CHRISTIAN GUIDELINES: Privacy Policy

Your privacy is especially important to Christian Guidelines, and you can be confident that we will do everything we reasonably can to ensure your personal information will be kept safe and secure and will only be used for the purpose it was given.

We adhere to current data protection legislation, including the General Data Protection Regulation (EU/2016/679) (hereafter referred to as “GDPR”), the Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2003.

This privacy notice tells you what we will do with your personal information from initial point of contact through to after your therapy has ended, including:

• Why we process your information and what purpose we process it for

• Whether you have to provide it to us

• How long we store it for

• Whether there are other recipients of your personal information, and

• Your data protection rights.

We are happy to chat through any questions you might have about our data protection policy, and you can contact us via email. ‘Data controller’ is the term used to describe the person/organisation that has responsibility for people’s personal data. In this instance, the data controller is Christian Guidelines Ltd. We are registered with the Information Commissioner’s Office Z8939320. Our postal address is: 66 Newtownards Road, Bangor, Co Down, BT20 4DR. Our phone number is 028-91468846 and our email address is admin@cguidelines.org.uk.

LAWFUL BASIS FOR HOLDING AND USING YOUR PERSONAL INFORMATION

GDPR states that we must have a lawful basis for processing your personal data. There are different lawful basis’s depending on the stage at which we are processing your data. These are explained below:

o    If you have had therapy and it has now ended, we will use legitimate interest as the lawful basis for holding and using your personal information.

o    If you are currently having therapy or if you are in contact with us to consider therapy, we will process your personal data where it is necessary for the performance of our contract.

GDPR also makes sure that we look after any sensitive personal information that you may disclose appropriately. This type of information is called ‘special category personal information’. The lawful basis for us processing any special categories of personal information is that it is for provision of health treatment (in this case counselling) and necessary for a contract with a health professional (in this case, a contract between you and your Counsellor).

HOW WE USE YOUR INFORMATION

Data Security: We take the security of the data we hold about you very seriously and as such take every effort to ensure it is kept secure by using password-protected devices with anti-virus software, and lockable filing locations. Any digitally stored documents pertaining to you will be password protected.

Initial contact: When you contact us with an inquiry about our counselling services, we will collect information to help us satisfy your inquiry. This will include your name, address, telephone number and email address so we can arrange sending you an application form, to arrange your initial assessment appointment and can contact you if I need to amend or cancel your appointment due to unforeseen circumstances. If you do not wish to be contacted under any circumstances, you do not need to give a contact number or email address. If you decide not to proceed, we will ensure all your personal data is deleted within 3 months. If you would like us to delete this information sooner, please let us know.

Application form for counselling: We collect information on the application form to enable our Counselling Coordinator to allocate you to an appropriate and available counsellor. This includes date of birth, occupation, marital/parental status, church connection/leadership, description of problem, previous counselling, underlying problems, previous/current illness and/or medication, your expectations from counselling, days and times you may be available to attend. Please be aware that we will not routinely contact your GP to inform your GP of your attendance as your attendance is confidential. To fulfil our duty of care towards you while also maintaining your confidentiality we will only contact your GP if it is necessary and should these circumstances arise, we would discuss this with you wherever possible before contacting your GP.

While you are accessing counselling: If you consent, your email address or phone number will be used to provide you with written confirmation of your appointment times if necessary. With your consent, you may receive documents or links to information pertinent to the content of our sessions. If you are communicating with your counsellor via online sessions, your email address or phone number may also be used to send you links to enter the waiting room of online sessions.

We will keep a record of your personal details to help the counselling services run smoothly. These details are kept securely and are not shared with any third party unless under circumstances as described below.

We are affiliated with the British Association of Counselling & Psychotherapy (BACP) and Association of Christians in Counselling (ACC) and abide by their professional code of ethics. Confidentiality will only be suspended if there are legal or ethical obligations to disclose, for example, if you disclose abuse/neglect of a child or vulnerable adult or say something else that implies serious harm to yourself or others, or if a court of law requires us to disclose information. In the event that confidentiality must be suspended we will always try to speak to you about this first, unless there are safeguarding issues that prevent this.

Counsellors are required to have regular supervision support so your counsellor may discuss your work with their supervisor. This would be done without identifying you.  The supervisor also abides by the BACP/ACC’s code of ethics regarding confidentiality.

Your counsellor keeps brief notes of your sessions for the purpose of assisting your work together. The notes help keep track of the issues that you are working on, and they are for your counsellor’s use only. The notes do not include any personal details that could be used to identify you and they are stored securely in a locked location that only your counsellor is permitted access to.  Only in very exceptional circumstances e.g. incapacitation or death of your counsellor would another professional individual, designated by your counsellor, have permitted access. Administration staff are not permitted to open and view notes but may assist the counsellor in the correct storage of said notes.

After counselling has ended: Once counselling has ended your therapy session records will be kept for 3 years from the end of our contact with each other and are then securely destroyed. For security reasons we do not retain SMS/WhatsApp messages on the office mobile device after more than one month from therapy ending. If there is relevant information contained in a message the content is securely stored digitally for no more than 3 years after therapy has ended. Likewise with any email correspondence.

THIRD PARTY RECIPIENTS OF PERSONAL DATA

We share a limited amount of personal data with third parties to provide services to you. In such cases we have carefully selected which partners we work with e.g., Mailchimp to send out newsletters to those who have given consent, Cloud Storage provider (Microsoft Teams/SharePoint, iCloud), Software Providers (Microsoft, doxy.me, zoom). This list is not exhaustive, and providers may change but we take great care to ensure that the Third Party has a policy that states what they are allowed to do with the data we share with them. They should not use your information in any way other than the task for which they have been contracted.

YOUR RIGHTS

We try to be as open as we can be in terms of giving people access to their personal information. You have a right to ask us to delete your personal information, to limit how we 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 we hold about you and to object to the use of your personal data in some circumstances. You can read more about your rights at ico.org.uk/your-data-matters.

You can also ask us at any time to correct any mistakes there may be in the personal information we hold about you. To make a request for any personal information we may hold about you, please put the request in writing to the postal or email address above.

If you have any complaint about how we handle your personal data, please do not hesitate to contact us by writing or emailing to the contact details given above. We would welcome any suggestions for improving our data protection procedures.

If you want to make a formal complaint about the way we 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 ico.org.uk/make-a-complaint.

VISITORS TO OUR WEBSITE

When someone visits our website, we use a third-party service via squarespace.com to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way that does not identify anyone. We do not make, and do not allow squarespace.com to make, any attempt to find out the identities of those visiting our website.

We use legitimate interests as our lawful basis for holding and using your personal information in this way when you visit our website. You can read the squarespace.com privacy notice here https://www.squarespace.com/privacy .

No user-specific data is collected by us or any third party. If you fill in a form on our website, that data will be temporarily stored on the webhost before being sent to us.

By accessing the website, you are consenting to the information collection and use practices described in this privacy notice. Should you choose to contact us using the contact form on the website none of the data that you supply will be stored by the website or passed to any third-party data processors. Instead, the data will be collated into an email and sent to us over the Simple Mail Transfer Protocol (SMTP). SMTP servers are protected by TLS (sometimes known as SSL) meaning that the email content is encrypted before being sent across the internet. The email content is then decrypted by local computers and devices.

The website uses cookies and analytics. Almost all websites use cookies which are small files that get put on your computer by websites as you surf them. These cookies can store lots of information which can have privacy implications. Analytics is a service provided by Squarespace that gathers anonymous data on how people are using websites and then provides visitor statistics, details of page views etc. This service is used by many website owners as the data helps website owners to improve their websites.

Some page elements are embedded from trusted third parties to provide you with Interactive Maps. This makes the website more helpful to you as a site visitor however most of these come with their own cookies. This applies to Google Maps. We do not control these cookies so cannot guarantee what they do. In many cases the cookies are used to generate identical information to Google Analytics and indeed use Google Analytics, so opting out of Google Analytics will also opt you out of these cookies too. You can opt out of Google analytics and other Google services here – http://tools.google.com/dlpage/gaoptout and https://www.google.com/dashboard/.

CHANGES TO PRIVACY NOTICE

This privacy notice may be updated from time to time, so please check occasionally for any updates. {24 July 2023}