Copthall Health Privacy Policy

Introduction

This Privacy Policy explains what we do with your personal data, whether we are in the process of providing bespoke treatment and therapy sessions, continuing our relationship with you once you have recovered (aftercare), providing you with a service, receiving a service from you, or you are visiting our website.
It describes how we collect, use and process your personal data, and how, in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.
This Privacy Policy applies to the personal data of our WEBSITE USERS, CLIENTS, PARTNERS, SUPPLIERS AND OTHER PEOPLE WHOM WE MAY CONTACT to find out more about our Clients or whom they indicate is an emergency contact.
It is important to point out that we may amend this Privacy Policy from time to time. Please just visit this page if you want to stay up to date, as we will post any changes here.
If you are dissatisfied with any aspect of our Privacy Policy, you may have legal rights and, where relevant, we have described these as well.

What kind of personal data do we collect?

Client Data: To provide the best possible treatment or therapy opportunities that are tailored to you, we need to process certain information about you. We only ask for details that will genuinely help us to help you, such as your name, age, contact details, appropriate medical history, emergency contacts (and of course you may choose to share other relevant information with us). Where appropriate and in accordance with local laws and requirements, we may also collect information related to your general health, diversity information.
If you would like a more detailed description of the personal data that we collect about you, contact https://copthallhealth.co.uk/contact/

 

To the extent that you access our website we will also collect certain data from you. If you would like more information about this, please contact https://copthallhealth.co.uk/contact/:

Partner/Supplier Data: We need a small amount of information from our Partners/Suppliers to ensure that things run smoothly. We need contact details of relevant individuals at your organisation so that we can communicate with you. We also need other information such as your bank details so that we can pay for the services you provide (if this is part of the contractual arrangements between us).
If you would like a more detailed description of the personal data that we collect about you, please contact https://copthallhealth.co.uk/contact/

To the extent that you access our website we will also collect certain data from you. If you would like more information about this, please contact https://copthallhealth.co.uk/contact/

People whose data we receive from clients -such as emergency contacts: To provide Clients with suitable treatment or therapy safely and securely and to provide for every eventuality for them we need some basic background information. We only ask for very basic contact details, so that we can get in touch with you because you have been listed as an emergency contact for one of our Clients.
If you would like a more detailed description of the personal data that we collect about you, please contact https://copthallhealth.co.uk/contact

 

Website Users: We collect a limited amount of data from our website users which we use to help us to improve your experience when using our website and to help us manage the services we provide. This includes information such as how you use our website, the frequency with which you access our website, and the times that our website is most popular.
If you would like to find out more information about what data we collect about you when you visit our website, please contact https://copthallhealth.co.uk/contact/

 

A number of elements of the personal data we collect from you are required to enable us to fulfil our contractual duties to you or to others. Where appropriate, some, for example Clients National Insurance number and, religious affiliation, are required by statute or other laws. Other items may simply be needed to ensure that our relationship can run smoothly.

For details of the legal bases that we rely on to be able to use and process your personal data, please contact https://copthallhealth.co.uk/contact/

How do we collect your personal data?
Client Data: There are two main ways in which we collect your personal data:
1 Directly from you; and
2 From third parties (e.g. our Suppliers) and other limited sources (e.g. online and offline media).

If you would like to know more about how we collect your personal data, please contact https://copthallhealth.co.uk/contact/

To the extent that you access our website or read or click on an email from us, we may also collect certain data automatically or through you providing it to us. For more information please contact https://copthallhealth.co.uk/contact/

Partner/Supplier Data: We collect your personal data during our work with you.
To the extent that you access our website or read or click on an email from us, we may also collect certain data automatically or through you providing it to us. For more information please contact https://copthallhealth.co.uk/contact/

People whose data we receive from clients -such as emergency contacts: We collect your contact details only where a Client puts you down as their emergency contact.

 

Website Users: We collect your data automatically via cookies when you visit our website, in line with cookie settings in your browser. We will also collect data from you when you contact https://copthallhealth.co.uk/contact/

 

How do we use your personal data?

Client Data: The main reason for using your personal details is to help design bespoke service, treatment or therapy that might be suitable for you. The more information we have about you, your condition, medical history and general health the more bespoke we can make our service; and to ensure that the contractual arrangements between us can properly be implemented so that the relationship can run smoothly. Where appropriate and in accordance with local laws and requirements, we may also use your personal data for things like marketing, profiling and diversity monitoring. Where appropriate, we will seek your consent to undertake some of these activities.

Partner/Supplier Data: The main reasons for using your personal data are to ensure that the contractual arrangements between us can properly be implemented so that the relationship can run smoothly, and to comply with legal requirements.

Website Users: We use your data to help us to improve your experience of using our website to enhance other aspects of our communications with, or service to, you.

Please note that communications to and from COPTHALL HEALTH including emails may be reviewed as part of internal or external investigations or litigation.
Who do we share your personal data with?

Client Data: We may share your personal data with various parties, in various ways and for various reasons. Unless you specify otherwise, we may also share your information with any of our associated third parties such as our service providers where we feel this will help us to provide you with the best possible service.

If you would like to see a list of who we may share your personal data with, please contact https://copthallhealth.co.uk/contact/

 

Partner/Supplier Data: Unless you specify otherwise, we may share your information with any of our associated third parties such as our service providers and organisations to whom we provide services.
People whose data we receive from clients -such as emergency contacts: Unless you specify otherwise, we may share your information with any of our associated third parties such as our service providers and organisations to whom we provide services.
If you would like to see a list of who we may share your personal data with, please contact https://copthallhealth.co.uk/contact/

 

Website Users: Unless you specify otherwise, we may share your information with providers of web analytics services, marketing automation platforms and social media services to make sure any advertising you receive is targeted to you.
How do we safeguard your personal data?

We care about protecting your information. That’s why we put in place appropriate measures that are designed to prevent unauthorised access to, and misuse of, your personal data.
For more information on the procedures we put in place please contact https://copthallhealth.co.uk/contact/

 

How long do we keep your personal data for?

If we have not had meaningful contact with you for a period of two years, we will DELETE your personal data from our systems unless we believe in good faith that the law or other regulation requires us to preserve it (for example, because of our obligations to tax authorities or relating to any anticipated litigation).
For more information on our policy for the retention of personal data please contact https://copthallhealth.co.uk/contact/

 

How can you access, amend or take back the personal data that you have given to us?

 

Even if we already hold your personal data, you still have various rights in relation to it. For information about these, please CONTACT US   We will seek to deal with your request without undue delay, and in any event in accordance with the requirements of any applicable laws. Please note that we may keep a record of your communications to help us resolve any issues which you raise.
Right to Object: If we are using your data because we deem it necessary for our legitimate interests to do so, and you do not agree, you have the right to object. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases). Generally, we will only disagree with you if certain limited conditions apply.
Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example, for profiling your suitability for certain roles), or consent to market to you, you may withdraw your consent at any time.
Data Subject Access Requests (DSAR): Just so it’s clear, you have the right to ask us to confirm what information we hold about you at any time, and you may ask us to modify, update or   DELETE such information. At this point we may comply with your request or, additionally do one of the following:

– we may ask you to verify your identity, or ask for more information about your request; and
– where we are legally permitted to do so, we may decline your request, but we will explain why if we do so.
Right to Erasure: In certain situations (for example, where we have processed your data unlawfully), you have the right to request us to “erase” your personal data. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases) and will only disagree with you if certain limited conditions apply. If we do agree to your request, we will DELETE  your data but will generally assume that you would prefer us to keep a note of your name on our register of individuals who would prefer not to be contacted. That way, we will minimise the chances of you being contacted in the future where your data are collected in unconnected circumstances. If you would prefer us not to do this, you are free to say so.
Right of Data Portability: If you wish, you have the right to transfer your data from us to another data controller. We will help with this – either by directly transferring your data for you, or by providing you with a copy in a commonly used machine-readable format.
Right to lodge a complaint with a Supervisory Authority: You also have the right to lodge a complaint with your local supervisory authority, details of which are:

Phone: 0303 123 1113

Email: casework@ico.org.uk

Post: Information Commissioner’s Office

Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
If your interests or requirements change, you can unsubscribe from part or all our marketing content (for example Health Updates) by clicking the unsubscribe link in the email.
If you would like to know more about your rights in respect of the personal data we hold about you, please contact https://copthallhealth.co.uk/contact/

 

 

Who is responsible for processing your personal data on the COPTHALL HEALTH website?

 

COPTHALL HEALTH controls the processing of personal data on its website(s).
If you’ve got any further questions, or want further details, please contact  https://copthallhealth.co.uk/contact/

 

 

What are cookies and how do we use them?

 

A “cookie” is a bite-sized piece of data that is stored on your computer’s hard drive. They are used by nearly all websites and do not harm your system. We use them to track your activity to help ensure you get the smoothest possible experience when visiting our website. We can use the information from cookies to ensure we present you with options tailored to your preferences on your next visit. We can also use cookies to analyse traffic and for advertising purposes.
If you want to check or change what types of cookies you accept, this can usually be altered within your browser settings.
If you want to find out more about cookies, including how we use them and what choices are available, please contact https://copthallhealth.co.uk/contact/

 

How to reject cookies

 

If you don’t want to receive cookies that are not strictly necessary to perform basic features of our site, you may choose to opt-out by changing your browser settings
Most web browsers will accept cookies but if you would rather we didn’t collect data in this way you can choose to accept all or some, or reject cookies in your browser’s privacy settings. However, rejecting all cookies means that you may not be able to take full advantage of all our website’s features. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences.
For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.
 

 

LONG FORM DETAILED SECTIONS

WHAT KIND OF PERSONAL INFORMATION DO WE COLLECT?

So, you are looking for a bit more insight into what data we collect about you? Here’s a more detailed look at the information we may collect. The information described below is, of course, in addition to any personal data we are required by law to process in any given situation.

CLIENT DATA

 

Depending on the relevant circumstances and applicable local laws and requirements, we may collect some or all the information listed below to enable us to offer you services, treatment or therapy opportunities which are tailored to your circumstances and your interests. In some jurisdictions, we are restricted from processing some of the data outlined below. In such cases, we will not process the data in those jurisdictions:

-Name;
-Age/date of birth;
-Birth number;
-Sex/gender;
-Photograph;
-Marital status;
-Contact details;
-Emergency contact details;

-National Insurance number;
-Diversity information including racial or ethnic origin, religious or other similar beliefs, and physical or mental health, including disability-related information;
-Details of any Insurance cover you have;
-Extra information that you choose to tell us;
-IP address;
-The dates, times and frequency with which you access our services; and
-CCTV footage if you attend our premises.
Please note that the above list of categories of personal data we may collect is not exhaustive.
 

To the extent that you access our website we will also collect certain data from you. If you would like more information about this, please contact https://copthallhealth.co.uk/contact/

 

SUPPLIER DATA

We don’t collect much data about PARTNERS/SUPPLIERS – we simply need to make sure that our relationship runs smoothly. We’ll collect the details for our contacts within your organisation, such as names, telephone numbers and email addresses. We’ll also collect bank details, so that we can pay you. We may also hold extra information that someone in your organisation has chosen to tell us. In certain circumstances, such as when you engage with our Administration team, our calls with you may be recorded, depending on the applicable local laws and requirements.

To the extent that you access our website we will also collect certain data from you. If you would like more information about this, please contact https://copthallhealth.co.uk/contact/

PEOPLE WHOSE DATA WE RECEIVE FROM EMERGENCY CONTACTS

All we need from EMERGENCY CONTACT REFEREES is confirmation of the contact details so that we can contact you in the event of an accident or an emergency.

WEBSITE USERS

 

We collect a limited amount of data from our WEBSITE USERS which we use to help us to improve your experience when using our website and to help us manage the services we provide. This includes information such as how you use our website, the frequency with which you access our website, your browser type, the location you view our website from, the language you choose to view it in and the times that our website is most popular. If you contact https://copthallhealth.co.uk/contact/ we will collect any information that you provide to us, for example your name and contact details.
If you would like to find out more information about what data we collect about you when you visit our website, please contact https://copthallhealth.co.uk/contact/

 

HOW DO WE COLLECT YOUR PERSONAL DATA?

CLIENT DATA

 

We collect personal data in three primary ways:
1. Personal data that you give to us;
2. Personal data that we receive from other sources; and
3. Personal data that we collect automatically.
Personal data you give to us

COPTHALL HEALTH needs to know certain information about you to provide a tailored service.
There are numerous ways you can share your information with us. It all depends on what suits you. These may include:

-Entering your details as part of the registration process at your initial consultation
-Where you contact https://copthallhealth.co.uk/contact/ proactively, usually by phone or email;
-Where we contact you, either by phone or email, or through our business development activities more generally.
-Entering your personal details onto a client agreement form or
-Entering a competition through a social media channel such as Facebook or Twitter
-If you ‘like’ our page on Facebook or ‘follow’ us on Twitter we will receive your personal information from those sites

PERSONAL DATA WE COLLECT AUTOMATICALLY

 

To the extent that you access our website or read or click on an email from us, where appropriate and in accordance with any local laws and requirements, we may also collect your data automatically or through you providing it to us. For more information please contact https://copthallhealth.co.uk/contact/

 

PERSONAL DATA WE RECEIVE FROM OTHER SOURCES

 

Where appropriate and in accordance with any local laws and requirements, we may seek more information about you from other sources generally by way of due diligence or other market intelligence including:
– From third party market research and by analysing online and offline media (which we may do ourselves, or employ other organisations to do for us);
– From your GP; and
– From other limited sources and third parties. (for example, Insurance Companies)

PERSONAL DATA WE COLLECT VIA OUR WEBSITE

 

To the extent that you access our website or read or click on an email from us, where appropriate and in accordance with any local laws and requirements, we may also collect your data automatically or through you providing it

WEBSITE USERS: When you visit our website, there is certain information that we may automatically collect, whether or not you decide to use our services. This includes your IP address, the date and the times and frequency with which you access the website and the way you browse its content. We will also collect data from you when you contact us via our website. (https://copthallhealth.co.uk/contact/

We collect your data automatically via cookies, in line with cookie settings in your browser.
HOW DO WE USE YOUR PERSONAL DATA?

Having obtained data about you, we then use it in several ways.

CLIENT DATA

We generally use Client data in three ways:

MARKETING ACTIVITIES

EQUAL OPPORTUNTIIES MONITORING

TO HELP US TO ESTABLISH, EXERCISE OR DEFEND LEGAL CLAIMS AND:
– Here are some more details:
– Storing your details (and updating them when necessary) on our database, so that we can contact you in relation to your health;
– Allowing you to participate in specialised online offers;
– Allowing you to participate in the interactive features of our services, when you choose to do so;
– Carrying out our obligations arising from any contracts entered into between us;
– Carrying out our obligations arising from any contracts entered into between COPTHALL HEALTH and third parties in relation to your treatment;
– Facilitating our invoicing processes;
– Carrying out customer satisfaction surveys;
– Processing your data to enable us to send you targeted, relevant marketing materials or other communications which we think are likely to be of interest to you.

We may use your personal data for the above purposes if we deem it necessary to do so for our legitimate interests. If you want to know more about what this means, please contact us https://copthallhealth.co.uk/contact/

 

If you are not happy about this, in certain circumstances you have the right to object and can find out more about how and when to do this please contact https://copthallhealth.co.uk/contact/

Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements. For more information in relation to your jurisdiction, please contact https://copthallhealth.co.uk/contact/

 

MARKETING ACTIVITIES

 

We may periodically send you information that we think you may find interesting. In particular, we may wish to use your data for the purposes listed below, where appropriate and in accordance with any local laws and requirements. Please note that this list is not exhaustive. To:
– enable us to develop and market other products and services;
– market our full range of services to you;
– send you details of reports, promotions, offers, networking and client events, and general information about the industry sectors which we think might be of interest to you;
– display promotional excerpts from your details on the COPTHALL HEALTH website(s) as a success story (only where we have obtained your express consent to do so); and
– provide you with information about certain discounts and offers that you are eligible for by virtue of your relationship with COPTHALL HEALTH.

 

We need your consent for some aspects of these activities which are not covered by our legitimate interests (, the collection of data via cookies, and the delivery of direct marketing to you through digital channels) and, depending on the situation, we’ll ask for this via an opt-in or soft-opt-in (which we explain further below). Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements.
Soft opt-in consent is a specific type of consent which applies where you have previously engaged with us and we are marketing other service, treatment-related services. Under ‘soft opt-in’ consent, we will take your consent as given unless or until you opt out. For most people, this is beneficial as it allows us to suggest other services to you. For other types of e-marketing, we are required to obtain your explicit consent.
If you want to know more about how we obtain consent, please contact  https://copthallhealth.co.uk/contact/

 

If you are not happy about our approach to marketing, you have the right to withdraw your consent at any time and can find out more about how to do so by contacting us via the email address found in the footnote of this document. Nobody’s perfect, even though we try to be. We want to let you know that even if you have opted out from our marketing communications, it is possible that your details may be recaptured through public sources in an unconnected marketing campaign. We will try to make sure this doesn’t happen, but if it does, we’re sorry. We’d just ask that in those circumstances you opt out again.
All our marketing is based on what we think will serve our CLIENTS best, but we know we won’t always get it right for everyone. We may use your data to show you COPTHALL HEALTH adverts and other content on other websites, for example Facebook. If you do not want us to use your data in this way, please turn off the “Advertising Cookies” option (please refer to our COOKIES POLICY). Even where you have turned off advertising cookies, it is still possible that you may see a COPTHALL HEALTH advert, but in this case, it won’t have been targeted at you personally, but rather at an anonymous audience.
EQUAL OPPORTUNITIES MONITORING AND OTHER SENSITIVE DATA

 

We are committed to ensuring that our recruitment processes are aligned with our approach to equal opportunities. Some of the data we may (in appropriate circumstances and in accordance with local law and requirements) collect about you comes under the umbrella of “diversity information”. This could be information about your ethnic background, gender, disability, age, sexual orientation, religion or other similar beliefs, and/or social-economic background. Where appropriate and in accordance with local laws and requirements, we’ll use this information on an anonymised basis to monitor our compliance with our equal opportunities policy.

 

This information is what is called ‘sensitive’ personal information and slightly stricter data protection rules apply to it. We therefore need to obtain your explicit consent before we can use it. We’ll ask for your consent by offering you an opt-in. This means that you must explicitly and clearly tell us that you agree to us collecting and using this information.
We may collect other sensitive personal data about you, such as health-related information. We will never do this without your explicit consent.
If you would like to find out more about consent, please contact https://copthallhealth.co.uk/contact/

 

Please note that in certain of the jurisdictions in which we operate, different rules apply to this sensitive data. For more information in relation to your jurisdiction, please contact us https://copthallhealth.co.uk/contact/

 

If you are not happy about this, you have the right to withdraw your consent at any time and you can find out how to do so by contacting us via the email address found in the footnote of this document.

To help us to establish, exercise or defend legal claims

In more unusual circumstances, we may use your personal data to help us to establish, exercise or defend legal claims.

CLIENT DATA: We use CLIENT information for:
– MARKETING ACTIVITIES and
-TO HELP US TO ESTABLISH, EXERCISE OR DEFEND LEGAL CLAIMS
﷟HYPERLINK “https://copthallhealth.co.uk/contact/s://www.hays.co.uk/revised-privacy-policy/index.htm”Here are some more details about each:

– Keeping records of our conversations and meetings, so that we can provide bespoke, meaningful e services to you;
– Undertaking customer satisfaction surveys; and
– Processing your data for the purpose of targeting appropriate marketing campaigns.
We may use your personal data for these purposes if we deem this to be necessary for our legitimate interests. If you would like to know more about what this means, please contact https://copthallhealth.co.uk/

If you are not happy about this, in certain circumstances you have the right to object and can find out more about how and when to do this by clicking https://copthallhealth.co.uk/contact/

 

MARKETING ACTIVITIES: Subject to any applicable local laws and requirements, we will not, as a matter of course, seek your consent when sending marketing materials such as our Global Skills Index to a corporate postal or email address.
If you are not happy about this, you have the right to opt out of receiving marketing materials from us and can find out more about how to do so by clicking https://copthallhealth.co.uk/contact/

 

Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements regarding marketing activities. For more information in relation to your jurisdiction, please contact https://copthallhealth.co.uk/contact/

 

To help us to establish, exercise or defend legal claims

In more unusual circumstances, we may use your personal data to help us to establish, exercise or defend legal claims.
SUPPLIER DATA: We realise that you’re probably busy, and don’t want us to be contacting you about all sorts of things. To find the right balance, we will only use your information:
– To store (and update when necessary) your details on our database, so that we can contact you in relation to our agreements;
– To offer services to you or to obtain support and services from you;
– To perform certain legal obligations;
– To help us to target appropriate marketing campaigns; and
– In more unusual circumstances, to help us to establish, exercise or defend legal claims.

We may use your personal data for these purposes if we deem this to be necessary for our legitimate interests. If you want to know more about what this means, please contact https://copthallhealth.co.uk/contact/

 

We will not, as a matter of course, seek your consent when sending marketing messages to a corporate postal or email address.
If you are not happy about this, in certain circumstances you have the right to object and can find out more about how to do so by clicking https://copthallhealth.co.uk/contact/

 

Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements For more information in relation to your jurisdiction, please contact https://copthallhealth.co.uk/contact/

 

WHO DO WE SHARE YOUR PERSONAL DATA WITH?

 

Where appropriate and in accordance with local laws and requirements, we may share your personal data, in various ways and for various reasons, with the following categories of people:

– Tax, audit, or other authorities, when we believe in good faith that the law or other regulation requires us to share this data (for example, because of a request by a tax authority or in connection with any anticipated litigation);
– Third party service providers who perform functions on our behalf (including external consultants, business associates and professional advisers such as lawyers, auditors and accountants, technical support functions and IT consultants carrying out testing and development work on our business technology systems);
– Third party outsourced IT and document storage providers where we have an appropriate processing agreement (or similar protections) in place;
– Marketing technology platforms and suppliers;
– If COPTHALL HEALTH merges with or is acquired by another business or company in the future, (or is in meaningful discussions about such a possibility) we may share your personal data with the (prospective) new owners of the business or company.

HOW DO WE SAFEGUARD YOUR PERSONAL DATA?

 

We are committed to taking all reasonable and appropriate steps to protect the personal information that we hold from misuse, loss, or unauthorised access. We do this by having in place a range of appropriate technical and organisational measures. These include measures to deal with any suspected data breach.
If you suspect any misuse or loss of or unauthorised access to your personal information please let us know immediately. Details of how to contact https://copthallhealth.co.uk/contact/

 

HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR?

 

We will delete your personal data from our systems if we have not had any meaningful contact with you (for two years (or for such longer period as we believe in good faith that the law or relevant regulators require us to preserve your data). After this period, it is likely your data will no longer be relevant for the purposes for which it was collected.
For those clients whose services are provided via a third-party company or other entity, “meaningful contact” with you means meaningful contact with the company or entity which supplies your services. Where we are notified by such company or entity that it no longer has that relationship with you, we will retain your data for no longer than two years from that point or, if later, for the period of two years from the point we subsequently have meaningful contact directly with you.
When we refer to “meaningful contact”, we mean, for example, communication between us (either verbal or written), or where you are actively engaging with our online services. Your receipt, opening or reading of an email or other digital message from us will not count as meaningful contact – this will only occur in cases where you click-through or reply directly.
HOW CAN YOU ACCESS, AMEND OR TAKE BACK THE PERSONAL DATA THAT YOU HAVE GIVEN TO US?

One of the GDPR’s main objectives is to protect and clarify the rights of EU citizens and individuals in the EU with regards to data privacy. This means that you retain various rights in respect of your data, even once you have given it to us. These are described in more detail below.
To get in touch about these rights, please CONTACT US. We will seek to deal with your request without undue delay, and in any event within one month (subject to any extensions to which we are lawfully entitled). Please note that we may keep a record of your communications to help us resolve any issues which you raise.
Right to object: this right enables you to object to us processing your personal data where we do so for one of the following four reasons: (i) our Legitimate Interests; (ii) to enable us to perform a task in the public interest or exercise official authority; (iii) to send you direct marketing materials; and (iv) for scientific, historical, research, or statistical purposes.
The “legitimate interests” and “direct marketing” categories above are the ones most likely to apply to our WEBSITE USERS, CLIENTS, PARTNERS AND SUPPLIERS. If your objection relates to us processing your personal data because we deem it necessary for your legitimate interests, we must act on your objection by ceasing the activity in question unless:
– we can show that we have compelling legitimate grounds for processing which overrides your interests; or
– we are processing your data for the establishment, exercise or defence of a legal claim.
If your objection relates to direct marketing, we must act on your objection by ceasing this activity.
Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example, for our marketing arrangements or automatic profiling), you may withdraw this consent at any time and we will cease to carry out the particular activity that you previously consented to unless we consider that there is an alternative reason to justify our continued processing of your data for this purpose in which case we will inform you of this condition.
Data Subject Access Requests (DSAR): You may ask us to confirm what information we hold about you at any time, and request us to modify, update or delete such information. We may ask you to verify your identity and for more information about your request. If we provide you with access to the information we hold about you, we will not charge you for this unless your request is “manifestly unfounded or excessive”. If you request further copies of this information from us, we may charge you a reasonable administrative cost where legally permissible. Where we are legally permitted to do so, we may refuse your request. If we refuse your request we will always tell you the reasons for doing so.
Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements regarding data subject access requests and may refuse your request in accordance with such laws. For more information in relation to your jurisdiction, please contact https://copthallhealth.co.uk/contact/

 

Right to Erasure: You have the right to request that we erase your personal data in certain circumstances. Normally, the information must meet one of the following criteria:
– the data are no longer necessary for the purpose for which we originally collected and/or processed them;
– where previously given, you have withdrawn your consent to us processing your data, and there is no other valid reason for us to continue processing;
– the data has been processed unlawfully (i.e. in a manner which does not comply with the GDPR);
– it is necessary for the data to be erased in order for us to comply with our legal obligations as a data controller; or
– if we process the data because we believe it necessary to do so for our legitimate interests, you object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing.
Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements regarding data subject right to erasure and may refuse your request in accordance with local laws.

For more information in relation to your jurisdiction, please contact https://copthallhealth.co.uk/contact/

 

We would only be entitled to refuse to comply with your request for one of the following reasons:

– to exercise the right of freedom of expression and information;
– to comply with legal obligations or for the performance of a public interest task or exercise of official authority;
– for public health reasons in the public interest;
– for archival, research or statistical purposes; or
– to exercise or defend a legal claim.

When complying with a valid request for the erasure of data we will take all reasonably practicable steps to DELETE the relevant data.
Right to Restrict Processing: You have the right to request that we restrict our processing of your personal data in certain circumstances. This means that we can only continue to store your data and will not be able to carry out any further processing activities with it until either: (i) one of the circumstances listed below is resolved; (ii) you consent; or (iii) further processing is necessary for either the establishment, exercise or defence of legal claims, the protection of the rights of another individual, or reasons of important EU or Member State public interest.
The circumstances in which you are entitled to request that we restrict the processing of your personal data are:
– where you dispute the accuracy of the personal data that we are processing about you. In this case, our processing of your personal data will be restricted for the period during which the accuracy of the data is verified;
– where you object to our processing of your personal data for our legitimate interests. Here, you can request that the data be restricted while we verify our grounds for processing your personal data;
– where our processing of your data is unlawful, but you would prefer us to restrict our processing of it rather than erasing it; and
– where we have no further need to process your personal data but you require the data to establish, exercise, or defend legal claims.
If we have shared your personal data with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal data.
Right to Rectification: You also have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you. If we have shared this personal data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. Where appropriate, we will also tell you which third parties we have disclosed the inaccurate or incomplete personal data to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.
Right of Data Portability: If you wish, you have the right to transfer your personal data between data controllers. In effect, this means that you are able to transfer your COPTHALL HEALTH account details to another online platform. To allow you to do so, we will provide you with your data in a commonly used machine-readable format that is password-protected so that you can transfer the data to another online platform. Alternatively, we may directly transfer the data for you. This right of data portability applies to: (i) personal data that we process automatically (i.e. without any human intervention); (ii) personal data provided by you; and (iii) personal data that we process based on your consent or in order to fulfil a contract.

Right to lodge a complaint with a supervisory authority: You also have the right to lodge a complaint with your local supervisory authority. Details of how to contact them are as follows:

Phone: 0303 123 1113

Email: casework@ico.org.uk

 

If you would like to exercise any of these rights, or withdraw your consent to the processing of your personal data (where consent is our legal basis for processing your personal data) please contact https://copthallhealth.co.uk/contact/

Please note that we may keep a record of your communications to help us resolve any issues which you raise.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during the period for which we hold your data.
WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL DATA ON THE COPTHALL HEALTH WEBSITE?

COPTHALL HEALTH is responsible for processing your personal data and where it is located.
If you have any comments or suggestions concerning this Privacy Policy please contact https://copthallhealth.co.uk/contact/

 

We take privacy seriously so we’ll get back to you as soon as possible.

 

COOKIES POLICY

What’s a cookie?

A “cookie” is a piece of information that is stored on your computer’s hard drive and which records your navigation of a website so that, when you revisit that website, it can present tailored options based on the information stored about your last visit. Cookies can also be used to analyse traffic and for advertising and marketing purposes.
Cookies are used by nearly all websites and do not harm your system. If you want to check or change what types of cookies you accept, this can usually be altered within your browser settings. We also provide information about this in our Marketing preferences page on the COPTHALL HEALTH website.

How do we use cookies?

 

We use cookies to do two things:
– to track your use of our website. This enables us to understand how you use the site and track any patterns that emerge individually or from larger groups. This helps us to develop and improve our website and services in response to what our visitors want and need.

Cookies are either:
– Session cookies: these are only stored on your computer during your web session and are automatically deleted when you close your browser – they usually store an anonymous session ID allowing you to browse a website without having to log in to each page but they do not collect any information from your computer; or
– Persistent cookies: a persistent cookie is stored as a file on your computer and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again. We use persistent cookies for Google Analytics and for personalisation (see below).
Cookies can also be categorised as follows:
Strictly necessary cookies: These cookies are essential to enable you to use the website effectively, such as when applying for a job, and therefore cannot be turned off. Without these cookies, the services available to you on our website cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
Performance cookies: These cookies enable us to monitor and improve the performance of our website. For example, they allow us to count visits, identify traffic sources and see which parts of the site are most popular.
Functionality cookies: These cookies allow our website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced features. For instance, we may be able to provide you with news or updates relevant to the services you use. These cookies can also be used to remember changes you have made to text size, font and other parts of web pages that you can customise. They may also be used to provide services you have requested such as viewing a video or commenting on a blog. The information these cookies collect is usually anonymised.
Personalisation cookies: These cookies help us to advertise details of potential job opportunities that we think may be of interest. These cookies are persistent (for as long as you are registered with us).

 

 

OUR LEGAL BASIS FOR PROCESSING YOUR DATA

 

LEGITIMATE INTERESTS

Article 6(1)(f) of the GDPR is the one that is relevant here – it says that we can process your data where it “is necessary for the purposes of the legitimate interests pursued by [us] or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of [you] which require protection of personal data.”
We don’t think that any of the following activities prejudice individuals in any way – in fact, they help us to offer you a more tailored, efficient service, so everyone’s a winner! However, you do have the right to object to us processing your personal data on this basis. If you would like to know more about how to do so, please contact https://copthallhealth.co.uk/contact/

Please note that in certain of the jurisdictions in which we operate, a different legal basis for data processing might apply in certain cases. For more information in relation to your jurisdiction, please contact https://copthallhealth.co.uk/contact/

 

CLIENT DATA:

We want to provide you with bespoke, holistic services and relevant articles to read to help you on maintain your health. We therefore think it’s reasonable for us to process your data to make sure that we send you the most appropriate content.
We must make sure our business runs smoothly, so that we can carry on providing services to Clients like you. We therefore also need to use your data for our internal administrative activities, like invoicing where relevant.

To ensure that we provide you with the best service possible, we store your personal data and/or the personal data of individual contacts at your organisation as well as keeping records of our conversations, meetings, appointments. From time to time, we may also ask you to undertake a customer satisfaction survey. We think this is reasonable – we deem these uses of your data to be necessary for our legitimate interests as an organisation providing various services to you.
PARTNER/SUPPLIER DATA:
We use and store the personal data of individuals within your organisation in order to facilitate the receipt of services from you as one of our Partners or Suppliers. We also hold your financial details, so that we can pay you for your services. We deem all such activities to be necessary within the range of our legitimate interests as a recipient of your services.

PEOPLE WHOSE DATA WE RECEIVE FROM CLIENTS SUCH AS EMERGENCY CONTACTS:
If a client has given us your details as an emergency contact, we will use these details to contact you in the case of an accident or emergency. We are sure you will agree that this is a vital element of our people-orientated organisation, and so is necessary for our legitimate interest.

CONSENT

In certain circumstances, we are required to obtain your consent to the processing of your personal data in relation to certain activities. Depending on exactly what we are doing with your information, this consent will be opt-in consent or soft opt-in consent.
Article 4(11) of the General Data Protection Regulation states that (opt-in) consent is “any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.” In plain language, this means that:
– you must give us your consent freely, without us putting you under any type of pressure;
– you must know what you are consenting to – so we’ll make sure we give you enough information;
– you should have control over which processing activities you consent to and which you don’t. We provide these finer controls within our privacy preference centre; and
– you need to take positive and affirmative action in giving us your consent – we’re likely to provide a tick box for you to check so that this requirement is met in a clear and unambiguous fashion.
We will keep records of the consents that you have given in this way.
We have already mentioned that, in some cases, we will be able to rely on soft opt-in consent. We are allowed to market products or services to you which are related to the recruitment services we provide as long as you do not actively opt-out from these communications.
Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements regarding consenting to receive marketing materials. For more information in relation to your jurisdiction, please contact  https://copthallhealth.co.uk/contact/

 

As we have mentioned, you have the right to withdraw your consent to these activities. You can do so at any time, by( clicking https://copthallhealth.co.uk/contact/

 

ESTABLISHING, EXERCISING OR DEFENDING LEGAL CLAIMS

 

Sometimes it may be necessary for us to process personal data and, where appropriate and in accordance with local laws and requirements, sensitive personal data relating to exercising or defending legal claims. Article 9(2)(f) of the GDPR allows this where the processing “is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity”.
This may arise for example where we need to take legal advice in relation to legal proceedings or are required by law to preserve or disclose certain information as part of the legal process.

 

 

 

 

 

 

 

 

 

 

 

 

APPENDIX 1 – HOW TO CONTACT US

 

Country in which you use our services or supply us with services: UK

PLEASE NOTE COPTHALL HEALTH DO NOT PROCESS ANY PERSONAL DATA OUTSIDE OF THE UK

COPTHALL HEALTH entity responsible for processing the personal data of Website Users: COPTHALL HEALTH

How you can get in touch with us:

to access, amend or take back the personal data that you have given to us;

if you suspect any misuse or loss of or unauthorised access to your personal information;

to withdraw your consent to the processing of your personal data (where consent is the legal basis on which we process your personal data);

with any comments or suggestions concerning this Privacy Policy

You can write to us at the following address:

COPTHALL HEALTH

Copthall Pools

Champions Way

Hendon

N London

NW4 1PX

 

Alternatively, you can send an email to: info@copthallhealth.co.uk
How you can get in touch with us to update your marketing preferences

You can email us at: info@copthallhealth.co.uk or https://copthallhealth.co.uk/contact/://copthallhealth.co.uk/contact

 

 

 

 

 

 

 

 

 

 

 

APPENDIX 2 – HOW TO CONTACT YOUR LOCAL SUPERVISORY AUTHORITY

Country in which you use our services or supply us with services: UK

Details of your local supervisory authority: The Information Commissioner’s Office. You can contact them in the following ways:

Phone: 0303 123 1113

Email: casework@ico.org.uk

 

Post: Information Commissioner’s Office

Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

APPENDIX 3 – COUNTRY-SPECIFIC VARIATIONS TO OUR PRIVACY POLICY

PRIVACY POLICY TOPIC: COPTHALL HEALTH’ PROCESSING OF YOUR SENSITIVE PERSONAL DATA

IMPORTANT – COPTHALL HEALTH DOES NOT PROCESS ANY PERSONAL INFORMATION OUTSIDE OF THE UK

JURISDICTION: UK

COUNTRY-SPECIFIC LEGAL REQUIREMENT: Where your personal data are processed in accordance with the fair processing condition relating to our rights and obligations under employment and social security law, this relates to our processing of your personal data which is necessary for compliance with legal obligations.

NOTE: THIS APPENDIX WILL BE UPDATED WHEN LOCAL IMPLEMENTING LAW HAS BEEN FINALISED

 

Google AdWords User Lists

Google AdWords Conversion

Facebook Connect

Facebook Custom Audience

 

 

 

 

 

 

 

 

 

 

 

 

 

 

GLOSSARY

Clients – while it speaks for itself, this category covers our customers, clients, and others to whom COPTHALL HEALTH provides services in the course of its business.
Delete – while we will endeavour to permanently erase your personal data once it reaches the end of its retention period or where we receive a valid request from you to do so, some of your data may still exist within our systems, for example if it is waiting to be overwritten. For our purposes, this data has been put beyond use, meaning that, while it still exists on an archive system, this cannot be readily accessed by any of our operational systems, processes or team members.

 

General Data Protection Regulation (GDPR) – a European Union statutory instrument which aims to harmonise European data protection laws. It has an effective date of 25 May 2018, and any references to it should be construed accordingly to include any national legislation implementing it.

Other people whom COPTHALL HEALTH may contact – these may include COPTHALL HEALTH team members emergency contacts and referees. We will only contact them in appropriate circumstances.

Staff – includes employees and interns engaged directly in the business of COPTHALL HEALTH (or who have accepted an offer to be engaged) as well as certain other workers engaged in the business of providing services to COPTHALL HEALTH (even though they are not classed as employees). For these purposes we also include employees of COPTHALL HEALTH who are engaged to work on Clients premises premises under the terms of RPO or MSP agreements. Independent contractors and consultants performing services for COPTHALL HEALTH fall within the definition of a ‘Supplier’ for the purposes of this Privacy Policy.
Partners/Suppliers – refers to partnerships and companies (including sole traders), and atypical workers such as independent contractors and freelance workers, who provide services to COPTHALL HEALTH.
Website Users – any individual who accesses any of our websites.