As part of our day-to-day business of providing therapy services (the “Services”), we need to collect personal information from our clients and potential clients to ensure that we can meet their needs for the provision of or information about the Services. Your privacy is important to us and it is our policy to respect the confidentiality of information and the privacy of individuals. This notice outlines how we manage your personal information and details your rights in respect of our processing of your personal information. We process your information in terms of our Protection of Information Policy and Retention of Data Policy. To review same, kindly send a request to the Information Officer: Shereez Hayat (email@example.com). Defined terms herein, where not herein defined, are defined within the Protection of Personal Information Act, 2013 (as may be amended or substituted from time to time) (“POPIA”).
This Privacy Notice applies to the processing activities of Cape Town Therapy Hub (the “Practice”). The Practice is the Responsible Party (and Operator in certain instances) for the processing of your Personal Information. Any reference to ‘us’, ‘our’, ‘we’ in this Privacy Notice is a reference to both the Practice and the therapists providing therapy services at the Practice (“Therapists”) respectively. Similarly, any reference to ‘you’, ‘your’, ‘yours’ or ‘yourself’ in this Privacy Notice is a reference to any of our clients and potential clients as a Data Subject, or a Competent Person in respect of such client and potential client that is incompetent, such as a minor child. Our Privacy Notice will be reviewed from time to time to take account of new obligations and technology, changes to our operations and practices, and to make sure it remains appropriate to the changing environment.
We collect information necessary to fulfil our obligations to our clients in the course of providing the Services. We may collect the following types of information about you: Name, address and contact details, date of birth and gender, bank details, education and qualifications, employment details, family details, medical aid details, lifestyle and social circumstances, location data, any other similar information. On occasion the following sensitive Personal Information may be obtained: physical or mental health details, racial or ethnic origin, religious or philosophical beliefs, sexual orientation, genetic data, biometric data. We will only obtain and process this information with your express consent as set out in terms of the relevant contractual terms with the relevant Therapist. Much of this information is collected in order to establish and assess the reasons for a referral to us as well as whether we can and should provide the Services (and products, where relevant) to you. If you choose not to provide the information required, we may not be able to provide you with the requested product or service. If you provide us with any Personal Information relating to a third party (e.g. information of your spouse, children, parents, and/or employees), by submitting such information to us, you represent to us that you have obtained their consent and/or are a Competent Person in respect to the provision of such Personal Information. The main activities of the Practice are the provision of therapy services for children and adults. In this respect, by submitting Personal Information (including sensitive personal information) to the Practice, you expressly provide your informed consent for the collection, processing and storage of any minor child’s Personal Information in respect of such minor child and confirm that you are duly authorised to do so as a Competent Person.
We obtain this information in a number of ways, for example through the provision of intake assessments, interviews with you, relevant and related educators, relevant and related health care professionals, family members, questionnaires etc. as well as from information provided in the course of ongoing services and communication. Additionally, we may obtain Personal Information about you through your use of our websites, apps, or using cookies on our websites, in particular by recording your activity and which pages you look at on our websites. We may record any communications with you including electronic (including video conference), by telephone, in person or otherwise, which will constitute evidence of the communications between us. This information is collected in compliance with our regulatory duties in relation to our record keeping obligations. It may or may not be retrievable. Such conversations may be recorded without the use of a warning tone or any other further notice. Further, if you visit any of our offices or premises, we may have CCTV which may record your image and conversations which you acknowledge, understand and accept.
We may be required to collect and use certain types of Personal Information to comply with the requirements of the law and/or regulations, however we are committed to processing all personal information in accordance with POPIA and any other relevant data protection laws and codes of conduct (herein collectively referred to as “the data protection laws”) which are applicable to the Practice and its business.
The data protection laws allow us to only process your data for certain reasons:
All the processing carried out by us falls into the permitted reasons, for example; our use of your personal information in order to comply with our obligations under contract. This includes where a contract is not yet signed but you have requested us to take action as a first step (e.g. provide details of our services).
Where our use of your personal information requires consent, such consent will be provided explicitly by you as set out herein, in the Terms & Conditions entered into by you with the relevant Therapist at the Practice, or as otherwise provided or procured. If we rely on your consent as our legal basis for processing your personal information, you then have the right to withdraw that consent at any time by contacting us using the contact details set out in this Privacy Notice; however, the withdrawal of consent may be limited by law or contract or subject to the completing of a relevant service or other similar and related activity. Withdrawal of consent will likely necessitate the termination of services. We may use WhatsApp for communication, which has embedded end-to-end encryption that ensures only the persons you’re communicating with can read or listen to what is sent, and nobody in between, not even WhatsApp. We may use Google Workspace (formerly “GSuite”) which is designed to meet stringent privacy and security standards based on industry best practices. We may also utilise Microsoft Teams and Zoom. Further information can be provided on request or researched via their respective websites. You consent to us processing personal information via these channels as well as telephonic communication.
We may use information held about you in the following ways:
We may share the Personal Information we hold about you across the Practice and its Therapists to enable us to better understand your needs and run your accounts in the efficient way that you expect. Your Personal Information may also be used for customer modelling, statistical and trend analysis, with the aim of developing and improving our products and services. We will never sell, trade, or rent your Personal Information to others; however, we may share your information with selected third parties including:
Where we share your data with third parties we ensure that your data is held securely and in line with applicable legislation.
Safeguarding the privacy of your information is important to us, whether you interact with us personally, by phone, by mail, over the internet or any other electronic medium. We hold Personal Information in a combination of secure computer storage facilities and paper-based files and other records and take steps to protect the Personal Information we hold from misuse, loss, unauthorised access, modification or disclosure. When we consider that Personal Information is no longer needed, we will remove any details that will identify you or we will securely destroy the records. However, we may need to maintain records for a significant period of time in line with our regulatory obligations. If we hold any Personal Information in the form of a recorded communication, by telephone, electronic, in person or otherwise in relation to our regulatory obligations as detailed above, this information will be held in line with local regulatory requirements which will generally be until the minor child turns twenty-one years old, or unless a diagnosed disability is present, in which case the information is kept until the client is deceased. Where you have opted out of receiving marketing communication we will hold your details on our suppression list so that we know you do not want to receive these communications. The Retention of Documents Policy contains further information on this and is available on request.
We always take appropriate technical and organisational measures to ensure that your information is secure. In particular, we train our employees who handle Personal Information to respect the confidentiality of customer information and the privacy of individuals. We regard breaches of your privacy very seriously and will impose appropriate penalties, including dismissal where necessary. We have appointed an Information Officer to ensure that our management of Personal Information is in accordance with this Privacy Notice, applicable policies, and the applicable legislation. The internet is an open medium and we cannot guarantee that any information you send to us by email or via our sites will not be intercepted or tampered with; any transmission is at your own risk. Once we have received your information, we will use appropriate procedures and security features to prevent unauthorised access.
The data protection laws give you certain rights in relation to the data we hold on you. These are:
Where you have provided consent to our use of your Personal Information, you also have the unrestricted right to withdraw that consent at any time subject to contractual obligations. Withdrawing your consent means that we will stop processing the Personal Information that you had previously given us consent to use. There will be no consequences for withdrawing your consent; however, in some cases, we may continue to store and use the Personal Information where so permitted by having a legitimate reason for doing so or where required by law, regulation or by any other competent authorities. We may also not be able to continue our services to you. You can read more about these rights within section 5 of POPIA.
Your data may be transferred to, stored at, and processed at a destination outside of South Africa by our service providers (e.g. Google Workspace and WhatsApp). By submitting your Personal Information, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with applicable legislation or other relevant and appropriate laws.
Our sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies or how such websites collect and use your data. Please check these policies before you submit any Personal Information to these websites.
You have the right to request a copy of the Personal Information we hold about you. If you would like a copy of some or all of this information you may contact us as follows:
Information officer contact details
Full name: Shereez Hayat
Email address: firstname.lastname@example.org
Telephone number/s: 021 462 1508
Cape Town Therapy Hub’s head office details
Physical address: 49a Somerset Road, Green Point
Contact email address: email@example.com
Contact telephone number/s: 021 462 1508
If any of the information we hold is inaccurate, you can ask us to make any necessary amendments.
We reserve the right to update this Notice to reflect any legal changes or changes to the way in which we process your Personal Information. The updated Notice will be delivered to you electronically to the details we hold on file and/or published on our website and it will come into effect at the time of publication generally.
If you have any queries regarding privacy issues or the content of this Privacy Notice, you can email us on firstname.lastname@example.org; alternatively, by using the contact details provided above.
If you have a concern about any aspect of our privacy practices, you can make a complaint. This will be acted upon promptly. To make a complaint, please contact us via one of the methods set above. You undertake to first make a good faith attempt to resolve same with the Practice. If you are not first satisfied with our response to your complaint, you have the right to then lodge a complaint with our supervisory authority, the Information Regulator. You can find details about how to do this on their website: https://www.justice.gov.za/inforeg/.