Privacy Policy

This Data Protection & Privacy Policy specifies how Integrative Counselling Psychotherapist Henriette O’ Bryan trading as Somerset Counselling Therapy (hereinafter referred to as “SCT”, “us”, “our” or “we”) is committed to maintain standards of decency, fairness and integrity.

We recognise that your privacy is important. At SomersetCounsellingTherapy.co.uk we are dedicated to protecting your data and privacy. We collect, protect, store and dispose personal data of prospective and current clients - over age 18 only - in accord with SCT’s Insurer and the Information Commissioner’s Office (ICO). We follow data protection principles as per the Data Protection Act 1998 and General Data Protection Regulation (GDPR) effective 25 May 2018.

This policy is to aid clients’ understanding of the use of their personal data and sensitive personal data as well as their rights regarding their data. This policy also outlines the types of personal information we receive and collect when you use SomersetCounsellingTherapy.co.uk, as well as some of the steps we take to safeguard information. This will help you make informed decisions about consent, sharing personal data and/or becoming an online customer or offline client.

Data Collections via this Website

Info transmitted over the web is not 100% secure. Personal data is transmitted at your own risk but, once SCT is in control of your data we will adhere to privacy procedures to prevent unauthorised access. Also, our webmail and website communications between visitors’ browsers and https://www.SomersetCounsellingTherapy.co.uk/ are secure and encrypted. Hyper Text Transfer Protocol Secure (HTTPS) is the secure version of HTTP.

We collect the following personal data in electronic form:

Personal Identifiable Data Collected Online

SomersetCounsellingTherapy.co.uk may collect personally identifiable information from you in a variety of ways, including, but not limited to, when you visit our site, register on the site, or fill out a form, and in connection with other activities, services, features or resources we make available on our site.

We may collect and use your personal information to: run and operate and improve our site, display site content correctly, improve customer service by responding to your requests, enquiries or questions, providing support, personalise user experience, understand how our visitors - as a group - use services and resources provided on our webpages, improve our products and services or run a promotion, contest, survey or other site feature. Furthermore, your personal data can be used to send one-off emails about information requested by you about topics of interest or periodic emails, which may include electronic newsletters and/or autoresponder series of emails.

You can refuse to supply personally identifiable data and instead visit our site anonymously, but it may prevent you from engaging in certain site-related activities.

If we make material changes in the collection of personally identifiable information, we will inform you by placing a notice on our site. Personal information received from you will only be used for internal purposes. We will not sell it nor will we provide it to 3^rd Parties, subject to the Ethical or Legal Grounds for Sharing Personal Data and limitations of confidentiality relating to Counselling Clients who we have a contractual agreement with.

We will use personal information received from you for internal purposes only and will not sell it or provide it to third parties.

Ways we collect your personal data online

Web Contact Form - SCT collects enquirer’s name, phone, email and information relevant to the purpose of the form. We also collect each visitor's IP address, which is only used for the purpose to combat spam and fraud.

Emails from Third Parties - 3^rd Parties are not covered by our privacy policy. They provide SCT with referral's name, phone, email and/or enquiry details. 3^rd Parties include:

(1) Online Counselling Directories and Membership sites that forward enquiries &

(2) Agencies, Companies or Other Individuals who refer clients and/or take responsibility for payments.
Subscription Form for online Newsletter - SCT collects subscribers’ names and emails
Online Payments via “ecwid.com” Online Shop: if you purchase a product or service from us ecwid.com provides SCT with the purchaser’s name, email, phone and address. Clients can also pay in cash, cheque or do Bank Transfer. View ecwid.com's privacy policy here.

Non-identifiable Data in Electronic Form

We may collect non-personally identifiable information about you during interactions on our site. Non-personally identifiable information may include your browser name, type of computer and technical information about your connection method to our site, for example the operating system, Internet service provider used or other similar information.

Information is also collected via Cookies and Web beacons, but no personal identifiable data is provided to 3^rd Parties through their use. Cookies are identifiers or strings of information that are transferred to visitors’ computer hard drives through their web browsers to enable our system to recognise their browsers. Cookies personalise visitors’ experiences by recalling specific information eg telling visitors if they have returned to a specific webpage. Web beacons are transparent image files commonly used by sites that use 3^rd Party services to monitor traffic, visitors’ journeys around websites, visitors’ interactions on webpages or in products or ads to find out how many times visitors have seen an ad. Web beacons are often used in association with cookies to understand how visitors interact with the pages and content on the pages of a website.

About our Cookies & Web Beacons

Each time you return to SomersetCounsellingTherapy.co.uk your browser provides info to us via the means of Cookies which help us identify and track visitors, web visitors’ use of our website, and their website access preferences to personalise their experience. Through cookies and web beacons SomersetCounsellingTherapy.co.uk uses Google Analytics to analyse this website’s usage. Google Analytics gathers demographic, collects interest data and also generates statistical and other information about website use. These cookies are saved on your computer and we share the information with Google, who in turn stores and uses the information on their servers. Click here to visit Google's privacy policy. The information from Google Analytics is used by SomersetCounsellingTherapy.co.uk to track the number of visits to the website, browsers and operating systems. No personally identifiable data is collected from these cookies. We also use this information that are generated by Google Analytics relating to our website to produce reports that allow us to update and improve the usage of our site. If you are not happy for your data to be collected via Google Analytics, click here to install its opt-out browser extension or add-on.

About Affiliate Products

We receive affiliate commission for programmes and downloads sold via SomersetCounsellingTherapy.co.uk. Our site also links to social media sites or referral directories. By clicking on a product or service link, you consent to that website, service, social media or affiliate services platform's use of cookies, as outlined in their individual privacy policies in the links below:

Uncommon Knowledge/Hypnosis Downloads
ClickBank
Better Help (follow this link and look in FAQ)
Online-Therapy.com

About Social Media & Other Services

The following sites link out of our website and our privacy policy does not cover them. Should you wish for those sites not to collect your data, please visit their individual privacy policies.

Counselling Referral and Membership Sites
Counselling Directory
National Counselling Society

Online Counselling Sessions
Sylo

Social Media
Twitter
LinkedIn
For Facebook to not collect data whilst visiting this site, please log out of Facebook whilst being on here.

Refusing Cookies & Web Beacons

Browsers can be set to accept or reject cookies automatically, or notify you when cookies are being requested. Privacy software can override web beacons. Please refer to your browser’s Help section for guidance on refusing cookies or requesting to be notified when cookies are being requested.

If you choose to refuse SomersetCounsellingTherapy.co.uk's cookies, this should not cause any problem with the continued use of our site, but you may not be able to fully experience interactive features on the site.

Children's Privacy Protection

This website is directed to adults (over age of 18 only). It is not directed to children under the age of 18. Our site is operated in compliance with current regulations. Due to insurance purposes are offline clients must also be over the age of 18.

Visitors under the age of 16 must provide parental consent to use this site. We do not knowingly collect or use personally identifiable information from anyone under 16 years of age.

Online Release of Information

If we sell SomersetCounsellingTherapy.co.uk, any Non-personally Identifiable Information obtained by us from you through your voluntary participation in our site may be transferred to the new owner as a part of the sale so that the service provided to you may continue. In such an event, you will receive notice through our website of the change in control and practices, and we will make reasonable efforts to ensure that the purchaser honours any opt-out requests you might make.

Online Data Storage

Personally identifiable information and non-personally identifiable information collected by this site online is stored on our host's servers. That host is SiteSell Inc., located at 1000 Saint-Jean Boulevard, Suite 702, Pointe-Claire, QC H9R 5P1 Canada.

How You Can Correct or Remove Information

We provide this privacy policy as a statement to you of our commitment to protect your personally identifiable information. If you have submitted personally identifiable information through our website and would like to update that information or have it deleted from our records, click on this link (coming soon).

Personally Identifiable Data Collected - Offline

This section is relevant in order for prospective clients to make fully informed decisions before becoming an offline client. Prospective clients, current clients or clients being referred by their employer or another 3^rd Party may have the following personal data collected.

If you decide to become an offline Counselling, Reiki, Meditation or Tai Chi Client, the following personal data and sensitive personal data will be collected for customer service, health and safety as well as insurance purposes:

Data Collected Verbally eg via Phone - SCT colllects name, company name, phone number and email address.
Data Collected in Written Form in Sessions - Clients decide what to disclose. Data includes:

Personal data eg name, date of birth, phone, email, emergency contact, GP & Mental Health Professional details; and
Sensitive Personal Data eg, physical and mental health, social, religious/spiritual/philosophical beliefs, family history, cultural background, racial/ethnic origin, political opinions, trade union membership, gender, sex life or sexual orientation, genetic, biometric data.

What is personal data used for?

The purpose for which consent was given eg managing the service by responding to enquiries, book/cancel/reschedule sessions and provide mental health support. SCT also requests feedback and testimonials to ensure we provide an effective service. If testimonials are shown, only first initials are used eg Client E or Anonymous. Data will not be sold or passed to 3^rd Parties.

Ethical or Legal Grounds for Sharing Personal Data relating to Counselling Clients who SCT has a contractual agreement with

Confidentiality is fundamental to counselling. SCT does not share data with other Professionals, 3^rd Parties, Agencies, Companies or Other Individuals (family or significant others) who take payment responsibility. 3^rd Parties are only informed of session dates (attended, missed or cancelled).

One point of note is National Counselling Society requirement for counsellors to attend Supervision during which client work, “counsellor’s process” or interventions used, are discussed. Personally identifiable data is not disclosed during Supervision.

A second point of note is clients may give written consent to inform an organisation or individual, in which case SCT will oblige. In following exceptional circumstances SCT may breach confidentiality:

Risk of Serious Harm. Personal data may be shared with client’s GP or relevant authorities. This is to provide support if a client or someone else’s life is at risk of harm in order to prevent serious harm. Usually SCT will discuss this with the client first, although it is not always possible.
Compliance with Law to:

(1) report major crimes concerning money laundering, tax evasion, drug trafficking, terrorism, terrorism related activities a client might be involved in (or are aware of), concerns that a client is (or are at risk of) becoming radicalised;

(2) to report current child abuse or neglect; and

(3) comply with a court order.

How does SCT store Personal Data offline?

Paper files are kept in locked storage at our registered premises. Computer notes are encrypted and stored on a password protected computer. To ensure confidentiality Personal Data (identifiable data) are stored separate from Sensitive Personal Data disclosures, but linked with an anonymous code. This method is commonly used in the counselling profession.

Time Period Personal Data is Held by SCT & Disposal Method

Personal data - whether collected via text, email and web forms - is deleted once messages or requests have been acted upon. Pending requests awaiting input from prospective clients are kept for 3 months. Otherwise, all client related data is held secure for five years from the end date of therapy as per insurance requirement. After that period, SCT shreds paper evidence and erases electronic data using purpose-built commercial software; subject to any unresolved complaints or ongoing legal cases.

Your Rights about Your Personal Data Being Kept on Record by SCT

Right to be informed: SCT has an obligation to provide you with ‘fair processing information’ as described above to further transparency, integrity and trust.
Right of access: SCT has an obligation to provide you free access to your personal data and information on file within 30 days of request. Access to information can be requested by editing ICO’s Data Subject Access Request letter at https://ico.org.uk/media/for-the-public/documents/1253/how_to_make_a_request.doc. However, this letter is not compulsory; any written and signed request will be considered valid.
Right of rectification: you are entitled to have personal data updated/corrected eg an address. You also have a right to request that notes be edited if they do not reflect what happened during counselling.
Right to erasure: you are entitled to have your personal data erased, but it is not an absolute right to be forgotten. It can be erased if there is no convincing reason for its continued processing; subject to the counsellor’s insurance provider, outstanding complaints or ongoing court cases. SCT’s current insurer instructs that records be kept for 5 years from end of therapy date.
Right to restrict processing: you are entitled to restrict personal data processing eg, if a discharged client needs access to their records after 5 years (SCT’s insurer’s time requirement) to start, or defend a legal claim, SCT will oblige if notice was received prior to 5 year deadline.
Right to data portability: you are entitled to obtain and reuse your personal data for your own purposes across different services.
Right to object: you are entitled to change or withdraw previously given consent. Withdrawing consent to provide 3^rd Party organisations or individuals with specific details will not interrupt clients’ therapy. But, if prospective clients refuse to give or current clients withdraw consent re holding and processing of personal data, SCT would be unable to start or continue their therapy. Two important points of note - when withdrawing consent re holding and processing of personal data - are that SCT may still need to

1) use clients’ data, eg, to contact GP or emergency care provider to avoid serious risk of harm to the client or others; and

2) keep client data for 5 years as per insurance provider request. Consent withdrawal request are to be made in writing. SCT to acknowledge receipt of the request within 10 working days.

How to make a complaint?

Firstly please clarify the issue with your counsellor in person, by phone 07774 720 415 or via web contact. Other concerns about SCT’s handling of your data can be taken up with the ICO referring to Data Controller Registration Number: ZA281623. Issues about Henriette O’ Bryan (NCS15-02741) breaching Ethical Codes could be taken up with National Counselling Society (NCS), 19 Grafton Road, Worthing, West Sussex, BN11 1QT. Tel: 01903 200666.

Updates and Effective Date

SomersetCounsellingTherapy.co.uk reserves the right to make changes in this policy. Any material changes in our cookie and privacy practices will be indicated on our site and you will be provided with a link to the updated privacy policy. We encourage you to periodically review this policy so that you will know what information we collect and how we use it.

Agreeing to Terms

If you do not agree to SomersetCounsellingTherapy.co.uk's aforementioned terms and conditions as per our online privacy policy (as posted here on this website) or printed privacy policy (given to you in person for off-line personal data and personal sensitive data collections), please do not:

consent to the setting of cookies online
consent to collection and storage of your personally data online
sign any consent form
sign a contract form
make purchases
disclose any personal data.

Your explicit consent indicates acceptance of this privacy policy in its entirety.

Last updated: 25 May 2018

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