability and diagnosis, which we require for research and statistical purposes for product and service improvement.
  • We will remove personally identifiable references within text records, such as appointment transcripts and case notes. This will be done manually or automatically when the technology is available.
  • We will not remove data held by third parties, such as payment gateway providers.

Anonymous data collected through this website

CCBT reserves the right to anonymise (modify to render anonymous) any data collected from you. Once rendered anonymous these data may be used by CCBT to support research activities, provided that your identity is kept anonymous at all times and cannot be derived from the anonymised data.

Also, summaries of anonymous Personal and Clinical Data (for example average scores of all users on questionnaires) will be used to improve the service, and may be used in publications or presentations at conferences or on the website to indicate the effectiveness of the service. This anonymous data will consist solely of summary information and will not include any personal information that can be used to identify the users of the service. Your use of the service implies consent for the use of summary data in this way. In addition to the information we collect as described above, we use technology to collect anonymous information about the use of our website. For example, our web server automatically logs which pages of our website our visitors view, their IP addresses and which web browsers our visitors use. This technology does not identify you personally, it simply enables us to compile statistics about our visitors and their use of our website. Our website contains hyperlinks to other pages on our website. We may use technology to track how often these links are used and which pages on our website our visitors choose to view. Again this technology does not identify you personally – it simply enables us to compile statistics about the use of these hyperlinks.

Cookies

In order to collect the anonymous data described in the preceding paragraph, we may use temporary “cookies” that remain in the cookies file of your browser until the browser is closed. Cookies by themselves cannot be used to discover the identity of the user. A cookie is a small piece of information that is sent to your browser and stored on your computer’s hard drive. Cookies do not damage your computer.

We also use your IP address to help diagnose problems with our server and to administer our website. An IP address is a numeric code that identifies your computer on a network or, in this case, the Internet. Your IP address is also used to gather broad demographic information. We may also perform IP lookups to determine which domain you are coming from (e.g., aol.com, yourcompany.com) to more accurately gauge our users’ demographics.

Analytics

We may use third party analytics solutions to gather information and aggregate data from our website visitors such as which pages are visited and how often they are visited, and to enable certain features on our websites. Information is captured using various technologies and may include third party cookies.

Log Files

Log files are pieces of information that let us know how people are accessing CCBT websites. Each time you go to a page in our websites, our server shows this page on your computer. When the page displays, we create a log file that tells us that someone visited the page. We do not collect any personally identifiable information about you in the log files. CCBT uses log files to create aggregate reports of site activity. This means we take the information about our visitors and add it together to report on all pages of the site visited. We do share the reports of aggregate usage of our sites with our customers. In order to service you, if you sign-in to a CCBT secure website, CCBT may collect, track, and securely transmit certain website data and activity to CCBT’s back office systems, in order to allow you to securely access your personally-identifiable information.

Email

Please note that individualized information transmitted via email correspondence between you and CCBT — as opposed to transmission over CCBT’s website — is not encrypted. As a result, like most, if not all, non-encrypted Internet email communications, such email correspondence may be accessed and viewed by other Internet users without your knowledge and permission while in transit. For that reason, to protect your privacy, if you have concerns or questions that would involve the communication of confidential/personal health information, please call your physician or other healthcare professional. All users of secure sign-in websites are required to use a user ID and password to further protect privacy. It is very important not to share with or give your user ID or password to anyone, and also give thought to any person(s) who may have access to your account.

You agree that any comments, suggestions or other information sent to CCBT by way of this site is provided without restriction or obligation on CCBT and CCBT will be free to use such information on an unrestricted basis. You also agree:

  1. That information submitted is at your own risk,
  2. CCBT has no liability with respect to any unauthorized access by third parties,
  3. You are responsible for whatever material you submit and
  4. You, not CCBT, have full responsibility for any submitted message, including without limitation its legality, reliability, accuracy, completeness, appropriateness, originality and copyright.

Electronic or hard copies of the information captured through this website system may be archived or retained in CCBT files or systems. Information from emails may be transcribed into other CCBT systems such as a calls database.

Where sign-in is required to access a website, email addresses are collected as part of the registration process for the website. Email addresses are used to notify users of online activity related to the security and privacy of their accounts, such as requests to change a password or requests to change an address. These email communications are necessary to protect the privacy and security of your account. CCBT does not sell, rent, lease or give away user email addresses. CCBT does not share your email information with third parties other than for providing service to you and except as permitted by this Privacy Policy.

Security

A range of security features protect the privacy of any individualized information you provide over a secure sign-in to the CCBT website. During transmission over a secure sign-in website, your privacy is protected by 128-bit or greater cryptographic security. Other security safeguards are also in place.

CCBT uses physical, technical, and administrative safeguards to protect any personally identifiable data stored on its computers. Only authorized employees and third parties have access to the information you provide to CCBT for providing service to you.

Linked sites

CCBT’s website may have links to various other websites that we think might be useful or of interest to you, but are not operated by us. CCBT, however, cannot be responsible for, and does not endorse the privacy practices or the content of, its linked websites. CCBT urges you to review the privacy policies of any websites you visit once you leave CCBT’s website and before using the site or providing any Personal and Clinical Data about yourself. Links to various non-CCBT websites do not constitute or imply endorsement by CCBT of these websites or any association with their operators, any products or services described on these sites or of any other material contained within them.

Disclosure of your Personal and Clinical Data

We do not share, sell or distribute your Personal and Clinical Data with unrelated third parties, except as otherwise provided for in this Privacy Policy and under these limited circumstances:

  • We may share, transfer or disclose the information in our databases and server logs to comply with a legal requirement, for the administration of justice, interacting with anti-fraud databases, to protect your vital interests, to protect the security or integrity of our databases or this website, or to take precautions against legal liability. We will inform you of any such transfer or disclosure as required by law.
  • In special cases such as, to protect any individual’s personal safety, health or welfare in an emergency situation including without limitation if you threaten to harm yourself or others.
  • Someone believes that abuse or neglect might be occurring. Information concerning such abuse or neglect would be reported to the appropriate authorities.
  • When you consent to disclosure in writing.
  • When information is disclosed to medical or other emergency personnel in a medical emergency.
  • If you pose a danger to yourself or others, or threaten to commit a serious crime. This disclosure could involve law enforcement and, in the case of harm to others, the potential victim.
  • To comply with any subpoenas or court orders, to protect rights or defend any legal or administrative proceedings, or is in good faith necessary to comply with any laws or legal requirements.
  • To your payer/health care organization or others responsible for the payment of the services to you.
  • In the event of a sale or change in corporate control, for example, a merger, a sale of assets, or bankruptcy.
  • To affiliates, our business partners, vendors, suppliers and agents and others providing or participating in the services or functionality for the services to you, such as financial institutions, suppliers, providers, delivery services, parties providing hosting services, and web and technical support providers, as is necessary or required in connection with the operation, maintenance and support of this website, applicable software and/or the services, in which case we will request that such third parties maintain the confidentiality of your information.
  • Corporate administration or other lawful needs subject to the terms of this Privacy Policy.
  • To a provider/health care organization or health care professional who has referred you to this website ancillary to your treatment. In this case, the use of your Personal and Clinical Data by any such third party shall be subject to the terms of the privacy statement issued by that third party and we are not responsible for such use by such third party.
  • To a provider to whom you are referred as part of this website.
  • To an organization that is providing your access to this website, if applicable, as part of a health, wellness or insurance program.

Where appropriate, before disclosing Personal and Clinical Data to a third party, we contractually require the third party to take adequate precautions to protect that data and to comply with applicable law.

Data access and corrections

Data entered onto this site may form a part of your medical records. If you wish the Personal and Clinical Data we hold to be disclosed to you, then you should make this request through your healthcare provider. Requests to delete Personal and Clinical Data can only be made through your health care provider and are subject to any applicable legal and ethical reporting or document retention obligations imposed on us. For all changes you should contact CCBT.

Your obligations

It is your responsibility to keep your password safe and to ensure that when using the website, it cannot be accessed by other people without your consent. CCBT cannot accept any liability for loss or disclosure of your Personal and Clinical Data resulting from your failure to keep your password safe or allowing unauthorised persons access to the website whilst it is in use by you.

Transfer of data abroad

If you are visiting this website from a country other than the country in which our servers are located (currently UK), the various communications will necessarily result in the transfer of information across international boundaries. By accessing, browsing and/or using this website and communicating electronically with us, you consent to the processing and transfer of your Personal and Clinical Data as set out in this Privacy Policy.