- At Andrea Harrn Counselling Services we are committed to safeguarding the privacy of our clients and website visitors.
- This policy explains how we will handle your personal data.
How We Collect Your Data
- We ask you to sign-up for our regular email communications and/or to download a variety of free or paid resources we provide on this website.
(1) How We Use Your Personal Data – Counselling
We are committed to protecting your personal data. The only data we collect from you is as submitted by you on the client form that you will sign at the appointment or sent by email if a Skype/online Client or via the newsletter sign up form on our websites www.andreaharrn.co.uk and www.themoodcards.com. This includes data for young people under 18 years old, with a parent consent. We will use your sensitive personal data (completed on the client form) for the purposes of providing our services to you or if we need to comply with a legal obligation. The data we collect via my 2 websites will be your first name, last name and email address, phone number how you found us and other optional fields (helpful for Training Workshops/events when we need to contact you for confirmation of attendance) and for products such as online courses or books. We will use your non-sensitive personal data to (i) register you as a new client, (ii) manage payment, (iii) collect and recover monies owed to us (iv) to manage our relationship with you, (v) send you details of services or useful information via our newsletter if you have ticked the box. The legal grounds for processing your data in relation to points (i) to (v) above are for performance of a contract with you. We will not share your details with third parties for marketing purposes except with your express consent.
Records held about you on the client forms:
- name address, doctors details, email, phone number
- Details about your health, past medical history, treatment, medications, outcomes
- Appointment details: phone, emails, correspondence
- Details about your treatment and care including brief sessional notes
I can disclose personal information if you give your consent or if required by law.
In addition to the above as an accredited BACP member I fully adhere to their codes of practice and ethical framework. To find out more please visit: https://www.bacp.co.uk/events-and-resources/ethics-and-standards/ethical-framework-for-the-counselling-professions/
Working with clients under 18 years of age
A parental consent will be required to work with under 18s. Information may be shared with parents as necessary for good treatment outcomes. All other data protection rules apply.
Disclosure of your personal data
- I may have to share your personal data with (i) service providers who provide IT and system administration support, (ii) professional advisors including lawyers, bankers, auditors and insurers (iii) HMRC and other regulatory authorities (iv) third parties to whom we sell, transfer or merge parts of our business or our assets and/or (v) to other professionals for the purposes of discussing your treatment such as outside referral agencies/EAPS/private health care providers or in supervision. I require all of these third parties to whom I transfer your data to respect the security of your personal data and to treat it in accordance with the law. They are only allowed to process your personal data on my instructions.
- Protecting your data is important to me and I have put in place security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. I also limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on my instructions and they are subject to a duty of confidentiality. In certain circumstances you can ask us to delete your data. See the section entitled “your rights” below for more information. I may anonymise your personal data (so that you can no longer be identified……
- I will only keep your personal data for as long as is necessary to fulfill the purposes for which we collected it. I may retain your data to satisfy any legal, accounting or reporting requirements. You have the right to ask me to delete personal data about you in certain circumstances. See Section 5 below.
- You are able to exercise certain rights in relation to your personal data that we process. These are set out in more detail at www.ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/ In relation to a Subject Access Right request, you may request that I inform you of the data I hold about you and how I process it. I will not charge a fee for responding to this request unless your request is clearly unfounded, repetitive or excessive in which case I may charge a reasonable fee or decline to respond. I will in most cases, reply within one month of the date of the request unless your request is complex or you have made a large number of requests in which case I will notify you of any delay and will in any event reply within 3 months. If you wish to make a Subject Access Request, please send the request to firstname.lastname@example.org.
Keeping your Data up to date
- I have a duty to keep your personal data up to date and accurate so from time to time, whilst you are a client, I will ask you to confirm your personal data is still accurate and up to date. If there are any changes to your personal data such as a change of address or doctors details please inform me.
C. (2) How We Use Your Personal Data
Usage Data for website
- We process data about your use of our website and services, this is described as ‘usage data’.
- The usage data may include: your IP address geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use.
- The source of the usage data is Google Analytics, the Facebook Pixel, the Twitter Pixel and Constant Contact Tracking Code.
- This usage data may be processed for the purposes of analysing the use of the website and services.
- The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
- We process the personal data you provide in the course of your use of our services. This is known as ‘service data’.
- The service data may include name, email address and phone number.
- The source of the service data is you.
- The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you.
- The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
- We process information contained in any enquiry you submit to us regarding products and/or services. This is known as ‘enquiry data’.
- The enquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services to you.
- The legal basis for this processing is consent.
- We process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters. This is known as ‘notification data’.
- The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters.
- The legal basis for this processing is consent.
- We process information contained in or relating to any communication that you send to us. This is known as ‘correspondence data’.
- The correspondence data may include the communication content and metadata associated with the communication.
- Our website will generate the metadata associated with communications made using the website contact forms.
- The correspondence data may be processed for the purposes of communicating with you and record-keeping.
- The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
- In addition to the specific purposes for which we may process your personal data set out in above, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
- Please do not supply any other person’s personal data to us, unless we prompt you to do so.
Providing Your Personal Data to Others
- We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.
- We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.
- In addition to the specific disclosures of personal data set out in this Section D, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
International Transfers of Your Personal Data
- In this Section E, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
- Constant Contact, is our email service provider. The European Commission has made an “adequacy decision” with respect to the data protection laws of each country. Transfers to other countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.
Retaining and Deleting Personal Data
- This Section F sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
- Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
- Notwithstanding the other provisions of this Section F, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
- We may update this policy from time to time by publishing a new version on our website.
- You should check this page occasionally to ensure you are happy with any changes to this policy.
- You may instruct us to provide you with any personal information we hold about you. The provision of such information will be subject to:
- The payment of a fee (currently fixed at GBP 10); and
- The supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).
- We may withhold personal information that you request to the extent permitted by law.
- You may instruct us at any time not to process your personal information for marketing purposes.
- In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.
- A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
- Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
- Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
Cookies That We Use
- Cookies used by our service providers:
- We use Google Analytics to analyse the use of our website.
- Google Analytics gathers information about website use by means of cookies.
- We use Constant Contact to manage our marketing email activities.
The Facebook Pixel
- We use the Facebook Pixel to manage our promotional activities.
- Facebook uses the Pixel to allows us to send data to Facebook about the actions that visitors take on our website.
- The Facebook terms for conversion tracking are available at: https://www.facebook.com/customaudiences/app/tos/?ref=u2u
The Twitter Pixel
- We use the Twitter Pixel to manage our promotional activities.
- Twitter uses the Pixel to allow us to send data to twitter about the actions visitors take on our website
- The Twitter Ads policy can be viewed here: https://business.twitter.com/en/help/ads-policies/introduction-to-twitter-ads/twitter-ads-policies.html
- Most browsers allow you to refuse to accept cookies and to delete cookies.
- The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
- https://support.google.com/chrome/answer/95647?hl=en (Chrome);
- https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
- http://www.opera.com/help/tutorials/security/cookies/ (Opera);
- https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
- https://support.apple.com/kb/PH21411 (Safari); and
- https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
- Blocking all cookies will have a negative impact upon the usability of many websites.
- If you block cookies, you will not be able to use all the features on our website.
- This website is owned and operated by Andrea Harrn Counselling Services, whose registered address is Clarendon House, 117 George Lane, London E18 1AN.
I am committed to protecting your personal data but if for some reason you are not happy with any aspect of how I collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk) I should be grateful if you could contact me first if you do have a complaint so that I can try and resolve for you.
You can contact us directly via out website contact form, via the telephone number published on our website or via email at email@example.com
This Privacy Notice may need to be altered from time to time.
Dated 16th May 2018