PRIVACY STATEMENT
This privacy notice tells you what to expect us to do with your personal information:
Contact details
What information we collect, use, and why
Lawful bases and data protection rights
Where we get personal information from
How long do we keep information
Who we share information with
How to complain
Contact Details
Post: Phoenix Counselling, 129 Pottery Road, Oldbury, B68 9HE
Email: hello@phoenix-counselling.uk
Phone: 0121 647 9570
Who’s involved?
We operate using a referral system to self-employed therapists, meaning there’s a central administrative HQ and individual practitioners. Therefore, depending on why your personal data is collected, either Phoenix Counselling, the individual practitioner, and/or both may be responsible for how your data is used
Private Self-Referrals - Once allocated to a therapist, they take on responsibility for your data if you are.
Employment Assisted Programs - Both Phoenix Counselling and individual practitioners are responsible for your data.
We’re trying to be as transparent as possible. Please reach out to hello@phoenix-counselling.uk if you have any questions.
What information we collect, use, and why:
We collect or use the following information to allocate you to a therapist and/or supervisor:
Name, address and contact details, e.g. telephone and/or email
Gender
Date of birth
Reason for attendance
Day and Time Preference
Therapist preference
Additional information is required if you are part of an employment-assisted program or an insurance program. This includes:
Address and contact details, e.g., telephone and/or email
Pronoun preferences
Emergency contact details
Health information (including medical conditions, allergies, medical requirements and medical history)
Information about care needs (including disabilities, home conditions, medication, dietary requirements and general care provisions)
Insurance policy details
Records of meetings and decisions
Reports as requested by employers of employment-assisted programs.
Phoenix Counselling does not collect personal data for information updates, marketing, or market research.
Lawful bases and data protection rights
Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
The lawful basis we rely on may affect your data protection rights, which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:
Your right of access - You have the right to ask us for copies of your personal information. You can request other information, such as details about where we get personal information from and who we share personal information with. There are some exemptions, which means you may not receive all the information you ask for.
Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete.
Your right to erasure - You have the right to ask us to delete your personal information.
Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information.
Your right to object to processing - You have the right to object to the processing of your personal data.
Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you.
Your right to withdraw consent – When we use consent as our lawful basis, you have the right to withdraw your consent at any time.
If you make a request, we must respond to you without undue delay and in any event within one month. To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.
Our lawful bases for the collection and use of your
Our lawful bases for collecting or using personal information to allocate you to a therapist and/or client care:
Consent - we have permission from you, after we provided you with all the relevant information. All your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Legitimate interests - we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All your data protection rights may apply, except the right to portability.
Our legitimate interests include: providing counselling and psychotherapy (EAP Programs only) and/or allocating you to a therapist or supervisor.
Contract (EAP Programs only) – we collect or use the information so we can enter into or carry out a contract with you. All your data protection rights may apply except the right to object.
Where we get personal information from
Directly from you
Other health and care providers
Publicly available sources
From others in the profession who occasionally refer clients
Company - (EAP only)
How long we keep information
Private Clients - Once we have allocated you to a therapist, we will destroy all data provided, and your therapist will be responsible for your personal information and appointments. If the allocated therapist does not hear from you, your data will be destroyed after 4 weeks.
EAP Programs - This information is kept for 7 years. For more information on how long we store your personal information and the criteria we use to determine this, please contact us using the details provided above.
Who we share information with
We share personal information with:
Other health providers (e.g., GPs and consultants)
A member of our therapeutic team - e.g. allocation to a therapist
Employer (EAP), Insurance companies, brokers and other intermediaries
Charities and voluntary organisations
Organisations we need to share information with for safeguarding reasons
Other relevant third parties:
Information is shared with psychotherapy training institutes, if applicable.
Duty of confidentiality
We are subject to a common law duty of confidentiality, and require written consent for third-party disclosure. However, there are circumstances where we will share relevant health and care information. These are where:
You’ve provided us with your consent (we have taken it as implied to provide you with care, or you have given it explicitly for other uses)
We have a legal requirement (including court orders) to collect, share or use the data
On a case-by-case basis, the public interest to collect, share and use the data overrides the public interest served by protecting the duty of confidentiality (for example, sharing information with the police to support the detection or prevention of serious crime)
Reports - Employment-assisted reports are a requirement of the employer's program; these will include all appointment dates (including late cancellations and missed appointments). Should more detailed reports be required, consent for further information will be sought at your first appointment.
How to complain
If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice. If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
Website: https://www.ico.org.uk/make-a-complaint