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Privacy Notices (NHS Patients)

Effective date for users who register from 07 March 2022: 07 March 2022

Effective date for users who registered before 07 March 2022: 07 April 2022

Previous versions can be obtained from the Data Protection Officer.

We are committed to protecting your privacy and confidentiality.


Introduction

These are the Privacy Notices that cover the supply of Cognitive Behavioural Therapy services provided online (the Service) through https://my.iesohealth.uk (the Site) and our research and product development activities. The Site and the Service are provided by Ieso Digital Health (UK) Ltd.  In this Privacy Notice, the terms ieso, we, us, or our refer to Ieso Digital Health (UK) Ltd and our group of companies (that also includes Ieso Digital Health Ltd and Ieso Digital Health, Inc.). Ieso Digital Health (UK) Ltd and Ieso Digital Health Ltd are data controllers of UK personal data and are registered with the Information Commissioner (registration numbers ZA239229 andZ5383093). If you don’t understand or require further information on anything below, please contact our Data Protection Officer h.simpson@iesohealth.com. Full details on how to contact us can be found in section 9 below.

By agreeing to the terms and conditions of the Service you have entered into a contract with us which forms the legal basis for most of the processing of your personal information, including for research compatible with the original purposes of processing. Safeguarding and NHS minimum data set information is processed under legal obligation; standard information sharing with GPs is by consent; any information held in establishment or defence of a legal claim or complaint is processed in our legitimate interests; and processing to uphold NHS opt outs is to carry out a public task. We process your special category data for medical purposes. As part of our contract with you, we are committed to continued improvement and development. Research supports us to provide you and all our patients with high-quality evidence-based care and products, and to help more people get treatment earlier. We publish findings (which only ever include aggregated data) in peer reviewed scientific journals, satisfying the legal basis of the special category data processing being necessary for scientific research purposes, which we use for a subset of our research activities.

Here we explain what personal information we collect, how it is used, shared, secured, stored, and how you can exercise choices and manage your data. These Privacy Notices reflect legal requirements, regulations, and best practice.

We understand that the privacy and confidentiality of all the personal information, especially the verbatim records of therapy sessions, that you provide and we handle, is important to you, and our internal policies and procedures reflect this and the need to share the minimum information necessary.

What these Privacy Notices cover

These Privacy Notices describe our treatment of personal and clinical information that we collect when you access or use our Service.

We describe here how we handle your personal and clinical information for the purposes of providing and improving the Service and for scientific research. 

We will not sell your personal information for direct marketing or other promotional purposes.

These Privacy Notices apply to any Site where they are referenced, regardless of the computer, mobile or other device you use to access or use the Service. The site and Service includes links to websites that are owned and operated by third parties. We are not responsible for the privacy policies or content of such websites.

We reserve the right to change these Privacy Notices from time to time by changing them on the Site and by notifying you through your account or by email. Amended terms will take effect 30 days after they are published.


We collect the following personal information about you in several ways:

1. Information we collect

We collect the following personal information about you in several ways:

a) Information you provide to us when you register and use our Service
  • Registration information - when you register, we collect contact information such as your name, date of birth, email address and mobile number; information to authenticate you as an eligible patient such as your date of birth, NHS number, GP details and address, and to authenticate your access to the Service by way of a password for your sign-insecurity; and information required by the NHS, mostly not mandatory to answer, such as gender, ethnicity, religion to enable them to create a picture of services delivered around the country to check that quality standards are similar everywhere and the local demographic population is provided with adequate services (all reports published from this data are aggregated and contain no information that could reveal your identity).
  • Assessment information - we collect information using standard structured patient assessment questionnaires both to initially establish what treatment plan is likely to be beneficial to your needs, and on an ongoing basis prior to each session of your subsequent care. Assessment information can cover a range of factors relevant to your experiences and how you are feeling in addition to your medical history, lifestyle, family, work and education.
  • During the course of your treatment - This includes messaging between you and your therapist between sessions to arrange and provide you with information about your therapy sessions, the sessions themselves, the ‘homework’ activities and questionnaires completed, and the setting of goals. The sessions comprise a verbatim record of conversation between you and your therapist that are retained in the form of a transcript for text therapy or an audio file for video therapy, and which you can access through the account settings of the Service. This will include information relevant to and about how you are feeling at that point in time. You will be encouraged to record goals within your account, and we generate information about these treatment goals and assessment score graphs to help you and us to monitor and understand your progress.
  • Your queries or comments - we will collect information if you contact us for example with a question or comment about the Service and/ or its content.

You always have the option to refuse to submit personally identifiable information to us but note that without this information, the Services may be unavailable to you.

b) Information we collect from other sources

We add to the information we collect from you with information we receive from other sources. This includes:

  • Referral information - from your General Practitioner (GP) or healthcare provider, if you are referred by them for treatment to ieso and the Service. This will usually include your name, date of birth, address, mobile number, email address, NHS number, reason for referral and any relevant assessment notes and questionnaire scores.
  • Therapist notes - At the end of each session your therapist will produce a short set of clinical notes to summarise the session. For some of our NHS contracts, these summary notes are copied into your health record on your health care provider’s patient management system, but the verbatim records of sessions will never be copied over.
  • Supervision notes – a therapist may share some of your details with their supervisor per section 2 below and receive advice and /or feedback. Where this affects the treatment you receive, and/or the outcome, it makes up part of your medical record with us.
  • Demographic information - that is publicly available and that enables us to understand anonymous health statistics at postcode level.
c) Information collected automatically from your use of the Service
  • Session activity information - we collect information about you from your use of the Service. (E.g., when you log on, accept an appointment, join a session etc.)
  • Device information - this includes information about whether you are using the service on a mobile, tablet or computer. This helps us understand how people interact with our service so that we can ensure the Service is optimised for different devices.
  • Log information - we collect technical information such as your Internet Protocol (IP) address, (the unique address that identifies your device or computer on the internet), your browser type and when, how often and for how long you interact with the Service.

See here or read below for further information on cookies

Certain information is collected automatically from your computer or device about your engagement with the Service. This includes:

2. How we use collected information (includes sharing within ieso, and our contracted therapists and Psychological Wellbeing Practitioners)

We use the personal information we collect to ensure that we provide you with the best possible treatments both now and in the future. We have appointed a Data Protection Officer and Caldicott Guardian to seek to ensure that our procedures for handling patient information meet with our obligations. We use the personal and clinical information that we receive under our terms with you to:

  • Assess your suitability and eligibility
  • Register you with the Service - to consider requests for use of the Service and to enable sign-in and verified access and use of the Service.
  • Assess your treatment needs - to place you with an appropriate therapist, and to aid selection of exercises and questionnaires.
  • Provide your treatment - your personal information is shared with your therapist to support your treatment and evaluate your progress, including messaging to arrange sessions, conducting sessions, assessing progress against treatment goals and maintaining your case file. It’s your choice to decide what to share with your therapist, but the more information that your therapist has about you, the more likely it is that they will be able to provide you with highly effective treatment. Your therapist only has access to your personal information during your treatment and for 6 weeks after discharge to allow for reflection and/ or to consider any feedback from you.
  • Subject to appropriate safeguards, some of the details of your case maybe shared in your therapist’s routine clinical supervision with their Clinical Supervisor if they wish to obtain advice or assurance on the work you are doing together. The British Association of Behavioural & Cognitive Psychotherapies (“BABCP”) requires that all therapists must receive clinical supervision. A Clinical Supervisor is a therapist who has received additional training and is generally more experienced than the therapist. This is to ensure that the therapy you are receiving is the most helpful it can be and remains faithful to best practice evidence. Clinical supervision includes case discussions (and may include referring to messages/ transcripts/ audio recordings) either individually or within a group of therapists, all of whom are bound by confidentiality.
  • Communicate with you
  • via email, phone or the messages section of your file between sessions if/ when appropriate, to confirm appointments, remind about incomplete questionnaires, about Service availability and related Service updates or notifications, or reply to your enquiries, requests or complaints.
  • via text message to remind you about upcoming appointments.
  • via voicemail (where you have agreed to this) for missing information or questionnaires.
  • via post at assessment and /or the end of treatment.
  • Where you have indicated to us on a questionnaire or in response to an email that you would be happy to share your experience of receiving therapy provided by ieso to raise awareness of our service or for therapist training purposes, or to participate in some user experience evaluations, for example, we will use your contact details to give you more information. If you subsequently consent, we will process your information further for this purpose, which would include wider sharing of your personal data as agreed with you.
  • To let you know of any clinical trials/ studies for which you may be eligible (in which of course you can decline to take part).
  • We also contact you after you’ve completed treatment to ask for feedback and to check on your wellbeing.
  • Protect you and/or others - and seek to maintain a confidential and safe environment.

These measures include:

  • user authenticated access controls to the service
  • restricted access to patient identifiable information. Access to patient records within ieso is limited on a strictly 'need to know' basis and wherever possible processed by reference to indirect rather than directly identifying information, such as case reference numbers.
  • ongoing review of the care and help our professional therapists provide to make sure it meets our quality standards. This includes training, case management support, moderation, supervision and monitoring of messaging and treatment sessions.
  • developing learning/ training programmes for our therapists.
  • administering our professional compliance duties and obligations.
  • Uphold the NHS Opt-out service. We submit all patient NHS numbers to the ‘Check for National Opt-outs service’ in order to apply data opt-outs in accordance with patient wishes.
  • Conduct analysis and research to improve our service delivery, patient recovery rates, and service and/or product development. We are passionate about learning from these data by conducting high-quality scientific research to feed into treatment and product development to further improve outcomes and help more people get treatment earlier. We believe research can help provide a greater understanding of both the causes of mental illness and the effectiveness of treatments and interventions for different subgroups of patient. We may use that research to improve the Service, the Site and/or to develop new digital products to improve the assessment or treatment of mental health conditions.  We have internal procedures in place to safeguard your privacy so that only the minimum necessary information is used to conduct the research on the most de-identified data possible, including anonymisation where possible.

(We may anonymise patient data to use for new product development of products intended to help more people get treatment earlier. Although this is not then personal data, you may be interested in reading about an example of this research here.)

Much of our research is based on the NHS Minimum data set (see section 3below), but we also use machine learning, natural language processing (NLP) and artificial intelligence (AI) on questionnaires, communications between you and your therapist, and on therapist summaries of the sessions. Click here for more information about this.

- Determine whether or not a patient is eligible and suitable for participation in one of our clinical trials/ studies. We are data-driven research orientated company who passionately believe in responsible innovation to increase the understanding of mental health, improve treatments and widen access to treatment, and our clinical team may review your data to identify participants.

We only ever share the minimum information necessary to provide the best treatments, care and protection for yourself or others, or to satisfy legal requirements. For example, depending on your referring healthcare provider, your data may be provided to update their records and/or as part of the Minimum Data Set required nationally by NHS England for all its patients. We have specific processes in place regarding verbatim records of sessions which are only shared internally or externally in very limited circumstances, for example we may facilitate joint viewing of/ listening to specific verbatim records of sessions with the contracting NHS service in the case of a serious upheld complaint, see section 3 'When we share your information'. We will always seek your permission before disclosing your personal identifiable information to another person or organisation for any other reason than those set out in these privacy notices, unless we have an overriding legal duty to so do (for example, in the prevention and/or detection of a crime).

3. When we share your information

We use the personal information we collect to ensure that we provide you with the best possible treatments both now and in the future. We have appointed a Data Protection Officer and Caldicott Guardian to seek to ensure that our procedures for handling patient information meet with our obligations. We use the personal and clinical information that we receive under our terms with you to:

  • Assess your suitability and eligibility
  • Register you with the Service - to consider requests for use of the Service and to enable sign-in and verified access and use of the Service.
  • Assess your treatment needs - to place you with an appropriate therapist, and to aid selection of exercises and questionnaires.
  • Provide your treatment - your personal information is shared with your therapist to support your treatment and evaluate your progress, including messaging to arrange sessions, conducting sessions, assessing progress against treatment goals and maintaining your case file. It’s your choice to decide what to share with your therapist, but the more information that your therapist has about you, the more likely it is that they will be able to provide you with highly effective treatment. Your therapist only has access to your personal information during your treatment and for 6 weeks after discharge to allow for reflection and/ or to consider any feedback from you.
  • Subject to appropriate safeguards, some of the details of your case maybe shared in your therapist’s routine clinical supervision with their Clinical Supervisor if they wish to obtain advice or assurance on the work you are doing together. The British Association of Behavioural & Cognitive Psychotherapies (“BABCP”) requires that all therapists must receive clinical supervision. A Clinical Supervisor is a therapist who has received additional training and is generally more experienced than the therapist. This is to ensure that the therapy you are receiving is the most helpful it can be and remains faithful to best practice evidence. Clinical supervision includes case discussions (and may include referring to messages/ transcripts/ audio recordings) either individually or within a group of therapists, all of whom are bound by confidentiality.
  • Communicate with you
  • via email, phone or the messages section of your file between sessions if/ when appropriate, to confirm appointments, remind about incomplete questionnaires, about Service availability and related Service updates or notifications, or reply to your enquiries, requests or complaints.
  • via text message to remind you about upcoming appointments.
  • via voicemail (where you have agreed to this) for missing information or questionnaires.
  • via post at assessment and /or the end of treatment.
  • Where you have indicated to us on a questionnaire or in response to an email that you would be happy to share your experience of receiving therapy provided by ieso to raise awareness of our service or for therapist training purposes, or to participate in some user experience evaluations, for example, we will use your contact details to give you more information. If you subsequently consent, we will process your information further for this purpose, which would include wider sharing of your personal data as agreed with you.
  • To let you know of any clinical trials/ studies for which you may be eligible (in which of course you can decline to take part).
  • We also contact you after you’ve completed treatment to ask for feedback and to check on your wellbeing.
  • Protect you and/or others - and seek to maintain a confidential and safe environment.

These measures include:

  • user authenticated access controls to the service
  • restricted access to patient identifiable information. Access to patient records within ieso is limited on a strictly 'need to know' basis and wherever possible processed by reference to indirect rather than directly identifying information, such as case reference numbers.
  • ongoing review of the care and help our professional therapists provide to make sure it meets our quality standards. This includes training, case management support, moderation, supervision and monitoring of messaging and treatment sessions.
  • developing learning/ training programmes for our therapists.
  • administering our professional compliance duties and obligations.
  • Uphold the NHS Opt-out service. We submit all patient NHS numbers to the ‘Check for National Opt-outs service’ in order to apply data opt-outs in accordance with patient wishes.
  • Conduct analysis and research to improve our service delivery, patient recovery rates, and service and/or product development. We are passionate about learning from these data by conducting high-quality scientific research to feed into treatment and product development to further improve outcomes and help more people get treatment earlier. We believe research can help provide a greater understanding of both the causes of mental illness and the effectiveness of treatments and interventions for different subgroups of patient. We may use that research to improve the Service, the Site and/or to develop new digital products to improve the assessment or treatment of mental health conditions.  We have internal procedures in place to safeguard your privacy so that only the minimum necessary information is used to conduct the research on the most de-identified data possible, including anonymisation where possible.

(We may anonymise patient data to use for new product development of products intended to help more people get treatment earlier. Although this is not then personal data, you may be interested in reading about an example of this research here.)

Much of our research is based on the NHS Minimum data set (see section 3below), but we also use machine learning, natural language processing (NLP) and artificial intelligence (AI) on questionnaires, communications between you and your therapist, and on therapist summaries of the sessions. Click here for more information about this.

- Determine whether or not a patient is eligible and suitable for participation in one of our clinical trials/ studies. We are data-driven research orientated company who passionately believe in responsible innovation to increase the understanding of mental health, improve treatments and widen access to treatment, and our clinical team may review your data to identify participants.

We only ever share the minimum information necessary to provide the best treatments, care and protection for yourself or others, or to satisfy legal requirements. For example, depending on your referring healthcare provider, your data may be provided to update their records and/or as part of the Minimum Data Set required nationally by NHS England for all its patients. We have specific processes in place regarding verbatim records of sessions which are only shared internally or externally in very limited circumstances, for example we may facilitate joint viewing of/ listening to specific verbatim records of sessions with the contracting NHS service in the case of a serious upheld complaint, see section 3 'When we share your information'. We will always seek your permission before disclosing your personal identifiable information to another person or organisation for any other reason than those set out in these privacy notices, unless we have an overriding legal duty to so do (for example, in the prevention and/or detection of a crime).

4. How we secure your information

We place great importance on the security of personal identifiable information associated with our patients. We have put controls in place to safeguard the personal information that you provide, applying physical, technical and procedural measures against the loss, misuse and alteration of personal information under our control.

All information submitted by you is encrypted in transit using best-practice Transport Layer Security (TLS) with at least 128-bit encryption. All clinical data is encrypted using the industry-standard AES-256 cipher and stored in Microsoft Azure, on secure servers in the UK, managed by ieso.

We have achieved the International Standard certification for information security (ISO 27001), Cyber Essentials Plus certification, and satisfy the requirements of the NHS Data Security and Protection Toolkit requirements.

Remember also that you are responsible for keeping your password secret at all times when accessing and using the Service.

5. How we store your information

ieso’s headquarters are in the United Kingdom (UK),and information about you submitted via the Services is used by us and hosted by our service provider, Microsoft Azure, on secure servers in the UK, managed by ieso. As detailed in the Security section of these Privacy Notices, such information is stored in an encrypted state, both in transit and at rest, meaning the provider cannot lawfully access identifiable information.

We use a small number of well-known SaaS (Software as a Service)providers to store subsets of your information and enable the uses of information described in these notices. We have Data Processor Agreements in place with each. Where possible these providers store the data in the UK or EEA. Where they are located outside the UK / EEA we ensure they are either party to an adequacy decision or have in place one of the additional safeguards necessary to make the transfer such as Binding Corporate Rules or Standard Contractual Clauses (with additional technological and organisational controls as necessary or appropriate) to uphold your legal data protection rights.

We retain your information and health record as a resource that you can return to for 20 years post discharge. This can help you remember coping strategies, techniques or processes that you learnt in therapy. If you were to experience a setback between sessions or after you’ve completed treatment, you may find it useful to refer to the transcripts/ audio recordings of your therapy sessions and messages. We retain your clinical record by reference to the NHSX Records Management Code of Practice https://www.nhsx.nhs.uk/media/documents/NHSX_Records_Management_CoP_V7.pdf  and to support our legal obligations to be accountable for your care.

The Code is based on current legal requirements and professional best practice.Research records and data are kept for a minimum of 20 years in accordance with Medical Research Council guidance.

Our data retention practices are reviewed at least annually in conjunction with industry standards and best practice.

6. Your access, rights and choices

You can access specific details relating to your treatment through the Service online at anytime directly through your account, these will therefore remain resources available to you after the conclusion of your treatment. These include messaging between you and your therapist between sessions, the sessions themselves, the ‘homework’ activities, questionnaires completed, and any goal setting activities. The sessions comprise a verbatim record of conversation between you and your therapist that are retained in the form of a transcript for text therapy or an audio file for video therapy. You can also update or amend some key registration and contact details directly through your account.

If you feel there is an error of fact on your health record held by us, you can contact us, or in respect of your wider medical record your referring healthcare service or GP. If we or they agree the information is incorrect, the alteration will be made. If we or they are not satisfied the information is factually incorrect, a note will be made of the information you consider is inaccurate, and you will be notified of either the correction or the note.

Data protection law also includes the right to data portability and to make other requests to seek to erase, object to and restrict personal data processing where certain limited grounds apply. Note however that data processed for health/treatment and legal purposes, or where other legitimate grounds for the processing apply, are examples of circumstances where some of these rights can be restricted or not apply in practice. Specifically, the right to erasure does not apply when processing is necessary for the provision of healthcare or the management of healthcare systems or service.

If you need assistance or have an enquiry about accessing, updating or amending your records, or where applicable, about receiving or transmitting a file of the data you have provided (for example to your GP) please write to:

The Data Protection Officer, ieso,Jeffreys Building, Cowley Road, Cambridge, CB4 0DS

Or by email, For the Attention of the Data Protection Officer (DPO), to info@iesohealth.com.

Our complaints procedure is available on the site, and there is a link to it here.If you remain unhappy with a response you receive, you can also refer the matter to the Information Commissioner's Office

7. Cookies and Tracking

We use cookies or similar technologies such as device IDs, pixel tags and web beacons (collectively described here as 'cookies') to collect information about the access to and use of the ieso site and Service. These typically include a unique reference code that relates to, or is accessed from, a user's device and that enables that device to be remembered when next visiting the site or using the Service and that sometimes track information about a user.We use cookies for the following reasons:

  • Secure login and navigation - we use necessary session cookies to help verify and authenticate your access to the Services and to let you smoothly navigate the Service and use its features.
  • Functionality - these cookies allow us to optimise the Service to you. For example, you can shut your browser but not be logged out, as long as an hour of inactivity does not pass, to enable you to complete questionnaires, ‘homework’ etc.
  • Analytics and performance - we use cookies to collect information about how you use the site and Service or engage with communications about the Service, and which enables us to improve the way each works. These cookies provide us with overall statistics about the number of unique interactions there are with the Site and Service and provides aggregate information on overall patterns of usage. We use a third-party provider, Google Analytics to collect and provide this information by reference to the cookie id and IP of your device and the log information about the use of the site or Service affiliated to that cookie id to measure these activity levels. This information is transmitted to and stored on the servers of Google. You can opt-out from the collection of this information by Google by downloading and installing a browser plug-in at https://tools.google.com/dlpage/gaoptout.

Computers and mobile devices may automatically accept cookies, but you can change your browser to prevent that or to notify you each time a cookie is set. You can also learn more about cookies by visiting www.allaboutcookies.org which includes additional useful information on cookies and how to block cookies using different types of browser. Please note however, that by blocking or deleting cookies you may not be able to take full advantage of the site or Service.

You can also learn more about our use of cookies by visiting our cookies policy.

8. Specific information relevant to Children and Young People

Our contract with your healthcare provider determines the lower age limit for our services. As standard it is 18, but specific contracts also include 16 and 17 year olds.

9. Your questions and how to contact us

If you have any questions or comments about these notices, please let us know:

By email: info@iesohealth.com (or for technical support questions contact our technical support team: support@iesohealth.com)

By telephone: on 0800 074 5560

Or by post to:ieso, Jeffreys Building, Cowley Road, Cambridge, CB4 0DS

To reach our data protection officer please use the above details and mark your communication for the attention of:  Helen SimpsonIn an emergency please contact:

  • Your GP surgery or local A&E
  • Your referring healthcare provider
  • Urgent Care (for out of hours access to GP):111
  • The Samaritans 116 123 or jo@samaritans.org
  • Emergency Services 999
10. Changes to your personal data

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

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In a health emergency
Call Samaritans on 116 123 if you need to talk to someone
Call 111 if you’re experiencing a mental health crisis
Call 999 or go to A&E if your life Is at immediate risk
Call 116 123 talk to someone
Call 111 mental health crisis
Call 999 life is at immediate risk