Data Protection Policy

 

Introduction

My Neurons is a trading name for the sole trader Sarah Bisson. My Neurons provides tutoring, assessment and advice services to their clients. This policy sets out My Neurons’s commitment to ensuring that any personal data, including special category personal data, which My Neurons processes, is carried out in compliance with data protection law. ‘Data Protection Law’ includes the General Data Protection Regulation 2016/679; the UK Data Protection Act 2018 and all relevant EU and UK data protection legislation.

Information about me:

 My Neurons provides assessments for Specific Learning Difficulties for children and adults. I also provide exam arrangement assessment for schools.

Data Protection Officer: Sarah Bisson

 Data Protection Registration Certificate Number: ZA538791

 Date of review: 16^th February 2024

 Overview

 My Neurons is committed to respecting the privacy and protecting the data of clients. My Neurons protects the privacy of all who share personal data with us via email, post, text, phone or via the website: myneurons.co.uk

My Neurons will only collect and use personal data in ways that are described in this policy. There are strict policies and procedures in place to protect your data when you send it to me, and when I process it to provide you with the services you have requested.

The data you provide me will be used only for the efficient provision of agreed upon services and it will not be shared with anyone else unless explicitly stated in this document.

You have the right to see what data I hold on you and request that any data held is amended or deleted. Please contact me, if you have any concerns or queries.

I am registered with the Information Commissioner’s Office, the regulator of the Data Protection Act 1998 and abide by its requirements.

What information does my website collect?

 The only information you input into the My Neurons website is when you send a message through the ‘Contact Page’. This information is not stored by the web hosting company.

What information does My Neurons collect from clients?

 Depending on the service we are providing, we may collect the following data for adults and children. We collect this through paper and electronic questionnaires and documentation provided by you, over the phone, by email or submitted online:

• Name (Title, First and Surname);
• Home address;
• Email address;
• Telephone number;
• Medical/disability information;
• Date of birth;
• Gender;
• Background information on the child or adult being assessed or tutored (collected from child/parents/school)

How does My Neurons collect your data?

 When you conduct a transaction by email, by phone or text My Neurons collect only the personal information you give us, (such as your name, phone number, email address), which is necessary to provide my services.

When you engage my services as an assessor, consultant or supplier I collect information through email, and questionnaires. We communicate via email and text and will keep your details in our email system in order to reply to you and to keep you informed about the services you are interested in.

Why does My Neurons collect your data?

 To communicate with you as a response to an email, web enquiry, text or telephone call; To supply you with the services and products you request;

To provide you with ongoing support and services; To collect payment for our services; To comply with statutory requirements for bookkeeping, auditing and accounting.

How does My Neurons store your data?

 When you engage our services we store the information I collect about you electronically and/or on paper. Electronic data is kept in a secure cloud server and files containing sensitive information, such as diagnostic assessment reports, are password protected. Hard copies of documents are stored securely in a fireproof, locked filing cabinet.

Additionally, I use a secure online accounting service for invoicing and to store your name, email address and postal address within their system.

The online cloud and accounting service, are GDPR compliant and do not have access to any of your data.

 How does My Neurons share your data?

 I will not share data with 3rd parties.

 How long does My Neurons we keep your data?

 This will vary depending on the services provided.

 My Neurons keeps copies of assessment reports, (stored electronically), and test papers for the time required by law and as advised by our professional bodies. This may vary over time.

Currently electronic reports are kept for 6 years for adults and reports for minors are kept until they are 25 years of age. Test papers are destroyed after 12 months. Background questionnaires are stored in the secure cloud with the reports.

What are your rights?

 You have a number of rights under the GDPR including data correction, data erasure, data restriction, data objection etc. For full details see https://ico.org.uk/for-organisations/guide- to-the- general-data-protection-regulation-gdpr/individual-rights/.

You have the right to request your data, or withdraw your consent, as described below. Please contact me for information on any other rights mentioned above.

How can you withdraw your consent?

 You have the right to have your person data erased.

 You can withdraw your consent by contacting me, the relevant Data Protection Officer, (listed at the beginning of this document), in writing. If you do not receive a response to your email, please contact me again. I will act upon your request without undue delay and within one month of receipt.

Please note that this right is not absolute – I am required to hold certain data for legal and accounting reasons.

How can you get access to your personal data?

 If you want to know what personal data we have about you or your child, you can ask me for details of that personal data and for a copy of it. This is known as a subject access. Please email me, the relevant Data Protection Officer, (listed at the beginning of this document), for the information.

There is no charge for a subject access request if it is reasonable. I will aim to reply to your request within one month, but in some cases this can take up to three months

Complaints and questions

 Please contact me in the first instance with any questions or complaints you may have. sarah@myneurons.co.uk

Updates to privacy policy

 I reserve the right to modify this privacy policy at any time.

 If you would like to find out more about your rights and our obligation under the General Data Processing Regulation then please visit: https://ico.org.uk/

Scope

This policy applies to all personal data processed by My Neurons and is part of My Neurons’s approach to compliance with data protection law.

Data protection principles

My Neurons complies with the data protection principles set out below. When processing personal data, they ensures that:
• it is processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’)
• it is collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes (‘purpose limitation’)
• it is all adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’)
• it is all accurate and, where necessary, kept up to date and that reasonable steps will be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (‘accuracy’)
• it is kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed (‘storage limitation’)
• it is processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’)
My Neurons will facilitate any request from a data subject who wishes to exercise their rights under data protection law as appropriate, always communicating in a concise, transparent, intelligible and easily accessible form and without undue delay.
Process/procedures/guidance
My Neurons will:
• ensure that the legal basis for processing personal data is identified in advance and that all processing complies with the law
• not do anything with your data that you would not expect given the content of this policy and the fair processing or privacy notice
• only collect and process the personal data that it needs for purposes it has identified in advance
• ensure that, as far as possible, the personal data it holds is accurate, or a system is in place for ensuring that it is kept up to date as far as possible
• only hold onto your personal data for as long as it is needed, after which time My Neurons will securely erase or delete the personal data.
• ensure that appropriate security measures are in place to ensure that personal data can only be accessed by those who need to access it and that it is held and transferred securely

Data Subject Rights

My Neurons has processes in place to ensure that it can facilitate any request made by an individual to exercise their rights under data protection law.
All requests will be considered without undue delay and within one month of receipt as far as possible.
Subject access: the right to request information about how personal data is being processed, including whether personal data is being processed and the right to be allowed access to that data and to be provided with a copy of that data along with the right to obtain the following information:
• the purpose of the processing
• the categories of personal data
• the recipients to whom data has been disclosed or which will be disclosed
• the retention period
• the right to lodge a complaint with the Information Commissioner’s Office
• the source of the information if not collected direct from the subject, and
• the existence of any automated decision making
Rectification: the right to allow a data subject to rectify inaccurate personal data concerning them.
Erasure: the right to have data erased and to have confirmation of erasure, but only where:
• the data is no longer necessary in relation to the purpose for which it was collected, or
• where consent is withdrawn, or
• where there is no legal basis for the processing, or
• there is a legal obligation to delete data
Restriction of processing: the right to ask for certain processing to be restricted in the following circumstances:
• if the accuracy of the personal data is being contested, or
• if our processing is unlawful but the data subject does not want it erased, or
• if the data is no longer needed for the purpose of the processing but it is required by the data subject for the establishment, exercise or defence of legal claims, or
• if the data subject has objected to the processing, pending verification of that objection
Data portability: the right to receive a copy of personal data which has been provided by the data subject and which is processed by automated means in a format which will allow the individual to transfer the data to another data controller. This would only apply if My Neurons was processing the data using consent or on the basis of a contract.
Object to processing: the right to object to the processing of personal data relying on the legitimate interests processing condition unless My Neurons can demonstrate compelling legitimate grounds for the processing which override the interests of the data subject or for the establishment, exercise or defence of legal claims.

Special category personal data

This includes the following personal data revealing:
• racial or ethnic origin
• political opinions
• religious or philosophical beliefs
• trade union membership
• the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person
• an individual’s health
• a natural person’s sex life or sexual orientation
• criminal convictions or offences