Our contact details.
Your Space Your Time Counselling Ltd
Leanne Bolesworth & Teresa Young
3, Albion Court
72, Attleborough Road
Nuneaton
CV11 4JJ
ICO Certification number – CSN4918611
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Purpose of policy
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To comply with the law
To follow good practice
To protect clients, staff, team members, students and other individuals from unlawful unauthorised access to personal data
To enable us to process personal information in the course of our legitimate business.
To protect individual’s fundamental rights and freedoms, notably privacy rights, in respect of personal data processing |
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Date this policy was completed |
June 2021 |
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Renewal Date |
June 2022 |
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Signed by
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Leanne Bolesworth Teresa young |
Responsibilities |
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Directors |
Teresa Young and Leanne Bolesworth |
Data Protection Officer/s |
Teresa Young and Leanne Bolesworth are the appointed data protection officers and have joint responsibility in their role as data protection officers. Their responsibilities include: · Briefing Team members, associate counsellor’s volunteers and members of staff on Data Protection responsibilities within the company · Reviewing Data Protection and related policies · Advise staff and volunteers on Data Protection issues · Ensuring that Data Protection induction and training takes place. · Notification to the ICO · Handling subject access requests · Approving unusual or controversial disclosures of personal data · Approving contracts with Data Processors
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Specific Department |
Leanne Bolesworth is responsible for all data relating to students, volunteer tutors and CPCAB counselling courses. Teresa Young Is responsible for all data relating to associate counsellors, volunteers and members of staff. Teresa Young and Leanne Bolesworth have joint responsibility when it comes to client data, outside organisations and contractors |
Employees & Volunteers |
All staff and volunteers are required to read, understand and accept any policies and procedures that relate to the personal data they may handle in the course of their work. |
Enforcement |
Your Space Your Time Counselling Ltd job descriptions, contracts and volunteer agreements make it clear that all team members are bound by the provisions of the Data Protection Policy and that acceptance of the contract/completion of the training signifies consent to processing data and maintaining data protection. Induction training will include in-depth training on our policies and procedure including data protection in line with our commitments to ethical and safe working practice |
We currently collect and process the following information:
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The type of personal information we collect.
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Clients · Your name Address Telephone number and email address · Client contract/consent · Who to contact in case of an emergency. · A brief outline of why you have contacted our service. · GP/mental health team contact details. · Details about any ongoing health concerns/conditions · Banking information (if you make payments via standing order or credit/debit card) · Brief counselling notes once |
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The type of personal information we collect.
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Associate Counsellors
· Copies of qualifications · Insurance certificates · DBS certification · Proof of membership to a governing body i.e., BACP · Banking details · Contact details, address, telephone number and email |
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The type of personal information we collect.
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Students · Copies of current certification · Banking details · Contact details including address, telephone number and email. · Assessments, assignments and forms containing identifiable information |
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The types of personal information we collect.
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Organisations · Banking details if contracting with us. · Contact details · Number of delegates including names and contact details, when renting training rooms · Special requirement (for example the use of downstairs rooms or special dietary requirements) |
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Our website |
Use of cookies · If you use our website, we will gather certain information about you. · Just like any commercial websites our website uses cookies. Information gathered through cookies may include the date and time of your visit, the pages viewed and your IP address. · Cookies are small text documents, which can include an anonymous unique identifier these cookies allow us to recognise and count the number of visitors and see how visitors move around the site. This information helps us to improve the way our website works. However, these cookies do not collect personal data about you. |
Special category data
When you contract with us, any personal information you share is likely to be classified as sensitive. We collect and process this sensitive and personal data only when required to do so by law and in order to be responsive to your needs and the smooth running of our service.
The professional management of confidentiality concerns the protection of identifiable and sensitive information from unauthorised disclosure.
- Disclosure may be authorised by client consent or the law.
- A disclosure of client confidence is undertaken in ways that best protect the clients trust and respect client autonomy.
- Communication made on the basis of client consent does not constitute a breach of confidentiality.
- Client consent is the ethically preferred way of resolving and dilemmas over confidentiality.
- Exceptional circumstances may prevent us from seeking client consent due to the urgency and seriousness of the situation, for example preventing the client causing serious harm to self or others.
- We are ethically accountable for any breach of confidentiality.
- We are accountable to our clients and our profession for our management of confidentiality in general and particularly for any disclosures made with client consent.
- In some situations, the law forbids us informing the client that confidential information has been passed to the authorities, nonetheless we remain ethically accountable to colleagues and the profession.
How we get the personal information and why we have it
Most of the personal information we process is provided to us directly by you for one of the following reasons:
To fulfil our contractual obligations to you
To ensure safe and ethical practice
We may also receive personal information indirectly, from the following sources in the following scenarios:
From referrals,
We might get contact information from your employer, Doctor, mental health nurse, or organisations for example previous employer. This information is used to contact you and arrange appointments and/or follow up on requests or job applications. All information is kept securely.
Information from the DBS Disclosure and Barring service
Under the General Data Protection Regulation (GDPR), the lawful bases we rely on for processing this information are:
- Your consent. You are able to remove your consent at any time. You can do this by talking directly to your counsellor or by contacting the company Directors.
- We have a contractual obligation.
- We have a legal obligation.
- We have a legitimate interest.
How we store your personal information
Your information is securely stored at Your Time Your Space Counselling Centre in locked filing cabinets in our secure filing room.
Client notes, assessments and contracts are kept in anonymised format using unique reference codes and kept separately from contact details.
Any electronic information including telephone numbers, text and emails are kept on password protected business phones and laptops. Company laptops are password protected and kept in our secure filing room when not in use.
Your Space Your Time Ltd employ a clear desk policy to mitigate data breaches and ensure safe and ethical working practice.
Data is held for 7yrs in line with our insurance requirements and GDPR.
When personal data is no longer to be retained it will be disposed of in such a way that the rights and privacy of the individual concerned are protected, e.g., disposal by shredding, burning, secure electronic deletion.
In the event of a data breach
In the unlikely event that your personal information is breached in any way, the Data Controller will inform the ICO within 72 hours after having become aware of the breach, unless the Data Controller is able to demonstrate, in accordance with the accountability principle, that the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons.
Your data protection rights.
Under data protection law, you have rights including:
Your right of access - You have the right to ask us for copies of your personal information.
Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.
Your right to object to processing - You have the the right to object to the processing of your personal information in certain circumstances.
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, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
How to complain
If you have any concerns about our use of your personal information, you can make a complaint to us at:
3, Albion Court,
72 Attleborough Road,
Nuneaton
CV11 4JJ
You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113