Privacy Policy Anchor – The Counselling Practice (“Anchor”) is committed to protecting and respecting the privacy of both our clients and suppliers. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it, so you feel confident providing us with the information when you use our services, or when you are communicating with us. WHO ARE WE? Anchor is a limited company incorporated in England and Wales and are “controllers” and responsible for your personal data, and are referred to as “we”, “us”, or “our” in this privacy policy. We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact our DPO using the details set out below. Contact Details: Our full details are: Full name of legal entity: Anchor – The Counselling Practice Name and title of DPO: Ms. J. McCouat, CEO. Email Address: [email protected] Postal Address: The Meadows Centre for Health, Chinchilla Drive, Hounslow, TW4 7NN Telephone Number: 020 8867 7660 You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data processing issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. For the purpose of the EU General Data Protection Regulation (Regulation (EU) 2016/679 (the “GDPR”), the data controllers are Anchor. INFORMATION WE MAY COLLECT FROM YOU Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and process different types of personal data about you which we have grouped together as follows: Identity Data includes first name, last name, title, date of birth, and gender. Contact Data includes billing address, delivery address, email address, telephone numbers, and website URL. Financial Data includes bank account and payment card details. Transaction Data includes details about payments to and from you and other details of services you have purchased from us. Technical Data includes internet protocol address, your login data, your browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our site. Profile Data includes your purchases made by you, your interests, preferences, feedback and survey responses. Usage Data includes information about how you use our services. We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership). Nor do we collect any information about criminal convictions and offences. However, we do collect information about your health in a confidential manner in order to provide our counselling services to you. Your data may also be available to our website provider to enable us and them to deliver their service to us, carry out analysis and research on demographics, interests and behavior of our users and supporters to help us gain a better understanding of them to enable us to improve our services. This may include connecting data we receive from you on the website to data available from other sources. Your personally identifiable data will only be used where it is necessary for the analysis required, and where your interests for privacy are not deemed to outweigh their legitimate interests in developing new services for us. In the case of this activity the following will apply: Your data will be made available to our website provider The data that may be available to them include any of the data we collect as described in this privacy policy. Our website provider will not transfer your data to any other third party, or transfer your data outside of the EEA. They will store your data for a maximum of 7 years. This processing does not affect your rights as detailed in this privacy policy If you fail to provide data Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with an appropriate counselling service). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time. HOW IS YOUR PERSONAL DATA COLLECTED? We use different methods to collect data from you and about you including through: Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data when you complete forms at our practice or via our website anchorcounselling.org (our “site”) and complete our hard copy forms, or by any other means. provide information at the time of registering to use our sites, subscribing to receive email or SMS alerts, or completing an online form on our site. you report a problem with our site. Apply for our services. Subscribe to our service or publications. Enter a promotion or survey; or Give us some feedback. Automated Technologies or interactions. As you interact with our site, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below: Data relating to patients health records from West London Mental Health Trust (WLMHT). Technical Data from the following parties:- Analytics and search providers such as Facebook based outside the EU; Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU. USES MADE OF THE INFORMATION YOU PROVIDE US We only use your personal data when the law allows us to. Most commonly, we use information held about you in the following ways: To ensure that content from our site is presented in the most effective manner for you and for your computer. To provide you with information or services that you request from us or which we feel may interest you, where you have consented or otherwise agreed to be contacted for such purposes e.g. through registering to receive a service with us, or as otherwise provided in this policy. If you choose to provide information to us regarding your interests and/or preferences we may send you content based on the information that you have provided to us. We may use the information provided by you to display information about services that we believe may be of interest to you. We do not share this information with any other third party. To carry out our obligations arising from any contracts entered into between you and us. To notify you about changes to our services. To supply other third parties with the required information (including credit card details) for the purposes of payment. Under no circumstances will we pass your details on to third parties for marketing purposes. If you register on our site, we may use your data to provide you with information about services supplied by us which may be of interest to you, and we may contact you about these by post, email or by SMS message. If you do not wish to receive communication from us you can opt-out of the communication at any time by emailing us at [insert email]. Change of Purpose We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is incompatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact the DPO. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. COOKIES We use cookies to improve your experience when you visit our website. A cookie is a small file of letters and numbers that we put on your computer if you agree. These cookies allow us to distinguish you from other users of our website, which helps us to provide you with a good experience when you browse our website and also allows us to improve our site. You can configure your browser not to accept cookies. Disabling cookies in your browser will not prevent you from accessing the site, however, it may limit your access for certain features. The information collected by cookies is non-personal and allows us to statistically monitor how people are using our website. DISCLOSURE OF YOUR INFORMATION We may have to share your personal data with third parties in the following circumstances: We may disclose your personal information to third parties or to our suppliers, or by law, where necessary. If we are under a duty to disclose or share your personal data in order to comply with any legal obligation. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction. We require all members of staff and any third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. INTERNATIONAL TRANSFERS The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for one of our suppliers. Such staff may be engaged in, among other things, the processing of your payment details and the provision of support services. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA. By submitting your personal data, you agree to this transfer, storing or processing. SECURITY Anchor ensures all reasonable and appropriate steps are taken to protect the security and integrity of the personal information you provide to us via our site, or by any other means electronic or otherwise. We will protect any personal information provided to us by you from being accidentally lost, used or accessed in unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, consultants, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. The security measures we undertake include electronic firewall and other protection procedures involving virus scanning, security patches, vulnerability testing, backup and recovery planning, employee training, security audits and other steps designed to secure your data. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping your password confidential. We will never ask you to disclose your password and we ask you not to share your password with any third party. We cannot be responsible for any loss or damage caused by your negligence, misuse of log-in details or your decision to share account access with others. THIRD PARTY WEBSITES Our site may, from time to time, contain links to and from other websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites. LENGTH OF STORAGE We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. By law, we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. YOUR RIGHTS Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to: Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. Request correction of the personal data we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right and freedoms. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. No fee usually required You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. What we need from you We may need to request specific information from you to help us to confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. Time limit to respond We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. CHANGES TO OUR PRIVACY POLICY Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. This privacy policy replaces all privacy policies or statements. This Privacy Policy was last updated in May 2018. CONTACT Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to the DPO at [email protected].