GDPR Policy

And Privacy Notice for Clients

Privacy Notice for Clients

 This Privacy Notice provides you with the necessary information regarding your rights and our obligations, and explains how, why and when we process your personal data.

 I am registered on the Information Commissioner's Office Register; registration number C1569567 and I act as the Data Controller when processing your data.

 Information That I Collect

In the course of my counselling services, I collect and use your personal information to give you support and improve my services.

 I only ask for the information I need. I always let you decide what you're comfortable telling me, explain why I need it and treat it as confidential.

 I handle and store your personal information in line with data protection laws, and store notes in a secure way.

 I will only ask for information that's relevant to your problem. Depending on what you require help with, this might include:

 Name and contact details so I can keep in touch with you

  • Date of Birth

  • Equalities Data - information like your gender, ethnicity or sexual orientation

  • Health/Medical information (where relevant)

  • Next of Kin (where relevant)

  • Children’s Details (where relevant)

  • Personal information - for example about family or work.

 If you don't want to give us certain information, you may not have to. For example, with equalities data I will always give the option to prefer not to say.

 How I Use Your Personal Data

I will always process your personal data in a way that is lawful and fair. I will not process the data in a way that is unduly detrimental, unexpected or misleading.

The legal basis for processing your personal data is detailed below: 

  • Legitimate Interest – I may collect information about you so I can counsel you more effectively

  • Legal Obligation – where processing is necessary for compliance with a legal obligation to which I am subject

     effectively

  • Legal Obligation – or where processing is necessary in order to protect the vital interests of the data subject or of another natural person

Where I rely on Legitimate Interest, I will ensure that I have weighed your interests and any risk posed to you against our own interests; ensuring that they are proportionate and appropriate.

Special Categories Data

I sometimes need to process sensitive personal information (known as special category data) about you.  Where possible, I will always ensure you have the option to decline sharing sensitive data.

 I will only ever process special category data where one or more of the following apply: -

  • Processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law

  • Processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent

  • Processing is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity

  • Processing is necessary for reasons of substantial public interest because we would not be able to provide our services without doing so

  • Processing is necessary for reasons of public interest in the area of public health

Sharing and Disclosing Your Personal Information

I do not share or disclose any of your personal information without your consent, other than for the purposes specified in this notice or where there is a legal requirement.  This could include situations where I have to use or share your information: 

  • To comply with the law – for example, a safeguarding issue or if a court orders us to share information. This is called ‘legal obligation’

  • To protect someone’s life – for example, sharing information with a paramedic if a client was unwell at my office. This is called ‘vital interests’

  • To defend my legal rights – for example, sharing information with my legal advisors if there was a complaint against me.

Your Rights

You have the right to access any personal information that I process about you and to request information about:

  • What personal data we hold about you

  • The purposes of the processing

  • The categories of personal data concerned

  • The recipients to whom the personal data has/will be disclosed

  • How long we intend to store your personal data for

  • If we did not collect the data directly from you, information about the source

Access:  You can request a copy or some or all of the information I hold about you.  I will aim to get all the required information to you within one calendar month, unless there are complicated circumstances, in which case, I will explain what they are within one month and provide you with an idea of what you can expect, up to a maximum of a further two months.  I will not charge for supplying you with this information.

Rectification:  If you believe that I hold any incomplete or inaccurate data about you, you have the right to ask me to correct and/or complete the information and I will strive to do so as quickly as possible, within one calendar month; unless there is a valid reason for not doing so, at which point you will be notified.

Erasure:  You have the right to request erasure of some or all of your personal data in accordance with the data protection laws. If I cannot fulfil this request, I will let you know the reason within one calendar month.  There may be reasons why I cannot erase your data.  This may be to ensure I comply with my legal obligations or my insurer’s requirements, or in case I need to review the work I did for you.

Portability:  Where applicable, you have the right to data portability of your information from one IT environment to another in a safe and secure way.

 

If I receive a request from you to exercise any of the above rights, I may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.

Security Measures

I take your privacy seriously and take every reasonable measure and precaution to protect and secure your personal data.

How Long I Keep Your Data

I only ever retain personal information for as long as is necessary and I have strict review and retention policies in place to meet these obligations.

I will normally keep all of the information for 7 years from when our work comes to an end.  This is to comply with my legal obligations and my insurer’s requirements, and in case I need to review the work we did together.  After that time it will be securely destroyed unless I have a legitimate reason to keep it.

Cookie Notice

A ‘cookie’ is a small piece of data sent from a website and stored on the user’s computer by the user’s web browser while the user is browsing. When you visit a site that uses cookies for the first time, a cookie is downloaded onto your computer/mobile device so that the next time you visit that site, your device will remember useful information such as items added in the shopping basket, visited pages or logging in options.

Cookies are widely used in order to make websites work, or to work more efficiently, and my site relies on cookies to optimise user experience and for features and services to function properly.

Most web browsers allow some control to restrict or block cookies through the browser settings, however if you disable cookies you may find this affects your ability to use certain parts of our website or services. For more information about cookies visit: https://www.aboutcookies.org.

Visitors to my website

When you visit our website at https://www.wendychurchill.com/, we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns.

Google Analytics will save a cookie to your computer’s hard drive in order to track and monitor your visit, but will not store, save or collect personal information. You can read Google’s privacy policy for further information.

I use this to track interest on specific pages, see how the site is being used and look at how I can make improvements to the site. The information is only processed in a way that does not identify anyone.

Lodging a Complaint

I only process your personal information in compliance with this Privacy Notice and in accordance with the relevant data protection laws.

If, however you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how I have handled your information, you have the right to complain to me about this.

If you are not satisfied with how your complaint has been dealt with, you have the right to lodge a complaint to the supervisory authority:  Information Commissioners Office https://ico.org.uk/

 

 

Document Control

Date of Last Review: October 2024

Date of Next Review: October 2026

Changes from previous versions:

No change