Website Privacy Policy

Introduction

This Privacy Policy forms part of the Terms and covers the Neural Pathways website which may be accessed via; neural-pathways.co.uk (the “Website“) and the Services provided through it. It describes how We collect, protect and use information We receive from Website visitors. The data controller for the Website is Neural Pathways (“We”, “Us”, “Our” or “Neural Pathways”) whose head office is at 3 Kings Court, Kingsway South, Team Valley, Gateshead, NE11 0SH.

We will ensure that all personal and sensitive information provided by you is stored and processed in accordance with the Data Protection Act 1998 and the data protection and privacy principles set down in the act.

Information we may collect from you

You are able to access and browse our website without disclosing your personal data.

We may collect and process the following data about you:

• Information that you provide by filling in forms on our website. This includes information provided at the time of enquiring about our services, providing feedback, completing our contact form or through a job application
• If you contact us, we may keep a record of that correspondence.

Use of personal information

We use the personal information We collect via the Website for the purposes of:

• providing, developing, improving and personalising Our Services and the Website
• providing you with information about Our Services
• dealing with your enquiries and requests
• generating anonymous reports about use of the Website and its features
• using your contact information for recruitment purposes

Security and confidentiality

All of our employees who have access to and are associated with the processing of this data, are obliged to respect the confidentiality of such data in line with the Data Protection Act 1998 and the Data Protection Principles set down in the Act.

Neural Pathways safeguards the security of the personal information you provide to Us with physical, electronic and managerial procedures. We use industry-standard Secure Sockets Layer (SSL) encryption on all pages where We collect personal information.

Any personal information you provide will be held securely and your personal information will not be sold or traded to third parties. In some circumstances We may need to disclose your personal information (i) to a third party to provide a service you have requested, (ii) to fulfil a request for information, (iii) to comply with a legal requirement or request from a competent court, regulator or other authority, or (iv) if We believe that there has been a violation of the Terms, of Our rights or the rights of any third party. Any information about you that We pass to a third-party service provider will be held securely by that party and used only to provide the services or information you have requested.

Cookies

Cookies are small pieces of data sent to your computer when you visit the Website and which enable Us to collect information about you. They are stored in the cookie directory of your hard-drive, and do not necessarily expire at the end of your session although session cookies are automatically deleted when you close your browser. The information We collect in this way may include data about how you use the Website, information about your computer (including your IP address and browser type), demographic data and, if you visited the Website by clicking on a link from a different website, the URL of that website.  We may also collect information about your online activity, such as the pages you have viewed. Our use of cookies also allows registered users of the Website to be presented with a personalised version of the Website.

Although your browser may be set up to allow the creation of cookies, you can specify that you wish to be prompted before a website puts a cookie on your hard drive, so that you can decide whether to allow it. Alternatively, you can set your computer not to accept any cookies. Please refer to your browser instructions or help screen for information about how to do this. If you disable cookies, you may not have access to certain features that make your experience of the Website more efficient and some of Our Services may not function properly. Visitors who disable cookies can still make use of the website.

Social networking

Our Website may offer you the opportunity to share or follow information about the Website (or the products and/or services available through it) using third party social networking functionality (such as through “share this”, “like” or “follow” buttons).

We offer this functionality in order to generate interest in Our Website among the members of your social networks, and to permit you to share and follow opinions, news and recommendations about the Website with your friends. However, you should be aware that sharing personal or non-personal information with a social network may result in that information being collected by the social network provider or result in that information being made publicly-available, including through Internet search engines.

Please note that We do not endorse or control the policies or practices of any third party social network whose functionality you may access through Our Website. You should always read the privacy policy of any social network through which you share information carefully in order to understand their specific privacy and information usage practices.

Access to your information and contacting Neural Pathways

You have the right to request a copy of the personal information Neural Pathways holds about you and to have any inaccuracies corrected. Please address requests (with a return email address where possible) to:

The Data Manager, Neural Pathways, 3 Kings Court, Kingsway South, Team Valley, Gateshead, NE11 0SH.
Email: info@neural-pathways.co.uk.

If you have a query or complaint about this Privacy Policy or about the Website, you can contact Us via the same email address.

Links to external sites from the Website

The Website contains links to other websites. These websites are not covered by this Privacy Policy and Neural Pathways is not responsible for the privacy practices within any of these other websites. You should be aware of this when you leave the Website and We encourage you to read the privacy statements of other websites.

Changes to this Privacy Policy

If this Privacy Policy changes in any way, We will place an updated version on this webpage. If you do not agree with the changes We make please do not continue to use the Website. Regularly reviewing this webpage ensures you are always aware of what information We collect, how We use it and under what circumstances, if any, We will share it with other parties.

Services Privacy Policy

Introduction

Neural Pathways collects information about you, so that through the process of providing neuro-therapy we can identify, co-ordinate, and put in place the best possible neuro – rehabilitation for you.

Neural Pathways is committed to being transparent about how it handles your personal information, to protecting the privacy and security of your personal information and to meeting its data protection obligations under the General Data Protection Regulation (“GDPR”) and the Data Protection Act 2018.

The purpose of this information notice is to make you aware of how and why we will collect and use your personal information both during and after your relationship with Neural Pathways. We are required under the GDPR to notify you of the information contained in this privacy notice.

Neural Pathways has appointed a data compliance lead to oversee compliance with this privacy notice. If you have any questions about this privacy notice or about how we handle your personal information, please contact Claire Marley on 0333 0069015, or by email on claire.marley@neural-pathways.co.uk

Data protection principles

Under GDPR, there are six data protection principles that Neural Pathways must comply with. These provide that the personal information we hold about you must be:

1. processed lawfully, fairly and in a transparent manner.
2. collected only for legitimate purposes that have been clearly explained to you and not further processed in a way that is incompatible with those purposes.
3. adequate, relevant and limited to what is necessary in relation to those purposes.
4. accurate and, where necessary, kept up to date.
5. kept in a form which permits your identification for no longer than is necessary for those purposes.
6. processed in a way that ensures appropriate security of the data.

Neural Pathways is responsible for, and must be able to demonstrate compliance with, these principles. This is called accountability.

What types of personal information do we collect about you?

Personal information is any information about an individual from which that person can be directly or indirectly identified. It doesn’t include anonymised data, i.e. where all identifying particulars have been removed. There are also “special categories” of personal information which require a higher level of protection because it is of a more sensitive nature. The special categories of personal information comprise of information about an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation and genetic and biometric data.

Neural Pathways collects, uses and processes a range of personal information about you.

This includes:

• your contact details, including your name, address, telephone number and personal e-mail
• your emergency contact details
• next of kin information
• your date of birth
• your gender
• details of your GP
• details of your solicitor
• details of your financial deputy
• details of your accident or injury
• information about your family relationships
• details of any benefits that you are receiving
• information about any care you may be receiving or will need to receive
• details of your education and work history
• information about your ability to drive a car
• Neural Pathways may also collect, use and process the following special categories of your personal information (as applicable):
  • information about your health, including any medical conditions, medical reports and related correspondence
  • information about your racial or ethnic origin, religious or philosophical beliefs and sexual orientation
  • information about criminal convictions and offences

How do we collect your personal information?

Neural Pathways may collect personal information about you in a variety of ways. It is collected during the instruction process, either directly from you, or from the person referring you to Neural Pathways for neuro rehabilitation, such as a solicitor, financial deputy or case manager. We may also collect personal information from other external third parties, such as your GP, other healthcare professionals involved in your rehabilitation.

We will also collect additional personal information throughout the period that you are a client of Neural Pathways.

Your personal information may be stored in different places, including in your client file, and in other IT systems, such as the e-mail system.

Why and how do we use your personal information?

We will only use your personal information when the law allows us to. These are known as the legal bases for processing. We will use your personal information in one or more of the following circumstances:

• where we need to do so to fulfil the contract for services we have entered into with you, or your representative
• where we need to comply with a legal obligation
• where it is necessary for our legitimate interests (or those of a third party), and your interests
• or your fundamental rights and freedoms do not override our interests

We may also occasionally use your personal information where we need to protect your vital interests (or someone else’s vital interests).

We need all the types of personal information listed under “What types of personal information do we collect about you?” primarily to enable us to perform our contract with you and to enable us to comply with our legal obligations. In some cases, we may also use your personal information where it is necessary to pursue our legitimate interests (or those of a third party), provided that your interests or your fundamental rights and freedoms do not override our interests.

The purposes for which we are processing, or will process, your personal information are to:

• enable us to maintain accurate and up-to-date contact details
• performance of our contracted neuro rehabilitation role

Please note that we may process your personal information without your consent, in compliance with these rules, where this is required or permitted by law.

What if you fail to provide personal information?

If you fail to provide certain personal information when requested or required, we may not be able to perform the contract we have entered into with you, or we may be prevented from complying with our legal obligations. You may also be unable to exercise your statutory or contractual rights.

Why and how do we use your sensitive personal information?

We will only collect and use your sensitive personal information, which includes special categories of personal information and information about your health, criminal convictions and offences, when the law allows us to.

In this case, we will first provide you, or your representative with full details of the personal information we would like and the reason we need it, so that you can properly consider whether you wish to consent or not. It is entirely your choice whether to consent. Your consent can be withdrawn at any time.

We may also process these special categories of personal information, and information about any criminal convictions and offences, where we have your explicit written consent.

The purposes for which we are processing, or will process, these special categories of your personal information, and information about any criminal convictions and offences, are:

• to be able to carry out a full assessment of your rehabilitation and care needs
• to enable us to make referrals to relevant healthcare professionals
• to enable us to make referrals to care agencies
• to enable us to make referrals to relevant specialist services, such as architects for housing
• adaptations or vehicle suppliers for adapted vehicles

Where Neural Pathways processes other special categories of personal information, i.e. information about your racial or ethnic origin, religious or philosophical beliefs and sexual orientation, this is done only for the purpose of equal opportunities monitoring and in line with our data protection policy.

Personal information that Neural Pathways uses for these purposes is either anonymised or is collected with your explicit written consent, which can be withdrawn at any time. It is entirely your choice whether to provide such personal information.

We may also occasionally use your special categories of personal information, and information about any criminal convictions and offences, where it is needed for the establishment, exercise or defence of legal claims.

Change of purpose

We will only use your personal information for the purposes for which we collected it. If we need to use your personal information for a purpose other than that for which it was collected, we will provide you, prior to that further processing, with information about the new purpose, we will explain the legal basis which allows us to process your personal information for the new purpose and we will provide you with any relevant further information. We may also issue a new privacy notice to you.

Who has access to your personal information?

Your personal information may be shared internally within Neural Pathways, including with members of the Neural Pathways management team, the Neuro Rehabilitation team, the administrative team, the accounts department, if access to your personal information is necessary for the performance of their roles.

Neural Pathways may also share your personal information with third-party service providers (and their designated agents), including:

• healthcare professionals
• your GP
• care agencies
• educational professionals
• the Department of Work and Pensions
• the Driver Vehicle Licensing Authority
• Providers of specialist disability equipment or services
• We may also need to share your personal information with a regulator (such as with the Care Quality Commission) or to otherwise comply with the law.

We may share your personal information with third parties where it is necessary to administer the contract we have entered into with you, where we need to comply with a legal obligation, or where it is necessary for our legitimate interests (or those of a third party).

How does Neural Pathways protect your personal information?

Neural Pathways has put in place measures to protect the security of your personal information. It has internal policies, procedures and controls in place to try and prevent your personal information from being accidentally lost or destroyed, altered, disclosed or used or accessed in an unauthorised way. In addition, we limit access to your personal information to those employees, workers, agents, contractors and other third parties who have a business need to know in order to perform their job duties and responsibilities. You can obtain further information about these measures from our data compliance lead.

Where your personal information is shared with third-party service providers, we require all third parties to take appropriate technical and organisational security measures to protect your personal information and to treat it subject to a duty of confidentiality and in accordance with data protection law. We only allow them to process your personal information for specified purposes and in accordance with our written instructions and we do not allow them to use your personal information for their own purposes.

Neural Pathways also has in place procedures to deal with a suspected data security breach and we will notify the Information Commissioner’s Office (or any other applicable supervisory authority or regulator) and you of a suspected breach where we are legally required to do so.

For how long does Neural Pathways keep your personal information?

Neural Pathways will only retain your personal information for as long as is necessary to fulfil the purposes for which it was collected and processed, including for the purposes of satisfying any legal, health and safety, or reporting requirements.

Neural Pathways will generally hold your personal information only for the duration of your contract with the company.

Personal information which is no longer to be retained, will be securely and effectively destroyed or permanently erased from our IT systems and we will also require third parties to destroy or erase such personal information where applicable.

In some circumstances we may anonymise your personal information so that it no longer permits your identification. In this case, we may retain such information for a longer period.

Your rights in connection with your personal information

It is important that the personal information we hold about you is accurate and up to date. Please keep us informed if your personal information changes, e.g. you change your home address, during your contract with Neural Pathways. Neural Pathways cannot be held responsible for any errors in your personal information in this regard unless you have notified Neural Pathways of the relevant change.

As a data subject, you have a number of statutory rights. Subject to certain conditions, and in certain circumstances, you have the right to:

• request access to your personal information – this is usually known as making a data subject access request and it enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it
• request rectification of your personal information – this enables you to have any inaccurate or incomplete personal information we hold about you corrected
• request the erasure of your personal information – this enables you to ask us to delete or remove your personal information where there’s no compelling reason for its continued processing, e.g. it’s no longer necessary in relation to the purpose for which it was originally collected
• restrict the processing of your personal information – this enables you to ask us to suspend the processing of your personal information, e.g. if you contest its accuracy and so want us to verify its accuracy
• object to the processing of your personal information – this enables you to ask us to stop processing your personal information where we are relying on the legitimate interests of the business as our legal basis for processing and there is something relating to your particular situation which makes you decide to object to processing on this ground
• data portability – this gives you the right to request the transfer of your personal information to another party so that you can reuse it across different services for your own purposes.

If you wish to exercise any of these rights, please contact our data compliance manager. We may need to request specific information from you in order to verify your identity and check your right to access the personal information or to exercise any of your other rights. This is a security measure to ensure that your personal information is not disclosed to any person who has no right to receive it.

In the limited circumstances where you have provided your consent to the processing of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. This will not, however, affect the lawfulness of processing based on your consent before its withdrawal. If you wish to withdraw your consent, please contact our data compliance manager. Once we have received notification that you have withdrawn your consent, we will no longer process your personal information for the purpose you originally agreed to, unless we have another legal basis for processing.

If you believe that Neural Pathways has not complied with your data protection rights, you have the right to make a complaint to the Information Commissioner’s Office (ICO) at any time. The ICO is the UK supervisory authority for data protection issues.

Transferring personal information outside the European Economic Area

Neural Pathways will not transfer your personal information to countries outside the European Economic Area.

Changes to this privacy notice

Neural Pathways reserves the right to update or amend this privacy notice at any time, including where Neural Pathways intends to further process your personal information for a purpose other than that for which the personal information was collected or where we intend to process new types of personal information. We will issue you with a new privacy notice when we make significant updates or amendments. We may also notify you about the processing of your personal information in other ways.

Contact

If you have any questions about this privacy notice or how we handle your personal information, please contact our data compliance lead as follows:

Claire Marley – Group Operations Lead

Neural Pathways, 3 Kings Court, Kingsway South, Team Valley, Gateshead, Tyne & Wear NE11 0SH

Tel: 0333 0069015 Email: claire.marley@neural-pathways.co.uk