Last updated: 23 January 2022
This policy does not apply to information we process on behalf of our corporate customers and their employees. Please contact the Data Protection Officer (DPO) for more information about this if required, using the contact details below.
This policy may be updated from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, in some cases, we may provide you with additional notice (such as adding a statement to our website homepage or sending you a notification).
2.1 The DPO is responsible for ensuring that this notice is made available to data subjects prior to SMHS collecting/processing their personal data.
2.2 All Staff of SMHS who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and their consent to the processing of their data is secured.
3. Privacy notice
3.1 Who are we?
SMHS delivers solution-based education and treatment for mental health issues to the business community and private individuals. The Services provide supporting resources for those engaging with SMHS.
Our Data Protection Officer (DPO) and data protection representatives can be contacted directly here:
• 0800 2100 777
3.2 What information are we collecting?
Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:
“any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
The personal data we would like to collect from you during you use of the Services is limited to Usage Data, which is collected automatically while you are using the Services.
Usage Data may include information such as your device's Internet Protocol address (IP address), browser type, browser version, the pages of our website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When you access the Services by or through a mobile device, we may collect certain additional information automatically, including, but not limited to, the type of mobile device, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.
We may also collect information that your browser sends whenever you visit our Services or when you access the Services by or through a mobile device.
3.3 How will SMHS use the personal data it collects?
The personal data we collect will be used for the following purposes:
To provide and maintain our Services, including to monitor the usage of our Services
For other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services, products, marketing and your experience.
Our legal basis for processing for the personal data:
Consent obtained from the data subject
Performance of a contract where the data subject is a party – i.e., provision of the Services accessed by you
There are no special categories of personal data collected in relation to the use of the Services.
We are not collecting any details that would allow us to contact you for marketing purposes.
By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified.
You may withdraw consent at any time by ceasing to use or access the Services. Where SMHS has no legitimate reason to continue to hold your information, you have the right to be forgotten.
SMHS will not pass on your personal data to third parties. Aggregated or anonymised data may be used for reporting and monitoring as described in 3.1 above.
SMHS may of course be obliged by law to pass on information to the police or other law enforcement body, or statutory or regulatory authority.
3.6 Retention period
SMHS will not keep personal information for longer than is necessary for the purpose for which it was provided, unless required by law, or has other legitimate reasons to keep it for longer.
3.7 Your rights as a data subject
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
Right of access – you have the right to request a copy of the information that we hold about you.
Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
Right of portability – you have the right to have the data we hold about you transferred to another organisation.
Right to object – you have the right to object to certain types of processing such as direct marketing.
Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
Right to judicial review: in the event that Organisation Name refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below.
In the event that you wish to make a complaint about how your personal data is being processed by SMHS, or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and SMHS’s data protection representatives (the DPO). In the UK, the supervisory authority is the ICO: https://ico.org.uk/
3.9 Accessing the personal data that SMHS holds about you
SMHS at your request, can confirm what information we hold about you and how it is processed. If SMHS does hold personal data about you, you can request the following information:
Identity and the contact details of the person or organisation that has determined how and why to process your data.
Contact details of the data protection officer, where applicable.
The purpose of the processing as well as the legal basis for processing.
The categories of personal data collected, stored and processed.
Recipient(s) or categories of recipients that the data is/will be disclosed to.
How long the data will be stored.
Details of your rights to correct, erase, restrict or object to such processing.
Information about your right to withdraw consent at any time.
How to lodge a complaint with the supervisory authority.
Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
The source of personal data if it wasn’t collected directly from you.
Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
SMHS may require you to provide forms of ID in order to access this information – please contact the DPO for further information.
4. Links to other websites
The Services may, from time to time, contain links to and from other websites that are not operated by us. If you follow a link to any of these external websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these websites or their policies. Please check these policies before you submit any personal data to these external websites.
5. Use of the Services by Minors
You must be 18 years of age, or the age of majority in your province, territory or country, to use these Services.