Privacy Policy

Who are Mable Therapy?

Mable Therapy provides Speech & Language and Counselling Therapy services to children and young people between the ages of four and twenty-five. This privacy notice informs you as to how we process your personal data on our website and when you use our services. This privacy notice also tells you about your privacy rights pursuant to the Data Protection Act 2018 and UK GDPR and EU GDPR (“Data Protection Laws”).

Controller for personal data

We are Mable Therapy Limited (“Mable Therapy”) registered in England and Wales under company number 09529674 and have our registered office address at Mable Therapy, No.1 Aire Street, Leeds, LS1 4PR.

A “controller” is a person or organisation who alone or jointly determines the purposes for which and the way any personal data is or is likely to be processed. Unless we notify you otherwise Mable Therapy is the controller of your personal data for the purpose of this website and where we carry out our services to you.

Types of personal data

Personal data or personal information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed. This is known as anonymised data. Anonymised data falls outside the scope of Data Protection Laws.

To provide a high standard of clinical service Mable Therapy may need to obtain information from the client, from parents or carers and from those working directly with the client in a professional capacity and where this information is also used for the administration of our services to the parent or carer.

Mable Therapy processes personal data relating to pupils, school staff, parents and other health and social care professionals. Information obtained from the parent or carer and other sources during treatment include personal details, details relating to family lifestyle and social circumstances, education and training and employment. This information may be shared with the parent or carer, relatives and other healthcare or education professionals with the client and/or parent/carer permission.

Mable Therapy may collect, use, store and transfer different kinds of personal data about you which we have grouped together:

Identity Data includes first name, last name, date of birth (where you are a client for our services).
Contact Data includes billing address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details for the provision of services you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.
Usage Data includes information about how you use our website and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

How we collect your personal data

Directly from you

You give us your personal data in your direct interactions with us. Such personal data includes Identity Data, Contact Data, Financial Data, Usage Data, Technical Data, Marketing and Communications Data (i) by completing forms on our website (ii) by leaving comments (iii) by corresponding with us by email or post (iv) by calling us over the telephone.

We may collect personal data when you:

Register as a user on our sites or the Mable platform. You should not allow others to access your account, for example by sharing your login details with a colleague. For example all members of your school are entitled under the licensing agreement to set up their own account which they can do on the sites or by contacting the Mable representative within your school or contacting the Mable team on 0800 024 8646.

Input client data at app.mable.co.uk and onboarding to the Mable platform at onboarding.mabletherapy.com
Hold telephone conversation with account managers and clinicians
Contact us through email, website chat tools, SMS messages and engagement with our social media channels.
Sign up to access free content or to receive newsletters

From use of our website

We may gather information and statistics collectively about visitors to our website. Analysis of this information demonstrates the most frequently used sections of the website and assists us in continually improving the online service. You give us your personal data, which includes Usage Data, Technical Data and/or Marketing and Communications Data when you use our website or which we have agreed with you to use or when you review any publications or marketing material we send you. Please see our cookies notice for more information.

Indirectly: Third-party sources

We receive Identity Data and Contact Data about you from third parties (such as a Local Authority) when:

We provide our services or other parties send us your personal data to enable the provision of those service.
You provide your personal data to a third party for the purpose of sharing it with us.

How we use your personal data

We will only use your personal data when the law allows us to. We will use your personal data in the following circumstances:

Performance of a contract: Where we need to perform the contract, we are about to enter into or have entered into with you. For example, when we provide our services to you.
Legal obligation: Where we need to comply with a legal obligation. For example, for accounting or legal purposes.
Legitimate interests: 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.
Consent: We do not generally rely on consent as a legal basis for processing your personal data. Where we do rely on consent you have the right to withdraw consent at any time. Please contact us at DPO@mabletherapy.com to withdraw consent. Please also see Marketing communications.

Purposes for which we will use your personal data

We have set out below in a table format a description of all the ways we plan to use your personal data and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To provide you with our services	(a) Identity (b) Contact	Performance of a contract with you
To respond to any enquiries	(a) Identity (b) Contact	(a) Performance of a contract with you (b) Necessary for our legitimate interests
To process and deliver our services to you including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests i.e., to recover debts due to us
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy notice (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests i.e., to keep our records updated and to study how customers use our products/services
To administer and protect our business and this website including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Usage (d) Marketing and Communications (e) Technical	Necessary for our legitimate interests i.e., to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy Note: Where applicable consent will be used for data analytics obtained through cookies or similar technologies. See our cookies notice
To make suggestions and recommendations to you about our services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Marketing and Communications	Necessary for our legitimate interests to develop our products/services and grow our business

Special Category Data

Data relating to an individual’s health is classified as “Special Category Data” under Article 9 of the UK/EU GDPR. Where we process sensitive data we will ask for your explicit consent. Please note our health professionals such as Speech and Language Therapists are legally bound to keep client information confidential and it is under this condition that we process and store personal information.

Therapists employed and subcontracted by Mable Therapy are registered with an appropriate professional body (such as BACP, RCSLT, HCPC and others). They are subjected to an enhanced DBS check when employed with the company which is updated every three years.

Marketing communications

Mable Therapy may send you marketing communication which may be of interest to you relating to our services. You have the right to object to processing of your personal data for direct marketing purposes. You can unsubscribe from receiving marketing communications from us by using the unsubscribe methods contained in communications we send to you or by contacting us. See Contact us.

Where you opt out of receiving marketing communications this will not apply to personal data provided to us as a result of registering for or using our service, your service experience or other interactions with this website.

How we share your personal data

We want to inform our service users that the following parties may have access to your personal information. The reason is to perform the tasks assigned to them on our behalf. They are obligated not to disclose or use the information for any other purpose.

Unless we are required to do so by law or for child safeguarding purposes we will not disclose any personal information collected by any person other than as set out above.

Internally: Your personal data will be used by our employees and contractors including health care professionals who are working on providing your services to you on a need-to-know basis.
Suppliers: This would include service providers who support our business including IT and communication suppliers and outsourced business support to ensure our service runs smoothly.
Professional advisers: This would include lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
Law enforcement bodies, regulators and other authorities: This is to comply with our legal requirements or adhere to good practices.
Advertising networks and analytics service providers: This is to support the function of our website and to understand your engagement on our website, apps and other social media tools.
Third parties: This is in the context of the acquisition or transfer of any part of our business or in connection with the business reorganisation. If a change happens to our business then the new owners may use your personal data in the same way as set out in this privacy notice.

International transfers

How we safeguard personal data when we transfer it internationally

We ensure a similar degree of protection is afforded whenever we transfer personal data out of the UK/EEA by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information; or
We will use specific contracts approved for use in the UK by the UK Government or by the EU Commission which give personal information the same protection it has in the UK/EU. For example with the use of Article 46 UK/EU GDPR safeguard mechanisms to transfer personal data.

Please contact us if you would like further information about the specific mechanism used by us when transferring your personal data out of the UK/EEA.

Data security and storage of records

We will protect personal data and keep it safe from unauthorised or unlawful access, alteration, processing or disclosure and against accidental or unlawful loss, destruction or damage. In particular:

Paper-based records are kept under lock and key and when not in use.
Portable electronic devices are encrypted and password protected.
Patient records are kept on EU servers.
Patient reports are encrypted.
Users are authenticated when logging in by personal usernames and passwords. There are different levels of authorisation depending on the level of user permission.
Mable uses industry-standard security technologies such as HTTPS support, secure RTP, HTTP authentication, secure WebSockets and application level authentication using tokens to ensure secure video streaming.

Data retention and disposal

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal information we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means and the applicable legal, regulatory, tax, accounting or other requirements.

We may anonymise your personal data so that it can no longer be associated with you for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Disposal of records

Client data is kept in accordance with the Standards of Conduct Performance and Ethics from the Health Care Professionals Council. The SCPE are the standards we set for all the professionals stating terms our expectations of their behaviour and conduct. Importantly for service users they outline what the public should expect from their health and care professional.
Personal data not belonging to clients and that is no longer needed will be disposed of securely.
Personal data that has become inaccurate or out of date will also be disposed of securely, where we cannot or do not need to rectify or update it. For example we will shred or incinerate paper-based records and overwrite or delete electronic files.

Data Subject Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Not all rights are absolute. You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of some or all of the personal data we hold about you and to check that we are processing it lawfully.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below) or where we may have processed your information unlawfully. Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to the processing of your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground as you feel it has an impact on your fundamental rights and freedoms. You also have the right to object if we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Automated decision making: This is where decisions are made about you by automated means. We do not carry out automated decision making.

Children and subject access requests

Personal data about a child belongs to that child and not the child’s parents or carers. For a parent or carer to make a subject access request with respect to their child the child must either be unable to understand their rights and the implications of a subject access request or have given their consent.

Children below the age of 12 are generally not regarded to be mature enough to understand their rights and the implications of a subject access request. Therefore, most subject access requests from parents or carers of pupils at our school may be granted without the express permission of the pupil. This is not a rule and a pupil’s ability to understand their rights will always be judged on a case-by-case basis.
Children aged 12 and above are generally regarded to be mature enough to understand their rights and the implications of a subject access request. Therefore, most subject access requests from parents or carers of pupils at our school may not be granted without the express permission of the pupil. This is not a rule and a pupil’s ability to understand their rights will always be judged on a case-by-case basis.

Responding to subject access requests

When responding to requests we:

may ask the individual to provide 2 forms of identification.
may contact the individual via phone to confirm the request was made.
will respond without delay and within 1 month of receipt of the request.
will provide the information free of charge.
may tell the individual we will comply within 3 months of receipt of the request, where a request is complex or numerous. We will inform the individual of this within 2 weeks and explain why the extension is necessary.

If you wish to exercise any of the rights set out above, please contact us. See Contact us.

Concerns and complaints

We would appreciate the chance to deal with your concerns in the first instance. Please see Contact us section. If you have unresolved concerns and you live or work in the UK or believe that a personal data breach happened in the UK you have the right to complain at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).

If you live or work outside the UK or you have a complaint concerning our personal data processing activities you may lodge a complaint with another supervisory authority.

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KEEPING DATA SAFE

Our privacy policy