Headstrong counselling privacy policy

Headstrong Counselling respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

1.Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Headstrong Counselling collects and processes your personal data through your use of this website, including any data you may provide through this website when you book an assessment.

This website is not intended for children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data . This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

Bammens CIC trading as 'Headstrong Counselling' is the controller and responsible for your personal data (collectively referred to as “Headstrong Counselling”, “we”, “us” or “our” in this privacy policy).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

contact details

If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:

DPO: Anne-Sophie Bammens

Email address: enquiries@headstrongcounselling.co.uk

You have the right to make a complaint at any time to the Information Commissioners Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on July 21st, 2020.

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.

third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2.The data we collect about you

To let us operate the our virtual services effectively and to let you use our Counselling services, we may have to collect your personally identifiable information (such as, but not limited to, your name, phone number, email address, and address), billing and payment information, profile information, log data (information such as your computer Internet Protocol address ('IP'), pages that you visit and the amount of time spent on those pages, actions you take and other statistics), information related to the Counsellor Services or your need for Counsellor Services, and any information which is exchanged between you and your Counsellor (collectively, the 'Information').

In some cases, some of the Information that you give us is considered health related data. By deciding to provide the Information you agree to our methods of collections and use, as well to other terms and provisions of this Privacy Policy.

Protecting this Information is a top priority for us. We will never sell or rent any Information you shared in the Platform. Other than in the limited ways detailed in this Privacy Policy, we will never use or disclose any Information unless you specifically and explicitly requested or approved us to do so.

We will collect Personal Information data related to the Information you provide to the Counsellor during your assessment; this will be done in order to monitor client presentation and outcome and to best match you to a Counsellor. Once you have been allocated a counsellor, we will collect Pseudonymised Personal Data about you, as you will have been allocated a Client Identification Code.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do collect Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).

Your Personal Information may be transferred or disclosed to our sister service, Amira2 CIC Headstrong Hackney; this transfer will occur should you decide your needs are best suited to their service, to our third providers who assist us to provide the Services (such as website hosting, data analysis, information technology and related infrastructure provision, email delivery, auditing and other services ), and with whom we have a contract that includes appropriate privacy obligations.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3.How is your personal data collect

If you fail to provide personal data

4.How is your personal data collected?

We use different methods to collect data from and about you including through:

direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you
apply for our products or services
give us feedback or contact us.
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs, and other similar technologies.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

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

To manage your account, provide you with customer support, and ensure you are receiving quality service.
To contact you or provide you with information, alerts and suggestions that are related to the service.
For billing-related purposes.
To reach out to you, either ourselves or using the appropriate authorities, if either we or a Counsellor have a good reason to believe that you or any other person may be in danger or may be either the cause or the victim of a criminal act.
To match you with a Counsellor.
To enhance and validate our internal matching system.
To enable and facilitate the Counsellor Services.
To supervise, administer and monitor the service.
To measure and improve the quality, the effectiveness and the delivery of our services.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
To comply with applicable laws, including, but not limited to laws related to protecting client and public health and safety.
To provide, support, personalize, and develop our Platform and Counsellor Services.
To personalise your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Websites, third-party sites, and via email or text message (with your consent, where required by law).
To comply with a legal obligation.
To inform medical professionals if the service user is harming themselves or others or we see that there is a potential they will harm themselves or others.
To inform the authorities if the service user is involved in, or has knowledge of, an act of terrorism.

5.Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

6.Data retention

How long will you use my personal data for?

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) two years after they cease being customers. In some circumstances, we will keep your anonymise 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.

In some circumstances, you can ask us to delete your data: see your legal rights below for further information.

7.Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

Request access to your personal data.
Request erasure of your personal data.
Request transfer of your personal data.
Request correction of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Right to withdraw consent.

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

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Your legal rights

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 the personal data we hold about you and to check that we are lawfully processing it.

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), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. 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

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.

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.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where 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:

If you want us to establish the datas accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
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.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

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.