Marpe Wellbeing

This privacy policy provides you with details about the personal information we collect and hold about you, how we use your personal information and your rights regarding your personal information.

Depending on our relationship, we will collect and use your information in different ways.


The type of personal information we collect

Marpe Wellbeing currently collects and processes the following information from:

(a) Clients: 

    • Personal identifiers, contacts and characteristics (for example, name and contact details, date of birth, gender, address and GP contact details.
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    • Sensitive personal typed data that the therapist makes during remote video sessions with the client.
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    • When a client wants to book a therapy session, they will be required to enter their payment card details. Marpe Wellbeing does not store this information.
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    • Marpe Wellbeing does not keep credit card details such as name, credit card number, card expiry date, CVV code and billing address. Marpe Wellbeing utilises a third party secured payment organisation called Stripe. Note that third-party payment processors may keep this information in accordance with their own privacy policies and terms.
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    • The Client is not obliged to provide details of their General Practitioner; however, Marpe Wellbeing will not be liable for any harm or loss that may arise in not having such details disclosed.
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    • With the client’s consent, therapy session notes from therapists may be shared with their General Practitioner.
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    • Marpe Wellbeing gets the information direct from the client and the sensitive information from through the therapists documentation from the clients sessions with therapist. This information is required for the purpose of booking the clients appointments, identifying the client and for the purpose of record keeping necessary for continuation of the clients therapy care.

 

(b) Therapists:

Initial Stage data collection

When the therapists first registers a profile on the web/app platform

    • Name
    • Postal address
    • Email address
    • Telephone number
    • Age
    • A copy of your passport details including passport photograph
    • National insurance number
    • Current and previous employment/work details, including job title and employer and relevant experience;
    • Professional certifications, education and qualifications, skills, career history,
    • Right to work status, citizenship, and any other information relevant or required by law to enable clients to be able to assess whether or not they would want to engage you;
    • Any other information which you include in your CV
    • Details of self-employment (where relevant);
    • Professional body registration number
    • Insurance details and/or indemnity cover;
    • Results of pre-employment screening or vetting checks (including the results of any Disclosure and Barring checks and any information you provide relating to current and/or spent criminal convictions uploaded to the platform during the registration of a profile process);
    • Relevant right to work information uploaded to the platform during the registration of a profile process;
    • Bank details to be able to create invoices and
    • Details you fill out on your profile (bio, IT systems, qualifications and languages spoken).
    • Personal information about yourself by using the online forms provided on our website [or on our app,] [or by contacting us by phone, email or other means]. This includes, for example, where you provide your personal information to us in order to receive information or services from us.


Other data collection

In addition to the initial stage data we collect, we will collect and hold the following personal information:

    1. References from third parties such as previous employers and nominated referees;
    2. Any email communications, including attachments, which you send to us;
    3. Information provided when you correspond with us;
    4. Information related to your availability which we will obtain through your use of Marpe Wellbeing app/web platform
    5. Any updates to information provided to us;
    6. Details of your character;
    7. Information about your preferences.

 

  • When a therapist registers, they will be required to put in their bank account details which will be stored for the purposes of payments to the therapist and utilised by third party secured payment organisation called Stripe. Note that third-party payment processors may keep this information in accordance with their own privacy policies and terms.


  • Marpe Wellbeing gets the information direct from the therapist and it is our use in Marpe Wellbeing web and app platforms, for the purposes of displaying your biography, qualifications and specialties to the clients on the Marpe Wellbeing platform.


  • Marpe Wellbeing will also receive information in form of client review and rating from the clients perspective. This information may be collated and displayed to users on the Marpe Wellbeing platform.

 

How we use your personal information  (Clients & Therapists- also known as “users”)

We will collect, use and store the personal information listed above for the following reasons:

  1. Enabling therapists to advertise their availability as a self-employed therapist and to communicate with clients to arrange the delivery of your services via Marpe Wellbeing platform.
  2. Allowing clients (being potential engagers of your services) to view therapists profile
  3. maintaining a record of  Therapists profile information and website use history so that clients who are seeking someone with a specific skill set can easily book an appointment with a chosen therapist.
  4. Conducting profiling and business development activities, as well as market research and statistical analysis regarding activity via our platform. Such details will be anonymised as far as is reasonably possible and you will note identifiable from the information collected;
  5. Maintaining profile information of therapists and clients ;
  6. Complying with any legal or regulatory requirements and to make the necessary disclosure under the requirements of any applicable law, regulation, direction, court order, guideline, circular or code which are applicable to us for the prevention of crime;
  7. To allow therapists and clients to access and use our website or the app;
  8. To provide technical support;
  9. To provide users  with the information you request from us;
  10. To store information about users preferences, and so allow us to customise our website and the app according to your individual interests;
  11. To recognise users when they return to our Site;
  12.  For equal opportunities monitoring;
  13. Making our Site and users use of it available
  14. Improving our Site to ensure that content is presented in the most effective manner for users and their devices; and assisting in our efforts to keep our Site safe.
  15. To allow users to access and use our Site;
  16. To provide technical support;
  17. To provide you with the information you request from us;
  18. To store information about your preferences, and so allow us to customise our website according to users individual interests;
  19. To recognise you when users return to our website;
  20. For improvement and maintenance of our website and preparing reports or compiling statistics in order to improve our goods and services. Such details will be anonymised as far as is reasonably possible and you will not be identifiable from the information collected.
  21. To send you certain communications (including by email or post) about our goods and services such as service announcements and administrative messages (for example, setting out changes to our terms and conditions and keeping you informed about our fees and charges);
  22. To allow you to attend our events and to send you photos that you have permitted us to take of you;

 

  • Special categories of data. Some of the personal information that we collect about users or which users provide to us may be special category of data. Special categories of data include information about physical and mental health, sexual orientation, racial or ethnic origin, political opinions, philosophical belief, trade union membership and biometric data.


  • Disclosure and Barring Services ("DBS") certificate. Personal information we collect about therapists in relation to criminal convictions and offences (usually in the form of a DBS certificate) will be collected as required by law for a healthcare professional to be able to provide healthcare professional services in the UK.


  • Source of personal information. We may receive some of your personal information from third party sources, such as your employer or your employer's company website. We may also collect this personal information from publicly-available sources, such as LinkedIn or Federation websites.


All visitors to our website

What personal information we collect about you

We, or third parties on our behalf, may collect and use any of the following information about you:

(i)  information provided when you correspond with us;


(ii)  any updates to information provided to us;


(iii)  the following information created and recorded automatically when you visit our website:


  • Technical information. This includes: the Internet protocol (IP) address used to connect your computer to the internet address; the website address and country from which you access information; the files requested; browser type and version; browser plug-in types and versions; operating system; and platform. We use this personal information to administer our website, to measure the efficiency of our systems and to undertake an analysis on the locations from which people access our webpages;
  • Information about your visit and your behaviour on our website (for example, the pages that you click on). This may include the website you visit before and after visiting our website (including date and time), time and length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, traffic data, location data, weblogs and other communication data and information provided when requesting further service or downloads.


How we use your personal information

We will collect, use and store the personal information listed above for the following reasons:

(i)  to allow you to access and use our Site;


(ii)  to receive enquiries from you through the Site about any of Marpe Wellbeing  services;


(iii)  for improvement and maintenance of our Site and to provide technical support for our Site;


(iv)  to ensure the security of our Site;


(v)  to recognise you when you return to our Site, to store information about your preferences, and to allow us to customise the Site according to your individual interests; and


(vi)  to evaluate your visit to the Site and prepare reports or compile statistics to understand the type of people who use our website, how they use our website and to make our Site more intuitive. Such details will be anonymised as far as reasonably possible and you will not be identifiable from the information collected.


A word about cookies

(i)  Some pages on our website use cookies, which are small files placed on your internet browser when you visit our website. We use cookies in order to offer you a more tailored experience in the future, by understanding and remembering your particular browsing preferences.


(ii)  Where we use cookies on our website, you may block these at any time. To do so, you can activate the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of our website or to use all the functionality provided through our website.


(iii)  For detailed information on the cookies we use and the purposes for which we use them, please refer to our cookies policy.


Whatever our relationship with you is, we may also collect, use and store your personal information for the following additional reasons:

(a)  to deal with any enquiries or issues you have about how we collect, store and use your personal information, or any requests made by you for a copy of the information we hold about you. If we do not have a contract with you, we may process your personal information for these purposes where it is in our legitimate interests for customer services purposes;


(b)  for internal corporate reporting, business administration, ensuring adequate insurance coverage for our business, ensuring the security of company facilities, research and development, and to identify and implement business efficiencies. We may process your personal information for these purposes where it is in our legitimate interests to do so;


(c) to comply with any procedures, laws and regulations which apply to us – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others to comply, as well as where we are legally required to do so;


(d) to establish, exercise or defend our legal rights – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others, as well as where we are legally required to do so.


Further processing

We will not use your personal information in any way that is incompatible with the purposes set out in this policy.

 

Legal basis for use of your personal information
We consider that the legal bases for using your personal information as set out in this privacy policy are

as follows:

Clients:








 

When and Who we may share your personal information:
We hold information about each of our clients and the therapy they receive in confidence. This means that we will not normally share your personal information with anyone else. However, in exceptional circumstances, we might need to share personal information with relevant authorities:

 

When there is need-to-know information for another health provider, such as your GP.

• When disclosure is in the public interest, to prevent a miscarriage of justice or where there is a legal duty, for example a Court Order.
• When the information concerns risk of harm to the client, or risk of harm to another adult or a child. We will discuss such a proposed disclosure with you unless we believe that to do so could increase the level of risk to you or to someone else.
• We may also need to share your information if you make a complaint against a mental health professional or raise a concern.  In such an event we may have to share your information with third parties such as insurers, professional advisors or regulators.


Marpe Wellbeing does not record therapy sessions.



Therapists
(a) Our use of your personal information is necessary for complying with our legal obligations (for

example, to enable us to make payments to you);













Where (a) does not apply, use of your personal information is necessary for our legitimate interests or the legitimate interests of others (for example, to ensure the security of our website). Our legitimate interests are:

  • to develop and maintain an industry-relevant database of therapists
  • to carry out market research for our internal use;
  • for internal record keeping purposes;
  • run, grow and develop our business;
  • operate our Site and app

 

The storage and use of your personal information allows you to be connected to clients who may be of interest to you, now or in the future, and we do not believe that this storage and use will unduly prejudice your rights or freedoms.

 

If we rely on your consent for us to use your personal information in a particular way, but you later change your mind, you may withdraw your consent by contacting us at hello@marpewellbeing.uk and we will stop doing so. However, if you withdraw your consent, this may affect your use of the Site.

 

We will share your personal information with the following third parties or categories of third parties:

  • our other service providers and sub-contractors, including but not limited to payment processors, utility providers, suppliers of technical and support services, insurers, logistic providers, and cloud service providers;
  • public agencies and the emergency services;
  • companies that assist us in our marketing, advertising and promotional activities;
  • analytics and search engine providers that assist us in the improvement and optimisation of our website.

 

  • Any third parties with whom we share your personal information are limited (by law and by contract) in their ability to use your personal information for any purpose other than to provide services for us. We will always ensure that any third parties with whom we share your personal information are subject to privacy and security obligations consistent with this privacy policy and applicable laws.

 

We will also disclose your personal information to third parties:

    • Where it is in our legitimate interests to do so to run, grow and develop our business:
    • if we sell or buy any business or assets, we may disclose your personal information to the prospective seller or buyer of such business or assets;
    • If substantially all of Marpe Wellbeing or any of its affiliates' assets are acquired by a third party, in which case personal information held by Marpe Wellbeing will be one of the transferred assets;
    • If we are under a duty to disclose or share your personal information in order to comply with any legal obligation, any lawful request from government or law enforcement officials and as may be required to meet national security or law enforcement requirements or prevent illegal activity;
    • In order to enforce or apply our terms and conditions or any other agreement or to respond to any claims, to protect our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity; or
    • To protect the rights, property, or safety of Marpe Wellbeing, our staff, our customers (including residents) or other persons. This may include exchanging personal information with other organisations for the purposes of fraud protection and credit risk reduction.

 

We may also disclose and use anonymised, aggregated reporting and statistics about users of our website or our goods and services for the purpose of internal reporting or reporting to our group or other third parties, and for our marketing and promotion purposes. None of these anonymised, aggregated reports or statistics will enable our users to be personally identified.


Save as expressly detailed above, we will never share, sell or rent any of your personal information to any third party without notifying you and, where necessary, obtaining your consent. If you have given your consent for us to use your personal information in a particular way, but later change your mind, you should contact us and we will stop doing so.


How long we store your personal information

We keep your personal information for no longer than necessary for the purposes for which the personal information is processed. The length of time we retain personal information for depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.


Your rights

You have certain rights in relation to your personal information. If you would like further information in relation to these or would like to exercise any of them, please contact us via email at hello@marpewellbeing.uk at any time. You have the following rights:

    • Right of access. You have a right of access to any personal information we hold about you. You can ask us for a copy of your personal information; confirmation whether your personal information is being used by us; details about how and why it is being used; and details of what safeguards are in place if we transfer your information outside of the European Economic Area ("EEA").
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    • Right to update your information. You have a right to request an update to any of your personal information which is out of date or incorrect.
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    • Right delete your information. You have a right to ask us to delete any personal information which we are holding about you in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting us on hello@marpewellbeing.uk
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    • We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort. You can ask us who the recipients are by contacting us on hello@marpewellbeing.uk

 

  • Right to restrict use of your information: You have a right to ask us to restrict the way that we process your personal information in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting us on hello@marpewellbeing.uk

 

  • We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort. You can ask us who the recipients are by contacting us on hello@marpewellbeing.uk

 

  • Right to stop marketing: You have a right to ask us to stop using your personal information for direct-marketing purposes. If you exercise this right, we will stop using your personal information for this purpose.

 

  • Right to data portability: You have a right to ask us to provide your personal information to a third party provider of services. This right only applies where we use your personal information on the basis of your consent or performance of a contract; and where our use of your information is carried out by automated means.


  • Right to object. You have a right to ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our or another person's legitimate interest.


  • We will consider all such requests and provide our response within a reasonable period (and in any event within one month of your request unless we tell you we are entitled to a longer period allowed by applicable law). Please note, however, that certain personal information may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims.


If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any request you make.


Marketing

We may collect and use your personal information for undertaking marketing by email telephone and post.


We may send you certain marketing communications (including electronic marketing communications to existing customers) if it is in our legitimate interests to do so for marketing and business development purposes.


However, we will obtain your consent to direct marketing communications where we are required to do so by law and if we intend to disclose your personal information to any third party for such marketing.


If you wish to stop receiving marketing communications, you can unsubscribe, change your marketing preferences or contact us by email at hello@marpewellbeing.uk

 

Risks and how we keep your personal information secure

  • The main risk of our processing of your personal information is if it is lost, stolen or misused. This could lead to your personal information being in the hands of someone else who may use it fraudulently or make public information that you would prefer to keep private.


  • For this reason, Marpe Wellbeing is committed to protecting your personal information from loss, theft and misuse. We take all reasonable precautions to safeguard the confidentiality of your personal information, including through use of appropriate organisational and technical measures. We have undertaken an internal audit of our hardwares, ensuring everyone has secure password protections, encryption and malware systems on laptops, authentication on emails and our system. If we store any hard copies of personal data this is in a secure lockable cupboard. No data is stored on laptops for longer than necessary, screens are locked when staff members are away from their desk. Any printed materials with personally identifiable data is shredded within 1 week of use, for example CVs. Staff have had information governance training.


  • In the course of provision of your personal information to us, your personal information may be transferred over the internet. Although we make every effort to protect the personal information which you provide to us, the transmission of information over the internet is not completely secure. As such, you acknowledge and accept that we cannot guarantee the security of your personal information transmitted to our website and that any such transmission is at your own risk. Once we have received your personal information, we will use strict procedures and security features to prevent unauthorised access to it.


  • Where we have given you (or where you have chosen) a password which enables you to access your online account, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.


Links to other websites

Our website may contain hyperlinks to websites that are not operated by us. These hyperlinks are provided for your reference and convenience only and do not imply any endorsement of the activities of such third-party websites or any association with their operators.


This privacy policy only applies to the personal information that we collect or which we receive from third party sources, and we cannot be responsible for personal information about you that is collected and stored by third parties. Third- party websites have their own terms and conditions and privacy policies, and you should read these carefully before you submit any personal information to these websites.


We do not endorse or otherwise accept any responsibility or liability for the content of such third-party websites or third-party terms and conditions or policies.


Changes to our privacy policy

We may update our privacy policy from time to time. Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by post or email. Please check back frequently to see any updates or changes to our privacy policy.


Further questions and how to make a complaint

If you have any queries or complaints about our collection, use or storage of your personal information, please comtact us on hello@marpewellbeing.uk. We will investigate and attempt to resolve any such complaint or dispute regarding the use or disclosure of your personal information.


In accordance with Article 77 of the General Data Protection Regulation, you may also make a complaint to the Information Commissioner's Office, or the data protection regulator in the country where you usually live or work, or where an alleged infringement of the General Data Protection Regulation has taken place. Alternatively, you may seek a remedy through the courts if you believe your rights have been breached.


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 practices described in this privacy policy statement are current as of 30th June 2020.


Privacy Policy