This privacy notice is to let you know how The National Council for Hypnotherapy (‘NCH’) look after your personal information. This includes what we learn from you as our member, by what you tell us and the choices you select in the way we communicate with you. This notice explains how the NCH protects your information, including the data which is collated when you use our website and our services.
This policy will be updated from time to time in line with the General Data Protection Regulations (‘GDPR’) or current legislation.
Lawful Basis for Processing Information
To perform its function as a membership organisation, the NCH needs to collect and use certain types of information about people who apply or who are members. We consider that our lawful basis for processing information is one of legitimate interest as without collecting and keeping your information we are unable to provide the service that our members require.
The NCH is committed to the lawful and correct treatment of personal information in line with the General Data Protection Regulations and have taken all reasonable precautions regarding the storage and processing of your information to ensure that it is protected.
The Data Controller is:
The NCH Board
The Data Processors are:
The Board and Officers known as “The Executive”.
From time to time we will contract with external agencies to provide services on our behalf. In all instances we will seek written assurance that these agencies are compliant with the GDPR principles.
The GDPR Principles
The NCH will ensure personal data is:
- Processed fairly, lawfully and in a transparent manner in relation to the data subject.
- Collected for specified, explicit and legitimate purposes and not further processed for other purposes incompatible with those purposes.
- Adequate, relevant and limited to what is necessary in relation to the purposes for which data is processed.
- Accurate and, where necessary, kept up to date.
- Kept in a form that permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed.
- Processed in a way that ensures appropriate security of the personal data including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
Use of Your Personal Data
We will use personal information provided by you for the necessary purpose of registration, or gathered by the NCH for the following purposes:
- To decide your eligibility for membership
- To enable the general public to search the Register to check your registration status and to make contact with you
- To administer, update and maintain the Therapists Directory and the database which includes associate, student and and non practising members.
- To process and respond to requests, enquiries and complaints received from you
- To process and respond to requests, enquiries and complaints received about your standards and fitness to practise
- To process data relating to barred individuals
- To communicate with you about our services, events and news
- To communicate with you regarding membership benefits e.g. Hypnotherapy Journal and certificates
- To analyse trends and profiles and compile statistics
- To collect details of ethnicity for members completing the HPD and Supervisor Accredited Award for the purposes solely of forwarding to the NCFE as required by them.
- To ensure the Supervision Accredited Award is tailored to individual
needs we collect details of any learning requirements delegates may have.
This may involve collection of information relating to particular
diagnoses e.g. dyslexia
- For audit purposes
- To process membership details to CNHC, NCFE. P.A’ s and other similar bodies
- To survey registrants
- To prevent or detect fraud
- With your consent, to liaise with your supervisor regarding areas of development identified following a complaint.
- For Conference purposes, photographs will be taken, with your consent, and these will be used for the NCH website, Hypnotherapy Journal and in NCH marketing material.
We do not store bank or card details other than to process refunds which you request us to make and such data will be deleted immediately after we have actioned our part.
In order to comply with company law requirements we will hold your personal information on our systems for the duration of your membership and for a period of 7 years after your membership lapses.
In compliance with Article 5 of the GDPR, after this time we will delete your records in a secure manner unless there has been a complaint about your fitness to practice.
All details of complaints from the public and members against members of the NCH are retained for 3 years. After 3 years the information will be anonymised and stored for the purposes of precedent and identifying training improvements.
In compliance with company law requirements we will store historic data pertaining to NCH Executive decisions and actions for the duration of the existence of the National Council for Hypnotherapy Ltd.
What is visible to the Public?
We will make some of the information you provide to us visible to any enquirer on our website. The public can inspect the following information on the online register:
- Your full name
- Your registered discipline and qualifications
- Your practice post code you provide to us
N.B. this information can be your home address details if you do not have a separate practice address
- Your practice Town/City you provide to us
- Your practice telephone number(s) you provide to us
- Your website address you provide to us
- Your NCH registration number
- Your photograph provided to us
- Your details contained in your Overview
Your home address details (unless the same as your practice address), date of birth and other data are not available to the public unless given to us specifically for that purpose by you.
Collecting Personal Information
We will also hold details of any criminal convictions disclosed to us for the duration of the decision making process. If we determine that the conviction does not preclude you from being a member we will delete all reference to this. If we determine that it does mean that you can no longer be a member we will inform you of this and remove your information from public view but will retain your data for one year, in accordance with our Personal Data policy above.
The NCH will process personal information of the new applicant to perform its function. If an individual is not content to allow us to process personal information, that individual will not be eligible for membership.
Links to other websites
The NCH has social media accounts, should you wish to participate with these accounts and posts therein, your participation will be visible to the public.
We collect your data automatically via cookies when you visit our website, in line with cookie settings in your browser. If you would like to find out more about cookies, including how we use them and what choices are available to you, please click here. We will also collect data from you when you contact us via the website, for example by using the online form.
NCH contact with you
Members: We will contact you by telephone, letter and email and will seek consent if you prefer not to be contacted by email. If you would prefer not be contacted by one or more of these methods you can update your preferences by logging onto your membership page. You will be given the opportunity to unsubscribe to emails at any time.
Security and Storage of Your Personal Data
We will take appropriate technical and organisational measures to limit the opportunity for unauthorised or unlawful processing of personal data and to guard against accidental loss, destruction of, or damage to personal data.
Appropriate contractual obligations shall be incorporated into contracts that we enter into with third parties.
We will ensure that staff employed to undertake data processing are aware of their responsibilities in relation to the processing of personal data as it applies to their area of work.
Sharing of Personal Data
The Executive will share information between them from time to time, only in so far as is necessary to address or resolve an enquiry or dispute
We share information in the following circumstances:
• Where we are required to do so by law
• When it is in the public interest to do so
• When the Professional Standard Authority for Health and Social Care (PSA) requires us to disclose details of any complaint against you
• When you have given consent for us to do so
We may share your personal data with:
• Professional associations
• Other organisations that are holders of Accredited Registers
• Statutory health and social care regulators
Your Right to Access
You have the right to request a copy of the personal information that we hold about you and to have any inaccuracies corrected. Please refer to our Right to Access Policy.
Amendment of Personal Data Held
If you believe that incorrect personal information about you is held on the Therapists Directory, you may access your personal information details and make the appropriate amendment/s directly yourself. If you believe the NCH holds incorrect information you can apply for rectification. Please refer to our Rectification Policy.
Breach of Obligations
For any concerns regarding our application or a potential breach of our data protection policy please refer to our Rights under Breach of Policy.
Right of Erasure
Under Article 17 of the GDPR individuals have the right to have personal data erased. This is also known as the “right to be forgotten”. The right is not absolute and only applies in certain circumstances. Please refer to our Right of Erasure policy.
The NCH is registered with the Information Commissioner’s Office,
Reference Number: Z656424X
Date: 01 May 2018
Review: 01 May 2019