When you trust us with your personal information, we take responsibility to protect this seriously. Phoenix Counselling respects your privacy and your rights to control your personal information and to keep you informed about how we use your information and why.
The main purpose of us collecting personal information is to provide a service of counselling and psychotherapy for clients and for business purposes for therapists. In both cases, we do not sell your information to third parties.
1. Who are we?
We are Phoenix Counselling. We are data controllers and are responsible for how information is gathered stored and used. We are registered with the Information Commissioners Office (ICO) under registration number ZB339240.
2. Our Site
If you provide your personal information when visiting our site, we keep it private and secure until we no longer need it. We have tried to make sure online forms are safe and secure; however it is not possible to guarantee that any email is secure, so if you email us, you do so at your own risk and you hold responsibility for the consequences of doing so.
We make sure that any personal information we hold:
Used and stored in line with appropriate privacy laws
We ask for awareness that no information sent over the internet is completely safe. However, we will always do our utmost to protect your personal information.
3. Information we collect
We may collect the following personal information about you:
Information you give us
We collect the information you voluntarily provide through our site, over the phone and by email. This includes information you provide when you contact our service through our site, apply/become to be a therapist within our team, or when you report a problem with our site. The information you give us may include your name, address, email address and phone number.
If you are a Counsellor or Therapist applying or have joined our team, you may also give us information about, for example, financial matters, qualifications, insurance and membership of professional bodies. You may also provide us with documents, a personal description of yourself and a photograph. If we take any payments from you, we will do this securely and in line with industry standards.
Special category data (sensitive information)
When you provide information through our site, you are in control of the type and amount of information you provide. You may choose to provide information that may be classed as ‘special category data’. For example, you may choose to give us information about your health to help us respond to your enquiry. Special category data includes information about your mental or physical health, your racial or ethnic background, your sex life or sexuality, your political opinions, trade union memberships, or your religious or philosophical beliefs.
By using the forms on our site to contact us, share a personal experience, or send us any other information, you agree to us processing your information (including any special category data you have provided) as is necessary for the service you've requested (for example, emailing a copy of your enquiry to the Counsellor or Therapist you have chosen or been allocated to).
We will not be responsible for the type of information you voluntarily provide through our site. However, to make sure that we keep to the General Data Protection Regulation (EU) 2016/679 (GDPR), we will ask you to tick a box on the appropriate form to confirm that we have your permission to process this information. We will only process the information if you have ticked the relevant box.
Please do not send us any information about criminal convictions, offences or similar measures (criminal offence data) using our online forms.
Information we collect automatically
Whenever you visit our site we may automatically collect the following information.
Technical information. For example, we may collect information about the type of device you use to visit our site, the internet protocol (IP) address used to connect your device to the internet, your log-in information, browser type and version, operating system and other technology on the devices you use to visit our site.
Information about your visit, including what you click on, pages you view or search for, page response times, download errors, length of visit to certain pages, methods used to browse away from the page and any phone number used to call the centre.
Analytics services track and report on the use of our website, including who uses it. They give us insights into how our customers use our service, which helps us to improve the services we offer. We may get information from analytics services (for example, Google Analytics and Facebook Pixel) to evaluate your use of our site, produce reports on things such as pages visited, time spent on pages, and clicks on our Facebook posts or links, and collect and evaluate other information relating to our site and use of the internet. The information we collect is anonymous.
We will ensure that all your personal information is stored and used lawfully, in an open, honest and fair way, without removing or reducing your rights. We will only process your personal information if any of the following applies.
You have given us permission to process your personal information for one or more specific purposes allocation to a therapist
We need to process the information to enter into a contract with you or meet our obligations under a contract we have with you.
We need to process the information to meet a legal requirement.
We need to process the information to protect the vital interests of you or another person.
Processing the information is in our legitimate interests or those of a third party who provides a service to us (for example, a company that processes card payments we take) unless these interests are outweighed by your basic rights. It is in our legitimate interests to process your personal information so that we can give you relevant information when appropriate so that we can look at ways of establishing and improving our relationship with you. Our legitimate interests include using your information to analyse and improve our services and the content on our websites and apps, send you information about our services, and tell you about similar products and services that you might be interested in.
If, while visiting our site or using our services, you provide personal information about another person, you should make sure they know about this privacy notice and that you have their permission to provide the information, under GDPR regulations we are unable to contact any potential client aged over 16 years of age without direct contact from them.
It may sometimes be appropriate for us to combine your personal information with other information we have about you, such as combining your name with the history of your relationship with us or where you live, work or visit.
If you fail to provide personal information
If you do not provide the personal information we ask for, you can still visit most areas of our site, but you may not be able to obtain services from our therapist or join our therapeutic team.
In some cases, we may need to collect some personal information by law or under a contract, and you will be limited in the services you can use if you don’t provide personal information. For example, if you do not provide your personal information you will not be able to be listed in our directory. We will let you know how this will affect you at the time.
5. What do we use your personal information for
We use your personal information to provide you with the services we offer. Below are some examples of how we may use your personal information.
Example 1: Contacting us to be booked with a therapist
If you use our site to be booked with a Counsellor or Therapist, we will pass your information on to them so that any appointments can be arranged. In so providing us with a mobile number or email address, we may also send you a confirmation message by text message or email. We will only store your personal information in our systems for up to 14 days. We will not use your personal information for any other purpose.
The server our site is stored on records the IP addresses of people who visit our web pages for a short time, so we can monitor the performance of our site, but we will usually delete this information as soon as we no longer need it. We may also store information about you, such as your IP address or website activity, to record certain actions (for example, when you contact us through our site, we use Google Analytics and Facebook Pixel to record that you’ve successfully completed this action). We use this information to monitor and manage our site (such as evaluating how effective our advertising is).
Example 2: if you apply to be or become a part of our therapy team
are applying to a therapist within our team
are already a therapist within our team
We will use your personal information to manage our service to you and to communicate with you (for example, telling you about your referrals, security, invoicing and other types of service updates). Also, if you contact us in any way, we may use your personal information to improve our service or to communicate with you.
Below is a summary of how we may use your personal information. Depending on the way you use our site, some of the following points may not apply.
To display the content on our site in the most effective way for you and your device.
To provide information, products and services that you ask for, or which we think you may be interested in.
To meet our obligations under any contract we have with you.
To allow you to use our interactive services.
To tell you about changes to our services.
To tell you about other goods and services that might interest you.
To manage our site and for internal purposes like troubleshooting, analysing data, testing systems, carrying out research, producing statistics and carrying out surveys.
To help us keep our site safe and secure.
To produce records we must keep by law (for example, we have to produce accounting records and keep them for at least six years).
To settle disputes.
To respond to feedback and comments.
If you have used our services before, we will only email you about the service you previously requested. If you are a new customer, we will only contact you if you agree to it.
We usually only need your permission to use your personal information if we are using it for marketing purposes. If you don’t want us to use your personal information for any particular purpose, let us know by emailing us. We will delete your information. However, this will limit our ability to provide the best possible service to you, and some parts of our service may not be available to you as a result.
As we have already explained, with your permission (or where we are allowed by law) we may use your personal information for marketing purposes. This may lead to us phoning or emailing you to give you information, news and offers on our services. We will not do anything not covered by this privacy notice, and we will not send you any spam emails. We will take all reasonable steps to make sure that we fully protect your rights and meet our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.
6. Where do we store your personal information
We will have controls in place, such as agreements containing appropriate clauses, to make sure that your information is protected to the same standard as if it were in the UK.
To protect your information we have put in place suitable physical, electronic and managerial procedures to protect information collected through our site. Only those employees, agents, contractors and other third parties who need your information for business purposes will have access to it. They will only process your personal information when we instruct them to, and they must keep the information confidential.
We have procedures in place to deal with any situation where we suspect that the conditions in this privacy notice have not been met, and will tell you and any appropriate regulator if we need to do so by law.
7. Providing your information to others
We can give your personal information to others in the following circumstances.
If we want to sell our company, any part of our business or any assets. In this case, we can give your information to the potential buyer.
If we want to buy any business or assets. In this case, we can give your personal information to the seller of the business or assets.
We can give your personal information to our therapists so they can arrange an appointment.
We can provide your personal information if we have to do so by law, or in order to protect other people's property, safety or rights.
We can share information with others to prevent fraud or credit risks.
We can provide your personal information in connection with legal proceedings.
Third parties or information publicly available
We contract suppliers to provide some services on our behalf. We use a variety of suppliers for services such as processing card payments, search engine facilities, email facilities, technical support, advertising and marketing. These suppliers may sometimes need access to some or all of your personal information.
We only share personal information the supplier needs to provide their services. If we need to share your personal information we will take all reasonable steps to make sure it is handled safely and securely, and always in line with the GDPR and relevant laws.
For questions about our suppliers, please email us at firstname.lastname@example.org
When you fill in an online form to contact for counselling or therapy, you need to give your personal information to the Counsellor or Therapist so they can provide the service you’ve asked for. We do not use your personal information for any other purpose, and we will always do our best to protect your information as set out in this privacy notice.
8. Keeping your personal information
We will keep your personal information for as long as we need to in order to:
provide services to you;
keep to any relevant laws;
settle disputes; and
allow us to carry on our business.
We are committed to maintaining confidentiality when you contact us for help. For this reason, when you contact us using the email form linked from our site, we will delete the information you typed into the form as soon as the form has been received by the Counsellor or Therapist.
This privacy notice and our internal guidelines will apply to all the personal information we keep. We will also keep anonymous information for statistical and analytical purposes (for example, to understand how people use our site and services). If you have a question about how long we keep certain types of personal information, email us at email@example.com.
9. Your rights
You can ask us not to use your information for marketing purposes. If you are listed as a therapist, you can do this by sending an email to firstname.lastname@example.org.
Under the GDPR, you have the right to control how your personal information is used and you can do the following.
Ask us for a free copy of the personal information we hold about you.
Ask us to correct any personal information that we hold about you or to make any changes to your personal information (for example, if your name or contact details have changed).
Ask us to transfer your personal information to another person.
Ask to be kept informed of what data processing is taking place.
In certain situations, ask us to restrict how your information is processed, or object to your personal information being processed.
certain situations, ask us to delete the personal information we hold about you.
Sometimes we will not be able to stop using your personal information when you ask us to (for example, if we need to use it by law or to keep to any regulation).
We will tell you if we cannot do what you ask, or how your request might affect you, when you contact us.
If you have given us permission to use your personal information, you can withdraw that permission at any time. If we process your personal information because it is in our legitimate interest or the public interest, you can object to this at any time.
You are responsible for making sure that your personal information is complete, accurate and up to date. If any of your personal information changes or is incorrect, tell us as soon as reasonably possible by sending us an email at email@example.com. We will correct the information as soon as possible, but certainly within 30 days.
10. Links to other sites
This privacy notice (and any documents referred to in it) does not apply to other websites that you get to by clicking on a link on our site. We have no control over how your personal information is collected, stored or used by other websites. You should check the privacy policies of other websites before you provide personal information through them.
11. Changes to this privacy notice
If we change this privacy notice we will post the changes on this web page. We may also email details to you.
12. How to contact us about this privacy notice
Our Data Compliance Manager is in charge of answering questions about this privacy notice and dealing with your requests to exercise your rights set out in clause 9. You can write to the Data Compliance Manager at Phoenix Counselling, 129 Pottery Road, Oldbury B68 9HE Or you can send an email to firstname.lastname@example.org. Our Data Compliance Manager may work with our Customer and HR Teams when dealing with you.
We are committed to working with you to settle any complaint or concern you may have about your personal information. If you have any concerns about how we are using (or have used) your personal information, first contact our Data Compliance Manager by emailing email@example.com or writing to:
Data Compliance Manager
129 Pottery Road
If you are not happy with the way we have dealt with your complaint or concern, you can contact the Information Commissioner's Office (ICO) in the following ways.
By visiting the website: https://ico.org.uk/global/contact-us/
By phone: 0303 123 1113
By textphone: 01625 545860