A New Beginning Therapies is committed to protecting and respecting the privacy and personal data that the company processes in connection with the services it provides to clients and individuals’ use of the A New Beginning Therapies websites.

To arrange therapy, provide customer service and handle complaints, A New Beginning Therapies Limited and other participants in the industry are required to use and share Personal Data.

During the therapy lifecycle A New Beginning Therapies Limited will receive Personal Data relating to potential or actual Clients, family members and other parties involved in therapy.

Therefore references to “individuals” in this notice include any living person from the preceding list, whose Personal Data A New Beginning Therapies Limited receives in connection with the services it provides under its engagements with its clients.

This Privacy Policy sets out how A New Beginning Therapies Limited will use your personal information and the disclosures it makes to subcontractors, other participants and other third parties and how you can exercise your rights under the General Data Protection Regulation (GDPR).

Data controller and contact information
The data controller is A New Beginning Therapies. If you have any questions, comments or requests regarding this Privacy Policy, please feel free to contact us at:

The Data Protection Officer
A New Beginning Therapies Limited
c/o Westlands Accountants
McMillan House, 6 Wolfreton Dr, Anlaby, Hull, East Yorkshire, HU10 7BY
Phone: 0800 030 9227
Email: [email protected]

Personal information that we process
We collect and process the following Personal Data:

Individual details including name, address, other contact details (e.g. email and telephone details), gender, marital status, family details, date and place of birth, employer, job title and employment history;

Identification details including identification numbers issued by government bodies or agencies (e.g. depending on the country you are in, social security or national insurance number, passport number, ID number, tax identification number, driver’s licence number);

Financial information including payment card number, bank account number and account details, other financial information;

Suitability information including information about the personal suitability criteria, which contains Personal Data and may include, only to the extent relevant to the therapy being provided:
─ Health data including current or former physical or mental medical conditions, health status, injury or disability information, medical procedures performed, relevant personal habits (e.g. smoking or consumption of drugs/alcohol), prescription information, medical history;
─ Criminal records data & criminal convictions; and
─ Other special categories of Personal Data including data concerning an individual’s sex life or sexual orientation;

Therapy information including information about current and/or previous therapy;

Credit and anti-fraud data including credit history and credit score, information about fraud convictions, allegations of crimes and sanctions details received from various anti-fraud and sanctions databases, or regulators or law enforcement agencies;

Marketing data including whether or not the individual has consented to receive marketing from us and/or from third parties and / or their marketing preferences; and

Website and communication usage including details of your visits to our websites and information collected through cookies and other tracking technologies, including, but not limited to, your IP address and domain name, your browser version and operating system, traffic data, location data, web logs and other communication data, and the resources that you access.

Sources of Personal Data
We collect and receive Personal Data from various sources, including (depending on the service we are seeking to or are providing and the country you are in):

- Individuals and their family members, online, face to face, or by telephone, or in written correspondence;
- Individuals’ employers or trade or professional associations of which they are a member;
- Credit reference agencies (to the extent Marsh Commercial is taking any credit risk);
- Anti-fraud databases and other third party databases, including sanctions lists;
- Government agencies, such as vehicle registration authorities and tax authorities;
- Business information and research tools;
- Selected third parties who provide us with details of potential customers
- Third parties who introduce business to us; and
- Forms on our website and your interactions with our website (please also see our Cookie Notice).

How we use and disclose your Personal Data
The “legal grounds” set out in the General Data Protection Regulation (the GDPR) and the UK Data Protection Act 2018, allows companies to process Personal Data only when the processing is permitted by the specific “legal grounds” set out in the GDPR (the full description of each of the grounds can be found here).

Please note that in addition to the disclosures we have identified in the table, we will disclose Personal Data for the purposes we explain in this notice to service providers, contractors, advisers, agents and A New Beginning Therapies group companies that perform activities on our behalf.

Special Categories of Personal Data and Criminal Data
When we collect, use or disclose to third parties (such as therapists) Special Categories of Personal Data and Criminal Records Data for the reasons set out in the table above, we typically do so for reasons of substantial public interests, such as because it is necessary for the range of therapy services we provide or because it is necessary for fraud prevention purposes.

Before you provide us with Special Categories of Personal Data and Criminal Records Data about a person other than yourself, you agree to notify such person of our use of their Personal Data and, if requested by us, to obtain their consent to our use of their Special Categories of Personal Data and Criminal Records Data (for example, by requiring the individual to sign a consent form).

Marketing
We may use your Personal Data to provide you with information about products or services which we think would be of interest to you. These may be sent by email or post or, in some circumstances, we may telephone you to explain this information to you. We take care to ensure that our marketing activities comply with all applicable legal requirements. In some cases, this may mean that we ask for your consent in advance us or our group companies of sending you marketing materials.

In all cases, you can opt out of receiving marketing communications, at any time. You can do this by clicking on the "unsubscribe" link in any marketing email or by contacting us using the details set out at the end of this Privacy Notice. Please note that, even if you opt out of receiving marketing messages, we may still send you communications in connection with the services we provide to you.

Safeguards
We have in place physical, electronic, and procedural safeguards appropriate to the sensitivity of the information we maintain. These safeguards will vary depending on the sensitivity, format, location, amount, distribution and storage of the Personal Data, and include measures designed to keep Personal Data protected from unauthorised access.

We restrict access of Personal Data to personnel and third parties that require access to such information for legitimate, relevant business purposes.

Purposes and lawful basis for processing personal data
We may collect, process and use your personal data in the course of providing therapy services, goods and other related services to you and to manage our relationship with you, in the following ways:

Processed under the lawful basis of Contract:
When you enquire about or purchase therapy services, goods and other related services from us, we will collect personal information to enable us to respond to your enquiry and to process and complete your purchase.
We collect personal information from you when you apply for a job with us to enable us to contact you and process your application.

Processed under the lawful basis of Legal Obligation:
We collect and process your personal information for producing invoices and accounting purposes which is required to meet HMRC legislation.
We collect personal information from employees to enable us to meet employment law obligations.

Processed under the lawful basis of Consent:
If you have given consent to receive marketing communications from us, we will collect information concerning your marketing preferences and send you communications based on those preferences.

Who we share your personal data with
We do not share your data with any other third parties except:

─ if you have given your consent.
─ if it is necessary to enable the provision of third party services you have requested (for example to facilitate quotes or agreements for other services or products).
─ if we are under a duty to comply with any legal obligation.

Third party recipients of your data
Data processors are third parties who provide elements of our business management services for us, who process or store personal data on our behalf. The categories of these recipients are administration, accounting, marketing, software, and website based activites & providers.

Retention periods
We collect, use, disclose and otherwise process Personal Data that is necessary for the purposes identified in this Privacy Notice or as permitted by law. If we require Personal Data for a purpose inconsistent with the purposes we identified in this Privacy Notice, we will notify clients of the new purpose and, where required, seek individuals’ consent (or ask other parties to do so on A New Beginning Therapies behalf) to process Personal Data for the new purposes.

Our retention periods for Personal Data are based on business needs and legal requirements. We retain Personal Data for as long as is necessary for the processing purpose(s) for which the information was collected, and any other permissible, related purpose.

Your rights in regard to your personal data
You have a number of rights in regard to your personal data. These include the right to request access to, rectification or erasure of personal data we hold, or restriction of processing concerning your data, or to object to the processing as well as the right of data portability. If you wish to make any such requests please contact us in writing using the contact details on the contact page.

Right to withdraw consent
Where we have processed your personal data on the lawful basis of consent, you have the right to withdraw this consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

Right to complain
If you have any concerns about how we have handled your personal data, please contact us so we may address them.

You also have the right to lodge a complaint with the supervisory authority, the Information Commissioner's Office, about how we manage your data. The ICO can be contacted by telephone at 0303 123 1113 or by email at [email protected]

Links to third party websites
Our websites may contain links to other third party websites. If you follow a link to any of those third party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your personal information. Please check these policies before you submit any personal information to such third party websites.

Changes to this policy
We will regularly review this privacy notice and update it where necessary. This policy was last updated on 1st February 2020.