The Privacy Policy aims to give you information on how we collect and process your personal data, including any data you may provide when you set up an account via the DECAMA mobile app or platform, contact us through this website (or other websites connected with CD Psychology Limited) to receive marketing and publicity information, receive reports and articles from us or register attendance at events we organise. We will also tell you about your privacy rights and how the data protection laws protect you.

You must read this policy together with any other specific privacy notice we provide when collecting or processing data about you.

The CD Psychology website and DECAMA app and dashboard (platform) are not intended for use by children and young people aged under 18 years; we do not knowingly collect data relating to children.

The Privacy Policy covers

• Who we are, how we manage your Personal Information and your Rights
• Retaining, deleting and pseudonymising data you have supplied
• Cookies, website analytics, third-party organisations, marketing and advertisements
• Amendments to the Privacy Policy

CD Psychology Limited is a company registered in the UK providing assessment, treatment, training and research concerning psychological health and wellbeing of adults. CD Psychology Ltd is the data controller and is responsible for ensuring the lawful and appropriate handling of all your personal data (collectively referred to as “we”, “us”, “our” in this privacy notice) associated with your engagement with our services.

CD Psychology Limited’s registered address is: 31 Barn Field Close, Colne, Lancashire BB8 OBQ. For all data matters, contact Catherine Dobson catherine@cdpsychology.co.uk.

DECAMA is a registered trademark of CD Psychology Limited.

CD Psychology Limited is registered with the UK Information Commissioner’s Office.

Our website is www.decama-uk.com

When you engage with CD Psychology Limited in person, via the website or set up an account through the DECAMA app or dashboard you enter into a contract with CD Psychology Limited for the provision of goods and services. Therefore, collecting your data is necessary for us to perform the contract with you.

We will treat your data in an appropriate and lawful manner, in accordance with data protection laws.

Personal data (or Personal Information) means any information about an individual from which that person can be identified. You can find out more about personal data from the UK Information Commissioner’s Office – What is personal data? | ICO

We may collect, use, store and transfer different kinds of personal data, grouped as follows:

a) DECAMA Wellbeing app and platform

• Individual identity data (such as name, age, date of birth, title, gender)
• Contact data (address, postcode, telephone, email)
• Employment data (such as an individual’s employer, their role or profession
• Company data (such as company name, address, telephone, industry sector)

b) Psychological Services provided by CD Psychology

• All of the above, plus
  
• Data associated with the services we provide (such as the provision of expert reports for employers or legal proceedings, psychological assessments and interventions, assessment findings, reports and correspondence written by us). This may include Special Categories of Personal Data (such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health). We may also collect information about criminal convictions and offences.

Directly: you may give us your name, email address, telephone

• when creating an account on the DECAMA app or platform
• when corresponding by phone, email or otherwise
• when you subscribe to our services or publications
• when you request marketing information
• when you apply for or attend an event we organise
• when you leave comments or queries on contact forms on our website

Indirectly: we also receive personal data from other parties

• when we receive information about you from another party, for example on referral from a trusted health, social care or legal agency

We will only use your personal data when the law allows us to. We do not rent, sell or share users’ information with third parties, except as described in this Privacy Policy.

Most commonly, we will use your personal data in the following circumstances:

• to communicate with you – providing you with technical information, responding to any customer service query you may have, arranging in-person appointments and consultations at your request and reminders, keeping you informed of our latest updates and services
• to communicate with you if you request a password reset, your IP address will be included in the re-set email
• to build a ‘user profile’ if you register through the DECAMA website or app. All users can see, edit or delete their personal information at any time (except they cannot change their user-name). Website administrators can also see and edit that information.
• to conduct statistical and service quality analyses
• to be able to undertake our services, including the collation and analysis of data provided by users of digital app and platform (dashboard) and to prepare reports derived from our analyses of data provided by you
• to collate user and visitor comments about our services

In addition to the above

• we may transfer or disclose personal information to our subsidiaries, affiliated companies and sub-contractors, in order for them to undertake services on our behalf
• we may share personal information with trusted third-party providers, who may be located in different jurisdictions across the world, for the following purposes:
  • hosting and operating our site
  • providing you with our services, including a personalised display of our site (dashboard)
  • storing and processing information on your behalf
  • assisting us in evaluating the success of our advertising campaigns and helping us to re-connect with users or target new users
  • providing you with marketing offers and promotional materials related to our site and services
  • performing research, technical diagnostics or analytics

We may also disclose information in good faith if we believe that disclosure of such information is necessary

• to comply with applicable law, regulation, legal process or governmental request
• to prevent harm to the rights, property or safety of us, our users, yourself or any third party
• to enforce our policies, including any investigations of potential violations of our policies
• to investigate, detect, prevent or take action regarding illegal activities or wrong-doing, suspected fraud, or security issues
• to establish or exercise our rights to defend legal claims
• to collaborate with law-enforcing agencies
• to enforce our intellectual property or other legal rights

You will be invited to agree your understanding of the Privacy Policy prepared by CD Psychology and to the retention of your personal information.

You may request

• to receive confirmation as to whether or not any personal information concerning you is being processed
• to have access to and receive a copy of your stored personal information, together with supplementary information
• to erase any personal data about you, this does not include any data we are obliged to keep for administrative, legal or security purposes
• to rectify personal information that we hold
• to object to the processing of personal information by us
• to restrict processing of personal information by us
• to lodge a complaint about the use of your personal data with a supervisory authority

If you wish to exercise your rights or receive information, please contact our Data Protection Officer Catherine Dobson catherine@cdpsychology.co.uk.

We will retain your personal information for as long as is necessary to provide our services and to comply with legal and regulatory obligations, to resolve disputes and enforce our policies. Retention periods will be determined by taking into account the type of information that is collected and the purpose of collection, bearing in mind requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time.

We may rectify, replenish or remove incomplete or inaccurate information, at any time at our own discretion.

‘Pseudonymisation’ of data enables us to retain data provided by you which we can continue to use for the purposes of analysis, research and evaluation of the quality of our Services.

In the course of providing our Services, we may pseudonymise data that you have supplied through our app, platform or Site, meaning that your data cannot be identified as being associated with you as an individual person. The UK Information Commissioner’s Office has guidance on the protection of Personal Information through the process of ‘pseudonymising’ data provided by an individual: see chapter-3-anonymisation-guidance.pdf (ico.org.uk)

Should you inform us that you wish to cease participation in services provided by CD Psychology you will be invited to

• request the deletion of all current and historic Personal Information relating to you, taking into account legal and regulatory requirements
• agree to the pseudonymisation of current and previous data that you have supplied so that it can no longer be associated with you as an identifiable user

Data which has already been psuedonymised will not be able to be deleted.

Our policy only addresses the use and disclosure of information we collect from you. To the extent you disclose your information to other parties or sites throughout the Internet, different rules may apply to their use or disclosure of the information you disclose to them. Accordingly, we encourage you to read the terms and conditions and privacy policy of each third-party that you choose to disclose information to.

This Privacy Policy does not apply to the practises of companies that we do not own or control, or to individuals whom we do not employ or manage, including any third-party to whom we may disclose information as set forth in this Privacy Policy.

We take great care in implementing and maintaining the security of the Site and your information. We employ industry standard procedures and policies. To ensure the safety of the information we collect and retain and prevent unauthorised use of any such information, we require any third-party to comply with similar security requirements in accordance with this privacy policy. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorised access or abuse our Site and we make no warranty, expressed, implied or otherwise that will prevent such access.

Please note that some data requirements may be located outside the EEA. In such cases, we will transfer your data only to such countries as approved by the European Commission and the United Kingdom as providing adequate level of data protection or enter into legal agreements ensuring an adequate level of data protection.

We and our trusted partners use cookies and other technologies in our related services, including when you visit our Site or access our services.

A ‘cookie’ is a small piece of information that a website assigns to your device (PC or mobile device) while you are viewing a website. Cookies are helpful and can be used for different purposes. These purposes include allowing you to navigate between pages, enable automation of certain features, remember your preferences and make the interaction between you and our services quicker and easier.  Cookies are also used to help ensure that advertisements you see are relevant to you and your interests and to compile statistical data on your use of our services.

a) ‘Session cookies’ When you visit our log-in pages, we will set a temporary cookie to determine if your browser accepts cookies. Session cookies are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed.

b) ‘Persistent cookies’ are read only by the Site, saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, for example, to allow us to store your preferences for the next log-in. These ‘cookies’ will be discarded one year after the date of your last browsing of the website or log-in to the app.

c) ‘Third party cookies’ are set by other online services who run content on the page you are viewing, for example, by third party analytics companies who monitor and analyse our website access.

Cookies do not contain any information that personally identifies you, but personal information that we store about you may be linked by us, to the information stored in and obtained from cookies. You may remove the cookies by following the instructions on your device preferences; However, if you choose to disable cookies, some features of our Site may not operate properly. And your online experience may be limited.

Articles on this site may include embedded content (videos, images, articles etc) from other websites. The user experience is the same as if the embedded content had been accessed directly.

We also use a tool called Google Analytics to collect information about your use of the Site. Google Analytics collects information such as how often users access the site, what pages they visit, when they do, etc. We use the information we get from Google Analytics, only to improve our Site and services. Google Analytics collects the Internet Protocol (IP) address assigned to you on the date you visit sites rather than your name or other identifying information. We do not combine the information collected through the Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics terms of use and the Google Privacy Policy.

We may use a third-party advertising technology to serve advertisements when you access the Site. This technology uses your information with regards to your use of the services to serve advertisements to you, such as by placing third-party cookies on your web browser.

You may opt out from any third-party advertisements including those operated by members of the Network Advertising initiative (NAI) and the Digital Advertising Alliance (DAA). For more information about this practise by NAI and DAA and your choices regarding having this information used by these companies, including how to opt out of third-party advertising networks operated by NAI and DAA members, please visit their respective websites: Opt Out – NAI: Network Advertising Initiative (thenai.org)  and Opt out of seeing personalised ads – Ads Help (google.com)

We may use your personal information, such as your name, e-mail address, telephone number, etc. Ourselves or by using our third-party subcontractors for the purpose of providing you with promotional materials concerning our services, which we believe may be of interest to you.

Please note that even if you have unsubscribed from receiving marketing emails from us, we may send you other types of important e-mail communications without offering you the opportunity to opt out of receiving them. These may include customer service announcements or administrative notices.

In respect of your right to privacy we provide you with such marketing materials with means to decline receiving further marketing offers from us. If you unsubscribe, we will remove your e-mail address or telephone number from our marketing distribution lists.

We may share information in the event of a corporate transaction (eg the sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, the transferee or acquiring company will assume the rights and obligations as described in this Privacy Policy.

We understand the importance of protecting children’s privacy, especially in an online environment. The Site is not designed or directed at children Under no circumstances shall we allow the use of our services by minors, without prior consent or authorization by a parent or legal guardian. We do not knowingly collect Personal Information from minors. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at catherine@cdpsychology.co.uk

If you have any general questions about the website, platform or app or the information we collect about you and how we use it you can contact us at catherine@cdpsychology.co.uk

We reserve the right to periodically amend or advise the Privacy Policy. Material changes will be effective immediately upon display of the revised Privacy Policy on our Site. The last revision will be reflected in the ‘last modified’ section of the Policy. Your continued use, of the mobile app, platform or website following the notification of such amendments on our website, constitute your acknowledgement and consent of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments.

5 September 2022 – amendments to include updates to decama-uk.com website: Privacy Policy v2.1

25^th July 2022 – initial draft for app and website: Privacy Policy v2