You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). It would, however, be appreciated if you could contact me with your concerns before you approach the ICO so please contact me in the first instance. It is important that the personal data held about you is accurate and current. Please keep me informed if your personal data changes during your relationship with me.
2. Who I am
2.1 Here are my details:
– My Website address is www.jennifersnowcounselling.co.uk
– And I trade under the name of Jennifer Snow Counselling.
– I act as my own Data Protection Officer and I can be contacted at email@example.com.
3. What information may be collected
3.1 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 (anonymous data).
3.2 I may collect, use, store and transfer different kinds of personal data about you which has been grouped together as follows:
- Identity Data includes first name, last name, username or similar identifier. When you email, phone, live chat or otherwise, I may collect information such as your first name, last name, email address and phone number.
- Contact Data includes your personal address, email address and telephone numbers.
- Financial Data includes any information collected during the processing of payments.
- Transaction Data includes details about payments and other details of Services with which you have been provided.
- 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 this Website.
- Usage Data includes information about how you use this Website and Services.
- Marketing and Communications Data includes your communication preferences.
- Cookies Data like many websites, “cookies” are used to enhance your experience and gather basic information about visitors and visits to our websites. Please refer to the “Do we use ‘cookies’?” section below for information about cookies.
- Third Parties and Information received from other sources. I may receive information about you if you use referral services, agencies or charities. In this case you will have been informed that data collected during your referral may be shared internally and combined with data collected on this Website.
3.4 We do not collect any 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). Nor do we collect any information about criminal convictions and offences.
3.5 Under UK GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following bases applies:
a) You have given consent to the processing of your personal data for one or more specific purposes;
b) processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
c) processing is necessary for compliance with a legal obligation to which we are subject;
d) processing is necessary to protect the vital interests of you or of another natural person;
e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
f) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party such as our financial payments, except where such interests are overridden by the fundamental rights and freedoms of the data subject, in particular where the data subject is a child.
4. How we may collect and use your data
4.1 I (or third party data processors, agents and sub-contractors acting on my behalf) may collect, store and use your personal information by way of different methods to collect data from and about you including through:
Direct interactions. You may give me your information by filling in forms via this Website or by corresponding with me by post, phone, email or otherwise. This includes personal data you provide when you use the Service offered by this website.
4.2 In addition to the above, we may use the information in the following ways:
a) Present Website content effectively to you.
b) Provide information, and services that you request, or (with your consent) which I think may interest you.
c) Carry out my contract with you.
d) Provide the relevant Services to you
e) Tell you my charges.
4.3 I will only contact you electronically while you remain my client.
4.4 If you are a new client, you will only be contacted if you agree to it.
4.5 Records may be held of those links which are used the most to provide the most helpful information but such information will be kept confidential and you will not be identified from this information.
4.6 In addition, if you don’t want your personal data used for any of the other reasons set out in this section, you can let me know at any time by emailing firstname.lastname@example.org and your data will be removed from my systems. However, you acknowledge this will limit my ability to provide the best possible services to you.
4.7 In some cases, the collection of personal data may be a statutory or contractual requirement, and I will be limited in the services In provide you if you don’t provide your personal data in these cases.
4.8 I will only use your personal data when the law allows us to. Most commonly, I will use your personal data in the following circumstances:
a) In order to perform the contract we are about to enter into or have entered into with you.
b) Where it is necessary for legitimate business interests (or those of a third party) and your interests and fundamental rights do not override those interests.
c) Where I need to comply with a legal or regulatory obligation, for example compliance with health and safety, tax or other statutory obligations.
4.9 Generally I do not rely on consent as a legal basis for processing your personal data.
5.1 All Cookies used by and on this website are used in accordance with current UK Cookie Law.
5.2 Cookies are used to distinguish users and improve our Website.
6. Where we store your data and security
6.2 Data security is of great importance to me, and to protect your data I have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through this Website. In addition, access to your personal data is limited to those third parties who have a business need to know. They will only process your personal data on my instructions and they are subject to a duty of confidentiality.
6.3 I 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 I am legally required to do so.
6.4 By giving me your personal data, you agree to this arrangement. I will do what I reasonably can to keep your data secure.
6.5 I have implemented security measures such as a firewall to protect any data and maintain a high level of security.
6.6 Notwithstanding the security measures that are taken, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting data via the internet and you take the risk that any sending of that data may not be secure despite the efforts taken.
6.7 If we give you a password upon registration on our Website, you must keep it confidential. Please don’t share it.
6.8 Personal data will be kept for as long as is necessary which is usually the life of our relationship and up to a period of seven years after our relationship have ended. I may however be required to retain personal data for a longer period of time to ensure I comply with our legislative and regulatory requirements. Data retention obligations are reviewed to ensure that data is not retained for longer than legally required.
7. Disclosing your information
7.1 I will not disclose your information except in the following circumstances:
7.1.1 Any legal requirement to disclose information to the police or under a UK Court Order
7.1.2 As required to by any referral service involved in your care
7.1.3 If we have a legal obligation to do so, or in order to protect other people’s property, safety or rights.
7.1.4 If a safeguarding issue becomes apparent during our relationship.
7.2 I will contract with a Clinical Trustee to supply services to you in the event that I become unable to continue working. The Clinical Trustee may require access to some or all of your data.
7.3 Where any of your data is required for such a purpose, I will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, my obligations, and the obligations of the third party under UK GDPR and the law. Any third party that I share data with will not be permitted to use it for any other purpose than fulfilling their contract.
8. Your rights
8.1 I aim to give you strong controls over my use of your data.
8.2 Under the UK GDPR, you have the right to:
- request access to, deletion of or correction of, your personal data held by me at no cost to you;
- request that your personal data be transferred to another person (data portability);
- be informed of what data processing is taking place;
- restrict processing;
- to object to processing of your personal data; and
- complain to a supervisory authority.
8.3 You have the right to ask me not to process your personal data for marketing purposes. I will usually inform you (before collecting your data) if I intend to use your data for such purposes or if I intend to disclose your information to any third party for such purposes.
9. Links to other sites
9.1 Please note that my terms and conditions and policies will not apply to other websites that you get to via a link from this Website. I have no control over how your data is collected, stored or used by other websites and advise you to check the privacy policies of any such websites before providing any data to them.
11. Terms and Conditions
12.1 Please also visit the Terms and Conditions page establishing the use, disclaimers, and limitations of liability governing the use of this Website.
12. Your agreement
13. Dispute Resolution