Privacy Policy

Who We Are

DJGP Group Ltd, trading as Dr Jo Gee Psychological Therapies (‘we’ or ‘us’ or ‘our’) gather and process your personal information in accordance with this privacy notice and in compliance with the relevant data protection Regulation and laws. This notice provides you with the necessary information regarding your rights and our obligations, and explains how, why and when we process your personal data.

Dr Jo Gee Psychological Therapies registered office is at 3 Saxton, Parklands, Guildford, GU2 9JX and we are a company registered in England and Wales under company number 12396385. We are registered on the Information Commissioner’s Office Register; registration number ZA839678, and act as the data controller when processing your data. Our designated Data Protection Officer/Appointed Person is Juliet Mills who can be contacted at 3 Saxton, Parklands, Guildford, GU2 9JX at office@drjogeepsychotherapy.co.uk

Information That We Collect

Dr Jo Gee Psychological Therapies processes your personal information to meet our legal, statutory and contractual obligations and to provide you with our products and services. We will never collect any unnecessary personal data from you and do not process your information in any way, other than as specified in this notice.

The personal data that we collect from you: –

• Identity data – Name, date of birth, title and gender
• Contact data – billing address, email address, telephone number,
• Insurance data – insurance number, claim number, insurer details
• Location data – your IP address and telephone codes
• Transaction data – card and bank transfer payments
• Payment data – payments via our Jane platform and Stripe. All websites payments are via Stripe
• Technical data – IP data, log in data via Jane platform, browser plug in type
• Profile – your email and password on our Jane platform
• Usage – your website and Jane platform usage
• Recruitment data – for our employees and job applicants, including CV, application form, identity and contact data, accreditation, DBS and insurance details and interview details
• Marketing and communications data – marketing preferences or opt outs and communication preferences
• Video – we do not record sessions or collect any data from your video sessions, other than IP address and session length
• Therapy notes – notes are kept about your sessions and stored on our Jane platform by our therapists. The notes are your session records and visible to your therapist, their supervisor and other practitioners involved in your treatment team at Dr Jo Gee Psychological Therapies
• Group sessions – sessions are not recorded and chats between members are disabled. The only information collected is the length of sessions time, client log in and log out events, and attendance. Please note that group participants will be able to see you on screen and to see your first name only. Pseudonyms can be used where appropriate
• Special Category Data – We will collect information on health/medical, details about religion, sexuality etc. We with express consent, will also process information on our outcome measures we send out for assessing therapeutic progress. In extraordinary circumstances, we may process your Special Category Data to protect your vital interest or that of another person where you are physically or legally incapable of giving consent and it is necessary to protect an interest that is essential to your life or that of another person, for example if you were unconscious.

We collect information in the below ways: –

We collect data provided by yourself on the Jane platform, via Zoom or via email. This includes the following actions:

• Email us
• Complete the intake forms
• Complete the client survey
• Complete the client consent forms
• Complete the client outcome measure
• Complete the client satisfaction forms
• Upload information to your Jane platform e.g. homework sheets
• Upload information to be sent via email e.g. homework sheets
• Upload your profile picture on Jane platform
• Complete other questionnaires or forms via email or Jane platform as and when required.

Third party data will be collected in the following ways:

• Information from GP or Psychiatrists – Health data will be collected only if express consent is given and remains on your account.
• Payment processing – Stripe payment information should you make a chargeback against your card
• Advertising –

Google Ads free conversion tracking features on certain pages. If you contact us online, the destination page will have code on it that will help us understand the path you took to arrive on that page.

We use Google Ads remarketing codes to log when users view specific pages or take specific actions on a website. This allows us to provide targeted advertising in the future. If you do not wish to receive this type of advertising from us in the future you can opt out using the Google Ads centre opt-out page or the Network Advertising Initiative opt-out page.

We will not disclose personally identifiable information we collect from you to third parties without your permission except to the extent necessary including:

• To fulfil your requests for services
• To protect ourselves from liability.
• To use in marketing and advertising.
• To respond to legal process or comply with law, or in connection with a merger, acquisition, or liquidation of the company.

Click here to access Google’s privacy information

This website includes Google Maps features and content. The use of Google Maps features and content is subject to the current versions of the:

Google Maps/Google Earth Additional Terms of Service at https://maps.google.com/help/terms_maps.html; and

Google Privacy Policy at https://www.google.com/policies/privacy/.

This website includes Google ReCaptcha to prevent spam and fraud when completing a contact form. The use of this is subject to the Google privacy policy and terms of use.

How We Use Your Personal Data (Legal Basis for Processing)

Dr Jo Gee Psychological Therapies takes your privacy very seriously and we will never disclose, share, or sell your data without your consent, unless required to do so by law. We only retain your data for as long as is necessary and for the purpose(s) specified in this notice. Where you have consented to us providing you with promotional offers and/or marketing, you are free to withdraw this consent at any time.

The purposes and reasons for processing your personal data are detailed below: –

To conduct our business and provide you with our services. Most commonly we will use your Personal Data in the following circumstances:

• Where you have consented before the processing.
• Where we need to perform a contract, we are about to enter or have entered with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

The below describes the ways we plan to use your Personal Data, and which Lawful Basis we rely on to do so.

To provide you with our services:

When we register you as a client, deliver treatment, take payment, refund or deal with requests, processing card payments (please note we do not hold card details on our Jane platform), processing insurance payments or following up on debts owed, asking you to complete a form or survey/questionnaire, scheduling appointments and other communications.

To carry our business related activities for our legitimate business

Marketing and remarketing via Google Ads, website monitoring and for security reasons. We process your data to protect you against fraud when transacting on our Website, and to ensure our Websites and systems are secure, research involving anonymous data collection and anonymous therapy outcome analysis, use of anonymised reviews.

For our legal obligations

To carry out accounting and legal activities associated with courts of regulatory bodies, in accordance with law and regulations. This will include our legal obligation to keep you safe, should a life threatening situation arise.

To carry our marketing activities

To send marketing emails for our services including email marketing newsletters generally. Our Jane platform lets you set preferences and opt out of marketing communications.

Your Rights

• You have the right to access any personal information that Dr Jo Gee Psychological Therapies processes about you and to request information about: –
• What personal data we hold about you
• The purposes of the processing
• The categories of personal data concerned
• The recipients to whom the personal data has/will be disclosed
• How long we intend to store your personal data for
• If we did not collect the data directly from you, information about the source

If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.

You are able to exercise certain rights in relation to your personal data that we process. These are set out in more detail at https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/ In relation to a Subject Access Right request, you may request that we inform you of the data we hold about you and how we process it. We will not charge a fee for responding to this request unless your request is clearly unfounded, repetitive or excessive in which case we may charge a reasonable fee or decline to respond. We will, in most cases, reply within one month of the date of the request unless your request is complex or you have made a large number of requests in which case we will notify you of any delay and will in any event reply within 3 months. If you wish to make a Subject Access Request, please send the request to Dr Jo Gee by emailing office@drjogeepsychotherapy.co.uk

If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.

Sharing and Disclosing Your Personal Information

We do not share or disclose any of your personal information without your consent, other than for the purposes specified in this notice or where there is a legal requirement. Dr Jo Gee Psychological Therapies uses a third party to provide the below services and business functions; however, all processors acting on our behalf only process your data in accordance with instructions from us and comply fully with this privacy notice, the data protection laws and any other appropriate confidentiality and security measures.

• Insurance providers for payment processing
• Google Ads and analytics for marketing
• Stripe for payment processing
• Jane platform for CRM purposes to carry out of services
• Zoom for group therapy
• Dropbox for policy holding
• Staffology for recruitment and staffing
• Third parties carrying out services on our behalf, including billing, sale s, marketing agencies, analytics, research, university research, data storage, validation, security, fraud prevention and legal services;
• Other organisations for the purposes of fraud/crime protection and investigation;
• Courts of law and government, regulatory authorities or third parties to the extent required by law, court order or a decision rendered by a competent public authority and for the purpose of law enforcement; or
• Other third parties subject to your consent regarding your health and wellbeing e.g. GP and psychiatrist

Safeguarding Measures

Dr Jo Gee Psychological Therapies takes your privacy seriously and takes every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place, including measures such as SSL, TLS, encryptions, pseudonymisation, restricted access, IT authentication, firewalls, anti-virus/malware etc

We deal with data breaches seriously in line with ICO guidance.

Processing and Transfers Outside the UK

Some of our third party providers are businesses outside of the EEA in countries which do not always offer the same levels of protection for your personal data. At Dr Jo Gee Psychological Therapies do our best to ensure a similar degree of security by ensuring that contracts, code of conduct or certification are in place which give your personal data the same protection it has within Europe. If we are notable to do so, we will request your explicit consent to the transfer and you can withdraw this consent at any time.

Consequences of Not Providing Your Data

You are not obligated to provide your personal information to Dr Jo Gee Psychological Therapies, however, as this information is required for to deliver our services, we will not be able to offer some/all our services without it.

Legitimate Interests

As noted in the ‘How We Use Your Personal Data’ section of this notice, we occasionally process your personal information under the legitimate interests’ legal basis. Where this is the case, we have carried out a thorough Legitimate Interests’ Assessment (LIA) to ensure that we have weighed your interests and any risk posed to you against our own interests; ensuring that they are proportionate and appropriate.

How Long We Keep Your Data

Dr Jo Gee Psychological Therapies only ever retains personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations. We will only keep your personal data for as long as is necessary to fulfil the purposes for which we collected it. We may retain your data to satisfy any legal, accounting, or reporting requirements. We need to keep certain information about you for 7 years post treatment. You have the right to ask us to delete the personal data we hold about you in certain circumstances.

Where you have consented to us using your details for direct marketing, we will keep such data until you notify us otherwise and/or withdraw your consent.

Special Categories Data

Owing to the products, services or treatments that we offer, sometimes needs to process sensitive personal information (known as special category data) about you, to keep you safe, and with express consent, to speak to your healthcare team, when this serves your best interests. Where we collect such information, we will only request and process the minimum necessary for the specified purpose and identify a compliant legal basis for doing so.

Where we rely on your consent for processing special category data, we will obtain your explicit consent through our intake form. You can modify or withdraw consent at any time, which we will act on immediately, unless there is a legitimate or legal reason for not doing so.

Complaints

We are committed to protecting your personal data but if for some reason you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

We may change this Privacy Notice from time to time and shall notify you of any changes.

This privacy notice provides you with details of how we collect and process your personal data.