CCS Privacy Notice

Your personal data – what is it?

Personal data includes, but is not limited to, your name, address, telephone number/s and e-mail address. It relates to a living individual who can be identified either directly or indirectly from that data. Identification can be by the information alone or in conjunction with any other information in the data processing. From 25^th May 2018, the processing of personal data is governed by the General Data Protection Regulation (the “GDPR”).

Who are we?

Communicare Counselling Service (CCS) is a registered charity, and under the terms of GDPR is the Data Controller.

How do we process your personal data?

CCS complies with its obligations under the GDPR by keeping personal data up to date; by storing information securely in paper systems, and by destroying it in a timely and secure manner; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure; and by ensuring that appropriate measures are in place to protect personal data.

We use your personal data for the following purposes:

To contact you regarding arrangements for your counselling;
To maintain CCS’s accounts and statistics;
To administer CCS’s records and, where necessary, to respond to situations involving safeguarding, dispute or complaint;
To comply with requests from those who are or have been clients with CCS for access to their personal records.

What is the legal basis for processing your personal data?

Explicit consent of the data subject so that CCS can contact you to arrange counselling for you.
Processing is necessary for carrying out ethical obligations in relation to the British Association for Counselling and Psychotherapy, and legal obligations such as responding to Subject Access Requests.

Sharing your personal data

The only personal information that will be kept by CCS is the name, address, e-mail, telephone number/s and GP surgery for those who are or have been clients with CCS. These are kept in hard copy in a locked cabinet on one secure site at CCS and are not kept electronically. CCS has a strict policy regarding confidentiality of such personal information and the only time that this confidentiality may be breached is if there is serious concern about self-harm or harm to others arising in the course of counselling, when limited but essential information regarding the nature of the risk may be shared outside CCS. This is in accordance with the Codes of Ethics and Practice of the British Association for Counselling and Psychotherapy, and this course of action would only be taken, whenever possible, after consultation with the client concerned.

How long do we keep your personal data?

Personal data will be kept for a maximum of seven years, as required by law, unless you withdraw consent. All processing of your personal data will cease if you withdraw consent, other than where this is required by law.

Your rights and your personal data

Unless subject to an exemption under GDPR, you have the following rights with respect to your personal data:

The right to request a copy of your personal data which CCS holds about you. The request should be made in writing and the information given to you within one month and free of charge.
The right to request that CCS corrects any personal data if it is found to be inaccurate or out of date.
The right to request your personal data is erased where it is no longer necessary for CCS to retain such data.
The right to withdraw your consent to CCS holding information about you at any time.
The right to request that the personal data held by CCS is transferred to another service (known as the right to data portability) and that this is carried out in a structured, commonly used and machine-readable form, and free of charge.
The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing.
The right to lodge a complaint with the Information Commissioner’s Office.

Further processing

If we wish to use your personal data for a new purpose, not covered by this Data Protection Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.

Withdrawing personal consent

You can change your consent preferences or withdraw your consent completely by contacting CCS at the address at the head of this notice. Please note that all processing of your personal data will cease once you have withdrawn consent, other than where this is required by law.

Contact details

To exercise all relevant rights, and for queries or complaints, please in the first instance contact: Communicare Counselling Service, Redford Way, Uxbridge, UB8 1SZ

Tel: 01895 256 056

Email: ccsenquiry@btinternet.com

You can also contact the Information Commissioner’s Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

Breach notification

The ICO must be informed of a data breach within 72 hours. If necessary, individuals whose data may be affected by the breach must be informed ‘without undue delay’.

Changes to this Privacy Notice

Please note this is a working document and we may occasionally update this Privacy Notice with new information.