THE HAYS
COUNSELLING &
PSYCHOTHERAPY
PRIVACY POLICY
Thank you for trusting us with some information about you. We take that trust seriously and we want you to know how we use your information and why.
INTRODUCTION
This privacy notice gives you details of how I collect and process your personal data, including any information you may give me through visiting my website www.thehayscounselling.co.uk or when I take session notes or your purchase our services.
THE TYPE OF PERSONAL INFORMATION I COLLECT
I currently collect the following information:
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Personal identifiers, contacts and characteristics (for example your name, address, email address and your first name, last name, marital status, title, date of birth and gender.
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Notes made during an initial conversation with prospective clients, or during a client session.
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Transaction Data, which may include details about payments between us and other details of purchases made by you of my services or products.
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Technical Data, which may include your internet protocol (IP) addresses, internet browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this website. Please see my cookie policy for further details.
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Usage Data, which may include information about how you use my website, products and services.
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Marketing and Communications Data, which may include your preferences in receiving marketing communications from me
If you do not provide me with this data, I may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide me with the requested data, I may have to cancel a product or service you have ordered but if I do, I will notify you at the time.
HOW I GET THE PERSONAL INFORMATION AND WHY I HAVE IT
Most of the personal information I process is provided to me directly by you for one of the following reasons:
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You’ve contacted me (via email/ text/ voicemail/ FB Messenger/ WhatsApp/ Twitter/ LinkedIn) or you’ve visited my website – www.thehayscounselling.co.uk – to find out more about my services, prior to working with me.
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During our initial contact, you may share information about yourself or your situation.
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During a session (whether online or in-person) you may share information about yourself or your situation.
I will record such information as brief session notes so that I can provide you with an appropriate counselling service.
I also receive personal information indirectly, from the following sources and scenarios:
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Via another professional (cross referral). In this situation EITHER you would be given my contact details OR you would receive an introductory email.
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When you visit our website www.thehayscounselling.co.uk
I USE THE INFORMATION THAT YOU HAVE GIVEN ME IN ORDER TO:
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Respond to an initial enquiry about my services.
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Record session dates and times, including your address and/or email address, (for example, in my online calendar).
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Record additional information from client sessions as brief session notes.
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Manage any actions arising from our sessions.
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Manage tax/ accounting/ invoicing obligations.
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I may share this information with My sister and virtual assistant – access to my calendar is shared, so that another person is always aware of my exact location.
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Dropbox.
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Google Workspace.
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Google Analytics.
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Wix.org
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Professional advisors including IT, banking, auditor and accountancy service providers.
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As part of my ongoing supervision and professional development, I will share the contentof a session with my supervisors. I will always endeavour to keep names anonymous.
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To fulfil my professional, ethical and legal obligations to my professional body The British Association of Counselling Professionals www.bacp.co.uk
UNDER THE UK GENERAL DATA PROTECTION REGULATIONS (UK GDPR) THE LAWFUL BASEIS I RELY ON FOR PROCESSING THIS INFORMATION ARE:
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Your consent.
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I have a contractual obligation.
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I have a legitimate interest.
You are able to remove your consent at any time. You can do this by emailing me:
Nicole Hay
The Hays Counselling and Psychotherapy is registered with the ICO www.ico.org.uk
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DATA SECURITY
I have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, accessed in an unauthorised way, altered or disclosed. I 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.
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I have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator including the ICO of a breach where I am legally required to do so.
DATA RETENTION
I will only retain your personal data for as long as I need it, to fulfil the purposes I collected it for, including to satisfy any legal, accounting, or reporting requirements including my membership of the BACP.
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In deciding how long to keep personal data, I consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which I process your personal data and whether I can achieve those purposes through other means, and the applicable legal requirements.
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By law I have to keep basic information about my clients (including Contact, Identity, Financial and Transaction Data) for 7 years after we stop working together, for tax purposes.
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In some circumstances you can ask me to delete your data: see below (Section 10) for more information.
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In some circumstances I may anonymise your personal data (so that it can no longer be associated with you) for research, personal development or statistical purposes in which case I may use this information indefinitely without further notice to you.
YOUR DATA PROTECTION RIGHTS
Under data protection law, you have rights including:
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Your right of access – You have the right to ask me for copies of your personal information.
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Your right to rectification – You have the right to ask me to amend personal information you think is inaccurate. You also have the right to ask me to complete information you think is incomplete.
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Your right to erasure – You have the right to ask me to erase your personal information in certain circumstances.
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Your right to restriction of processing – You have the right to ask me to restrict the processing of your personal information in certain circumstances.
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Your right to object to processing – You have the right to object to the processing of your personal information in certain circumstances.
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Your right to data portability – You have the right to ask that I transfer the personal information you gave me to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, I have one month to respond to you.
Please contact me at info@thehayscounselling.co.uk if you wish to make a request.
COMPLAINTS
If you have any concerns about my use of your personal information or would like your information deleted, you can contact me at sarah@freeyourspace.co.uk
You can also complain to the ICO if you are unhappy with how I have used your data.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113