This privacy notice sets out how HCCG CIC uses and protects any information that you give us when you visit this website or when you contact us by other means and the lawful basis under the Data Protection Act 1998 and the General Data Protection Regulations (‘GDPR’ to be enacted May 25th 2018) that permits us to do so.
Children and young people under the age of 16 must have the consent of their parent, guardian or carer in order to contact us via the website or by phone.
Consent to hold your personal data
HCCG CIC is committed to ensuring that we protect your privacy and will seek your explicit written consent to hold personal data about you, specifically and only for the purposes of providing counselling to you. We may also analyse data you provide us with for the purposes of providing the best possible service to you.
If you make contact via this website or by phone you will be asked to provide certain information by which you can be identified (see below).
You can be assured that all this information is held securely and will only be used in accordance with data protection principles, our data protection and confidentiality policies and our ethical principles (contained in the British Association for Counsellors and Psychotherapists Ethical Framework for the Counselling Professions: July 2016). We will honour the confidence and trust you have placed in us.
The basis on which we hold or share information about you is outlined below and also the limits around confidentiality.
You have the right of access to information we hold about you and to amend or ask for deletion of information that may not be accurate or correct. Please contact us if you wish to view the data we hold about you. HCCG CIC will not hold your data for longer than is deemed necessary for the purposes of counselling and following best practice and legal guidance. If you wish to know how long we hold data or notes for please contact us.
By visiting our website you are agreeing to the contents of this Privacy Notice.
For the purpose of the Data Protection Act 1998 and the GDPR, the data controller is Horsham & Crawley Counselling Group CIC, Alphacom House, 8a Oakhill Road, Horsham, West Sussex RH13 5SB. We are registered with the Information Commissioners Office on the Register of Fee Payers. You may also contact our Data Protection Officer via [email protected]
The types of personal data we collect and use
Whether or not you become a client of our counselling service we’ll use your personal data for the purposes of initiating counselling for you. We collect the majority of this information during first contact and assessment. We will advise you if any of this data is optional.
At first contact
We will collect the following information in order to establish if we can provide you with counselling:
- Your name
- Date of birth
- Contact information including your email address
- Geographic information from your postcode
- Other information relevant to you engaging in counselling with us, e.g. the name of your medical practice
- Information about any disability or communication difficulty you may have
- At first contact you may also choose whether or not to share with us a brief description of what is bringing you for counselling now
- Information about your income level to establish the cost of your assessment
- Information about your education or employment status
- At assessment you will be asked to sign our Informed consent form to give us permission to process your data and also information about your healthcare professionals and emergency contact details
- Further anonymised clinical information via Clinical Outcomes in Routine Evaluation (‘CORE’) you will have been given information about CORE beforehand and we will obtain your explicit written consent to do this
- Obtain your consent to participate in any research with any educational institutions we may be engaged with; you have the right to refuse to participate
- Information about your income level in order to determine what your counselling fees will be
- Anonymised counselling notes – your identity is protected and these notes are not shared with anyone unless we are legally required to do so or the client specifically requests we share them with another third party, which we have the right to refuse to do
- Personal data that identifies you and counselling notes are held separately and securely to protect your anonymity
- You have the right to view these notes and you would be advised of any request to share your notes
- These notes are the property of HCCG CIC and not the client
- Only your counsellor or in exceptional circumstances, i.e. in order to protect you or your counsellor, the Clinical Directors are authorised to access your notes
What we do with the information we gather
We collect this information to understand your clinical and other needs from counselling and provide you with a better service, and in particular for the following reasons:
- internal record keeping
- to assist with clinical assessment, allocation to an appropriate counsellor and for professional supervision of how we work
The lawful basis and purpose of holding this data is to ensure we can meet the terms for providing a contract for counselling with you. It is also to ensure good governance and for our own legitimate interests as a Community Interest Company to ensure we meet the requirements of our social mission.
We will also use your personal data to meet any legal obligations placed upon us – for instance when you exercise your rights to see what data we hold under data protection law or in order to meet any legal compliance placed on us; or occasions where we may be obliged to disclose information related to safeguarding children, young people and adults at risk.
Your written consent will be sought at assessment for the need to meet possible disclosure to other bodies and for when we process any special categories of sensitive personal data about you, such as gender, sexual orientation or biometric data, (when processed data is anonymised).
Where we store your personal data
The data that we collect from you is not transferred outside the European Economic Area (“EEA”).
HCCG CIC will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice and our data protection and confidentiality policies.
All information you provide to us is stored securely and information held on computer is held on our secure servers. Any payment transactions via your bank will only be identified by an anonymised client reference number and no other information will be required or shared.
Unfortunately, the transmission of information via the internet cannot be completely secure. We have in place security measures to protect your personal data, but we cannot guarantee the security of your data transmitted to our site, particularly by email; any transmission is at your own risk. Once we have received your information, we will use our own policies and procedures as far as is reasonably possible to prevent unauthorised access.
HCCG is committed to making sure your information is secure. We have in place appropriate policies and procedures to prevent unauthorised access or disclosure, There are suitable and appropriate physical, electronic and managerial procedures to safeguard and secure the information we collect online.
Links to other websites
Our website contains links to other websites that may be of interest. However, HCCG CIC has no control over other websites. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at their privacy statements
Controlling your personal information
We do not share your personal information with anyone else unless in pursuit of counselling on your behalf and only then if we have your permission to do so. In exceptional circumstances we may be required by law and our ethical responsibilities to break our confidentiality with you.
We would discuss this with you first wherever possible but if you do not give consent we may still have to disclose information. This relates to situations where you may be at risk of harm, causing harm to others, the safeguarding of children, young people and adults at risk, acts of terrorism and unreported road traffic accidents where we are under legal obligations.
Access to information
You have the right of access to the personal information which we hold about you under the Data Protection Act 1998 and the GDPR and also the right of access to your client notes. You can contact us or email us if you wish to examine what we hold and believe that any information we are holding on you is incorrect or incomplete. Steps will be taken to correct any incorrect information that we hold.
There is no charge to access this information and it will be provided to you within one week unless circumstances require longer, but this will not exceed a month in any event.
You have the right to complain to the Information Commissioners’ Office in connection with enforcement and compliance with data protection law at www.ico.org.uk
Questions, comments and requests regarding this privacy notice, policies and procedures around privacy and confidentiality are welcomed and should be addressed to us by email to [email protected] or by writing to us at our address.