Issy Harvey
Vibrant Life Ltd
Blighty, 266 – 268 High Road, London N15 4AJ    

+44 7939 038 550

Issy@vibrantlife.org.uk

I, Issy Harvey , am the registered Data Controller and Processor for all data collected from client(s).

The basis on which I keep client data is that of “Legitimate Interests”. This means that the data is necessary for me to fulfil the contract that we have together (ie to provide coaching with optional  hypno-therapy) and that it is data that you would reasonably expect me to hold and use.

For those who book and attend at least one session, the data I hold includes:

• Basic information such as name, email address, phone number
• Information that you give me/Vibrant Life as part of the work we do together
• Any audio and/or Video recordings
• Records of what interventions that I use (or potentially do not use) in our sessions
• Emails, texts and/or messages that are sent between us
• Information sent from any third party, eg GP, insurance company,

Some of the information that you give me may fall under the definition of special category of data as defined by the General Data Protection Regulation. I rely on your specific consent to hold this data. Your data is not shared with anyone, except possibly your GP, and for any reasons covered by the Requirements for Disclosure which are detailed and discussed when we first meet. 

The data is primarily used to enable me to provide coaching and hypno- therapy for you.

Details of where data is held:

• Any emails sent between us are held on a password and fingerprint protected Apple computer hard drive and/or an iPhone with Face recognition ID security
• Any WhatsApp messages sent between us are encrypted and held on an iPhone with Face Recognition and two-factor security passcodes
• Your notes are held in a Split Note system – your name and contact details are held in a secure file; your records and case notes are anonymised with a code number and held in a separate secure file
• Any zoom video recordings are encrypted and held in a secure iCloud storage.

Your data is kept for 7 years. The length of time is based on the requirements of my insurance company. After this time any paper records are shredded and computer records permanently deleted.

I take the security of data seriously

If there is any breach of data security I will give full details to the Information Commissioners Office and any person affected within 72 hours of the breach and do all possible to minimise any potential impact.

You have rights with regards to the data held:

• The right of access. I will provide you with all data I hold on you as soon as I can following a request (and definitely within 30 days, unless this is impossible due to holidays or illness).
• The right to rectification. If any data I hold is incorrect, just let me know and I will correct it as soon as I can following a request (and definitely within 30 days, unless this is impossible due to holidays or illness).
• The right to erasure. If you wish me to erase your data just let me know and I will delete any computer records and shred any paper records as soon as I can following a request (and definitely within 30 days, unless this is impossible due to holidays or illness). NB: data may be retained for scientific research, historical research or statistical purposes where erasure is likely to render impossible or seriously impair the achievement of that processing but this would never include case notes or data such as address/email/phone
• The right to restrict processing. This would usually be a stop-gap measure before correction of any errors or before erasure
• The right to data portability. This might apply if you want your notes sent to another therapist for example, but it is likely that the easiest solution would come under the right to access, ie I would send the data to you.
• The right to object to:
  • processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling). I do not engage in these things
  • direct marketing.
  • processing for purposes of scientific/historical research and statistics. For this, you must provide grounds for your objection.
  • automated decision making and profiling. I do not engage in automated decision making or profiling