Privacy and Confidentiality Policies
Definitions and interpretation
collectively all information that you submit to HJT Counselling via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;
Data Protection Laws
any applicable law relating to the processing of personal Data, including but not limited to the Directive 96/46/EC (Data Protection Directive) or the GDPR, and any national implementing laws, regulations and secondary legislation, for as long as the GDPR is effective in the UK;
the General Data Protection Regulation (EU) 2016/679;
HJT Counselling, or us
User or you
any third party that accesses the Website and is not either (i) employed by HJT Counselling and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to HJT Counselling and accessing the Website in connection with the provision of such services; and
the website that you are currently using, www.hjtcounselling.co.uk, and any sub-domains of this site unless expressly excluded by their own terms and conditions.
a. the singular includes the plural and vice versa;
c. a reference to a person includes firms, companies, government entities, trusts and partnerships;
d. “including” is understood to mean “including without limitation”;
e. reference to any statutory provision includes any modification or amendment of it;
3. For purposes of the applicable Data Protection Laws, HJT Counselling is the “data controller”. This means that HJT Counselling determines the purposes for which, and the manner in which, your Data is processed.
4. We may collect the following Data, which includes personal Data, from you:
b. contact Information such as email addresses and telephone numbers;
c. details provided by you via email, phone or contact forms;
How we collect Data
5. We collect Data in the following ways:
a. data is given to us by you.
Data that is given to us by you
6. HJT Counselling will collect your Data in a number of ways, for example:
a. when you contact us through the Website, by telephone, e-mail or through any other means;
b. website contact form;
Our use of Data
7. Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:
a. to respond to an enquiry made by you;
b. internal record keeping for the purpose of client contact;
8. We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed “Your rights” below).
Keeping Data secure
9. We will use technical and organisational measures to safeguard your Data, for example:
a. we store your Data on secure servers and filing systems.
10. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: email@example.com.
11. If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
13. Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.
14. You have the following rights in relation to your Data:
a. Right to access – the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive.” Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
b. Right to correct – the right to have your Data rectified if it is inaccurate or incomplete.
c. Right to erase – the right to request that we delete or remove your Data from our systems.
d. Right to restrict our use of your Data – the right to “block” us from using your Data or limit the way in which we can use it.
e. Right to data portability – the right to request that we move, copy or transfer your Data.
f. Right to object – the right to object to our use of your Data including where we use it for our legitimate interests.
15. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: firstname.lastname@example.org.
16. If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found on their website at https://ico.org.uk/.
17. It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.
Links to other websites
Changes of business ownership and control
20. We may also disclose Data to a prospective purchaser of our business or any part of it.
21. In the above instances, we will take steps with the aim of ensuring your privacy is protected.
24. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
25. This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.
In order to fulfil contracts with clients, information provided to HJT Counselling will be recorded from the following sources and held securely. Clients will be informed that confidentiality may need to be broken in an emergency situation if the client is at risk towards themselves or others. All information is stored in an anonymised secure filing system for no longer than 12 months following the contract end date.
Sources of information
1. Questionnaires- anonymised basic questionnaires may be completed at the beginning of client contracts to assess clients and track progress.
2. Emergency contact forms- to record basic contact details for GPs and clients in the case of an emergency.
3. Note taking- following the initial consultation and ongoing sessions, notes will be recorded for the purpose of providing an effective service. Notes will be anonymised and limited to relevant and necessary details only. As part of BACP membership, monthly supervision is required and as such, verbal reference to client cases may be made, with client identity limited to first name only.
4. Written consent- in the case of GP or third party request for client information or if the client requests said parties to be provided with their information, written client consent must be provided to Hannah Pullar first.