PRIVACY POLICY – PA COUNSELLING & TRAINING (PACT) LTD
This privacy policy sets out how PACT Ltd uses and protects any personal information we collect about you.
Our commitment to protecting your information:
PACT Ltd is committed to ensuring that your privacy is protected and your data is secure under the General Data Protection Regulation (GDPR). Should we ask you to provide certain information by which you can be identified when using this website or supplying information by email, in writing or by phone then you can be assured that it will only be used in accordance with this privacy policy.
PACT may change this policy from time to time by updating this page. You should check this page periodically to ensure that you are happy with any changes. This policy is effective from 24 May 2018
If you have any questions or queries about this policy, don’t hesitate to get in touch with us:
PACT Ltd, 122 Hunter Avenue, Shenfield, Brentwood, Essex CM15 8PG
Tel: 01277 226121
Email: office@pact-resources.co.uk
COUNSELLING
The following applies specifically to the personal counselling practice of Pauline Andrew only.
What is personal data?
- Personal data is information that allows for the identification of a living person.
- All data relating to counselling clients is encrypted and encoded, and session notes are kept separate from client personal details.
- In the case of counselling clients this will include:
- Your name, address, telephone number and email. This is basic information that helps me keep in contact with you regarding our sessions.
- Confidential information relating to your counselling work, including session summaries and more detailed personal information including your date of birth and age. This is recorded and stored as a means of contacting you regarding your sessions.
- These details may also be used for emergency purposes where there is an evident risk of harm to yourself (see ‘Confidentiality’ below).
- GP and ‘In Case of Emergency’ contact details are recorded for safeguarding purposes where I may have cause for concern regarding your wellbeing and safety. Where possible I will seek to get your consent and inform you before contacting them.
- Session notes are kept anonymously for my own recollection and to monitor the work we are doing. You may see this at any time on request.
Confidentiality
- All information collected will not be shared with or sold to anyone else, with certain exceptions.
- Please note that a decision to breach confidentiality is not taken lightly and all due consideration to your privacy is taken into account.
- Confidentiality may be breached in the following circumstances:
- Where there is significant risk of harm to yourself, when information may need to be shared with a GP or other professional.
- Where there is information shared that suggests a child or vulnerable adult is being harmed or is at risk of harm. In this instance information may need to be shared with relevant services.
- If there is disclosure of terrorism or money laundering I am legally obliged under the terrorism and money laundering act to disclose this information to the police.
- If I am subpoenaed by court to share any information then I must do so upon request.
- I have a professional requirement to share my case work with a Supervisor who is a qualified counsellor and adheres to the same confidentiality and privacy requirements. All information shared is encoded to avoid identification.
- In the event of my death or terminal injury resulting in me being unable to carry out my work my husband, Dr Chris Andrew, who is a qualified psychotherapist who also adheres to the same confidentiality requirements, or my supervisor, will have access to all my clinical records in order to inform clients and end therapy, and destroy data as required.
- As a writer and trainer, I may request permission from you to quote elements of our work together on training courses or in published writings. In this case, if permission is given, your identity will be disguised, and key elements changed, to avoid recognition.
Data Storage and Disposal
- Data is collected on paper and electronically. Paper documents and files are kept in a locked filing cabinet and computer records are encoded and encrypted. Your contact number is stored on my phone using only your initials.
- The length of time I store data varies. Throughout the duration of therapy I will keep all records. Once therapy has terminated I will keep your session notes for a further 5 years in line with my insurance policy and legal obligations.
Your Rights
Under General Data Protection Regulations you have the following rights:
- The right to be informed about the collection and use of your personal information as described herein.
- The right to make a request for your data under a data subject access request, which should be in writing. I will request you to sign a disclosure consent form and you can expect to receive the information within 30 days of receipt of the request.
- The right to have inaccurate personal data rectified or completed if incomplete.
- The right to erasure; you have the right to opt out of data collection. If you wish to do so please make this request in writing, however some data cannot be erased and will need to be retained for lawful purposes and in line with my insurance policy.
- The right to Data portability. You have the right to obtain and reuse your personal data for your own purposes across different services.
- You have the right to object to any personal data being collected. This will need to be made known in advance or at the start of any therapy commencing. Please note if this is the case all therapeutic work will be terminated as I am required to keep appropriate records in line with my insurance and ethical bodies as well for legal and safeguarding matters.
PURCHASING RESOURCES
- Resources: We collect personal information about you when you make an enquiry or place an order via pact-resources.co.uk, by email, phone, in writing or face to face with us.
- Sometimes this processing is necessary because there is a legitimate interest to do so, for example, you make an enquiry with us and we process your details to respond to you.
- Processing is also necessary for the contract we have with you (or steps you asked us to take before entering into a contract).
- It enables us to keep a record of and process your order and to contact you if necessary with information about that order.
- If you place a resources order with us, we reasonably expect you may like to know about new products we may produce. Please see ‘marketing’ section below for details.
- Your website usage information is also collected using cookies (see cookies section below).
TRAINING
- Regional Training Groups: We collect personal information about you when you enquire about, or join, a group either via pact-resources.co.uk, by email, phone, in writing or face to face with us. Processing is necessary because we believe you would reasonably and legitimately expect us to use your details in this way, for example we will email you to keep you informed of group meetings and related issues.
Who will my personal information be shared with?
- Your personal information may be shared with third party organisations, but only for the purposes of the contract we have with you, or to deliver marketing communications from you that we think you may be interested in. This is currently limited to:
- the transfer of your information to marketing partners which organise the delivery of our e-communications and postal mailings (MailChimp and Send DM). We will not share or sell your details with other companies for marketing purposes.
- com for the dispatch of postal orders.
- IT support services (Anthian Computer Systems Ltd, Kit Eglinton and Jeremy Acott), in order to assist with the smooth running of our website and computer operations.
- Accounting services (Haines Watts) for the legal keeping and processing of our accounting records.
- Your payment information is also securely kept on PayPal’s online platform and bank transfers and cheques are recorded in our Lloyds Bank account statements and, where appropriate, bank and cheque books.
- The Deep Release Bursary Fund if you apply for assistance towards meeting costs for counselling or Regional Training Group fees.
Will I receive marketing communications from you and how will my data be handled?
- Occasionally we launch new products, or update existing ones, and if you have placed a resources order with us in the past two calendar years, we expect you may be interested in hearing about this via email or by post.
- We may include information about other PACT products in the envelope your order is sent in and also the training brochure of our sister company, Deep Release Ltd, as we believe this closely matches an area of interest for you.
- We will not sell or share your details with other companies for marketing purposes.
What if I don’t want to receive such communications?
- Please contact us and we will promptly delete your information from our mailing database as requested. You can do this by contacting us using any of the following details: office@pact-resources.co.uk, by phone: 01277 226121 or by post: PACT Ltd, 122 Hunter Avenue, Shenfield, Brentwood, Essex CM15 8PG.
- There is also a link to unsubscribe at the bottom of our marketing emails.
How long will you keep my information for?
- We will keep your information only for as long as it is relevant and useful for the purpose for which it was originally collected and in line with legal requirements to keep accounting records for 6 years from the end of the last company financial year.
- If you haven’t placed a resources order in two calendar years we will delete you from our marketing database.
What can I do if my information is incorrect?
- It is important to us that the personal information we hold about you is accurate and we will promptly correct any errors. Please contact us using any of the following details: office@pact-resources.co.uk, by phone: 01277 226121 or by post: Deep Release Ltd, 122 Hunter Avenue, Shenfield, Brentwood, Essex CM15 8PG.
Can I access my personal information?
- You are entitled to a copy of all or part of the information we hold on you. Please contact us using any of the following details and we will supply your information within one month: office@pact-resources.co.uk, by phone: 01277 226121 or by post: Deep Release Ltd, 122 Hunter Avenue, Shenfield, Brentwood, Essex CM15 8PG.
How is my information kept secure?
- We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
How we use cookies
- This site uses cookies – small text files that are placed on your machine to help the site provide a better user experience. In general, cookies are used to retain user preferences, store information for things like shopping carts, and provide anonymised tracking data to third party applications like Google Analytics. As a rule, cookies will make your browsing experience better. However, you may prefer to disable cookies on this site and on others. The most effective way to do this is to disable cookies in your browser. We suggest consulting the Help section of your browser or taking a look at the About Cookies website (https://www.aboutcookies.org/) which offers guidance for all modern browsers.
Links to other websites
- Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website.
- Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy policy.
- You should exercise caution and look at the privacy policy applicable to the website in question.
What can I do if I’m unhappy with how my data is being handled?
- Please in the first instance contact us: office@pact-resources.co.uk, by phone: 01277 226121 or by post: PACT Ltd, 122 Hunter Avenue, Shenfield, Brentwood, Essex CM15 8PG.
- You can also contact the Information Commissioner’s Office:
Tel: 0303 123 1113
Email: https://ico.org.uk/global/contact-us/
Information Commissioner’s Office
Wycliff House
Water Lane
Wilmslow
Cheshire SK9 5AF