Privacy Policy
Version 3
Updated 24/06/2022 with below changes:
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Under "Introduction" I have removed my postal address.
Under "While you are accessing counselling" I have updated information on the storage of data.
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Updated 01/10/2021 with below changes:
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Under “Third party recipients of personal data” I have added details regarding my clinical will.
Website privacy policy
What type of information do you collect?
I receive, collect and store any information you enter on my website or provide me in any other way. In addition, I collect the Internet protocol (IP) address used to connect your computer to the Internet. I may use software tools to measure and collect session information, including page response times, length of visits to certain pages, page interaction information, and methods used to browse away from the page. I also collect personally identifiable information (including name, email); comments, feedback, product reviews, recommendations, and personal profile.
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How do you collect information?
When you contact me via my website, as part of the process, I collect personal information you give me such as your name, address, telephone number and email address. Your personal information will be used for the specific reasons stated above only.
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Why do you collect such personal information?
I collect such Non-personal and Personal Information for the following purposes:
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To provide and operate the Services;
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To provide Users with ongoing customer assistance and technical support;
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To be able to contact our Visitors and Users with general or personalized service-related notices and promotional messages;
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To create aggregated statistical data and other aggregated and/or inferred Non-personal Information, which I or my business partners may use to provide and improve our respective services;
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To comply with any applicable laws and regulations.
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How do you store, use, share and disclose your site visitors' personal information?
My website is hosted on the Wix.com platform. Wix.com provides me with the online platform that allows me to sell my products and services to you. Your data may be stored through Wix.com’s data storage, databases and the general Wix.com applications. They store your data on secure servers behind a firewall.
How do you communicate with your site visitors?
I will only contact you to in response to your enquiry or as otherwise necessary to enforce our User Agreement, applicable national laws, and any agreement I may have with you. For these purposes I may contact you via email, telephone and postal mail.
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How do you use cookies and other tracking tools?
I may use cookies and other website tracking if you give consent for me to do so. I will not use or share this information with third parties for any reason other than to gather information about site visitors for marketing purposes.
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How can your site visitors withdraw their consent?
If you don’t want me to process your data anymore, please contact me at info@liamcrouchercounselling.co.uk.
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Privacy policy updates
I reserve the right to modify this privacy policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the website. If I make material changes to this policy, I will notify you here that it has been updated, so that you are aware of what information I collect, how I use it, and under what circumstances, if any, I use and/or disclose it.
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Questions and your contact information
If you would like to: access, correct, amend or delete any personal information I have about you, you are invited to contact me at info@liamcrouchercounselling.co.uk.
Counselling privacy policy
Introduction
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Your privacy is very important to me and you can be confident that your personal information will be kept safe and secure and will only be used for the purpose it was given to me. I adhere to current data protection legislation, including the General Data Protection Regulation (EU/2016/679) (the GDPR) and the Data Protection Act 2018. This privacy notice tells you what I will do with your personal information from initial point of contact through to after your counselling has ended, including:
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What purpose I am processing your information for
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Whether you have to provide it to me
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How long I store it for
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Whether there are other recipients of your personal information
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Whether I intend to transfer it to another country
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Whether I do automated decision-making or profiling, and
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Your data protection rights.
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I am happy to answer any questions you have about my data protection policy and you can contact me via info@liamcrouchercounselling.co.uk. ‘Data controller’ is the term used to describe the person/ organisation that collects and stores and has responsibility for people’s personal data. The data controller for Liam Croucher Counselling is me, Liam Croucher. I am registered with the Information Commissioner’s Office with registration number ZB154861. My phone number is: 07745526570. My email address is: info@liamcrouchercounselling.co.uk.
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My lawful basis for holding and using your personal data
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The GDPR states that I must have a lawful basis for processing your personal data. My lawful basis for processing your data is that it is necessary for the performance of our contract.
The GDPR also makes sure that I look after any sensitive personal information that you may disclose to me appropriately. This type of information is called "special category personal information". The lawful basis for me processing any special categories of personal information is that it is necessary for the establishment, exercise or defence of legal claims.
The GDPR also ensures I look after any information related to criminal convictions, offences and related security measures. This type of information is known as “criminal offence data.” I am able to process this data as I am authorised by domestic law for the purposes of counselling etc and the safeguarding of children and of individuals at risk as defined by Schedule 1 of the Data Protection Act 2018.
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How I use your personal data
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Initial contact
When you contact me with an enquiry about counselling I will collect information to help me respond to your enquiry. This will include your name, address, email address & telephone number. Alternatively your GP or another health professional may send me your details when making a referral which may also include your address.
If I do not believe counselling with me is right for you I may refer you to another professional in which case I may share your details with them.
If you decide not to proceed with me I will ensure all your personal data is deleted within one month. If you would like me to delete this information sooner, just let me know.
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While you are accessing counselling
During your assessment I will collect additional information in order to satisfy my duty of care for clients and ensure counselling is right for you. This will include your date of birth, health information including current medication, GP details, reasons for seeking counselling, criminal convictions, support network, family situation and an overview of your life experience including relationships. In the course of our counselling relationship you may disclose other personal information to me. Rest assured that everything you share with me is confidential and will not be shared with any third party. The only exceptions to this are;
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if I feel there is risk of harm to yourself or others (this includes physical and sexual abuse and any serious criminal act),
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in discussion in supervision or
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if a court order to reveal information is served.
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I will always try to speak to you about this first, unless there are safeguarding issues that prevent this.
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I will keep a record of your personal details to help the counselling services run smoothly. All of your personal data is kept securely electronically and accessed using password protected devices that only I have access to. Any physical records are kept under lock and key.
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I will keep brief notes of each session. When stored electronically these are accessed using password protected devices that only I have access to. All physical notes are stored under lock and key. Notes are pseudonymised using a client reference number and stored separately from your personal data. For security reasons I do not retain text messages for more than one week. If there is relevant information contained in a text message I will save an electronic copy with notes from our sessions. Likewise, any email correspondence will be deleted after one month if it is not important. If necessary I will save an electronic copy with notes from our sessions.
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If I do not believe counselling with me is right for you I may refer you to another professional in which case I may share your details with them.
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After counselling has ended
Once counselling has ended your records will usually be kept for a minimum of 7 years from the end of our contact with each other and are then securely destroyed. I may store your data for longer than this to comply with insurance terms or to defend myself from legal action.
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Research purposes
As part of my continuing professional development I may invite you to take part in research I am conducting. If you consent to this, your data will be stored as above and will be securely destroyed immediately after the research is complete. Please note that should you wish to exercise your right to erasure or right to rectification, there may be limitations to this in terms of published anonymised research.
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Recordings
As part of my continuing professional development I may request to record our sessions. If you consent to this, the recordings will be stored as above and will be securely destroyed immediately after the purpose for recording has been satisfied.
Data security
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I take the security of the data I hold about you very seriously and as such I take every effort to make sure it is kept secure. Messages sent via my website are stored by Wix.com on secure servers behind a firewall. My email provider has higher than usual security measures meaning that my email content is encrypted and only accessible to me. Any printed data is stored under lock and key. All notes are accessed on password protected devices to which only I have access. These devices are never left unlocked in my absence.
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Third party recipients of personal data
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I sometimes share personal data with third parties, for example, where I have contracted with a supplier to carry out specific tasks. In such cases I have carefully selected which partners I work with. I take great care to ensure that I have a contract with the third party that states what they are allowed to do with the data I share with them. I ensure that they do not use your information in any way other than the task for which they have been contracted.
Third parties I currently share data with are as follows;
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Thomas Anthony Commercial Accountancy Services
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two executors of my clinical will
I share your name, phone number, email address and the usual time of our sessions with two trusted professionals acting as the executors of my clinical will who will contact you if I am incapacitated, unable to continue our work and unable to contact you myself. This data is held in digital format and password protected.
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Software I use that includes your personal data are as follows;
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Wix.com
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Microsoft 365
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Protonmail
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Sage
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Your rights
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I try to be as open as I can be in terms of giving people access to their personal information. You have a right to ask me to delete your personal information, to limit how I use your personal information, or to stop processing your personal information. You also have a right to ask for a copy of any information that I hold about you and to object to the use of your personal data in some circumstances. You can read more about your rights at www.ico.org.uk/your-data-matters. If I do hold information about you I will:
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give you a description of it and where it came from;
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tell you why I am holding it, tell you how long I will store your data and how I made this decision;
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tell you who it could be disclosed to;
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let you have a copy of the information in an intelligible form.
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You can also ask me at any time to correct any mistakes there may be in the personal information I hold about you. To make a request for any personal information I may hold about you, please put the request in writing addressing it to info@liamcrouchercounselling.co.uk. If you have any complaint about how I handle your personal data please do not hesitate to email me at the above address. I would welcome any suggestions for improving my data protection procedures. If you want to make a formal complaint about the way I have processed your personal information you can contact the ICO which is the statutory body that oversees data protection law in the UK. For more information go to www.ico.org.uk/make-a-complaint.