Supporting Minds understands that your privacy is important to you and that you care about how your information is used and shared. We respect and value the privacy of everyone who visits Our Site/ uses our services and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.
Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site.
“Our Site” means this website, http://www.supportingminds.com;
“UK and EU Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015; and
What Cookies Do We Use and What For?
• All Cookies used by and on Our Site are used in accordance with current English and EU Cookie Law.
• Before Cookies are placed on your computer or device you will be shown a message bar at the bottom of your screen requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.
What is Personal Data?
Personal data is any information that can be used to identify a person either directly or indirectly. This includes names, addresses, contact details but also includes IP addresses, acronyms etc. Personal data should be:
• Processed lawfully, fairly and in a transparent manner
• Collected for only specified, explicit and legitimate purposes
• Accurate and where necessary, kept up to date
• Processed in a manner that ensures appropriate security of the personal data.
When you contact us you will be asked to provide some personal data. The information that we will ask for includes; name, phone number(s), email address, date of birth, address, GP details, counselling history, medication details, client availability, drug and alcohol history, previous diagnosis, support network.
Verbal consent will be given before we take any personal data, an agreement or ‘Privacy Notice’ will be given to all clients, staff, counsellors, students and volunteers, you will be informed of your rights regarding your data and if you consent you will be asked to sign the form. We only take information that is relevant and used for legitimate purposes.
The personal data we collect will never be sold or passed on to another organisation or person. We will not share your personal data unless:
• You are a risk to yourself or to others, as outlined in the BACP Ethical Framework for Good Practice in Counselling and Psychotherapy.
• There is evidence of child abuse.
• Any criminal involvement.
• A court has made a legal order (subpoena).
Counsellors have a legal and ethical obligation to have a supervisor. This is to ensure that they are counselling ethically and safely, and these supervision sessions are bound by confidentiality. All clients are anonymous and are referred to using either a first name or a client code
If you contact us via our website your details will be emailed to our firstname.lastname@example.org email address. After we have responded to you your personal details will be deleted, unless you have requested for us to keep them for future contact.
All emails are secure on password protected computers and all personal data is kept on a private secure server which is also password protected.
All personal data will be kept in folders which are in locked cabinets in an office that is locked when staff are not in the building. Client notes which are anonymised will be kept in a separate locked cabinet to the client’s personal data (contact details etc).
The only people that can access these locked cabinets are your counsellor, management and the administrator.
Students and counsellors contact details are kept in a file in a locked cabinet and phone numbers are kept in the office mobile which is password protected and only accessible by the Director, office manager and administrator.
You can request to have a copy of all the data we hold on you-including counselling notes. You must send this request in writing to Jenine Butroid the Company Director and Joanne Hadley the Counselling Services Manager. We will respond to this Subject access request within 30 days.
All clients and students are given a privacy notice and asked to sign if they agree, this privacy notice includes; What information we ask for, why we want your data, what we do with your data, who we share your data with, why we would share your data, and it explains that you can withdraw your consent for us to hold your data.
If there is a data breach that is likely to result in a risk to an individual’s ‘rights and freedoms’ supporting minds will report this breach to the ICO within 72 hours of discovering the breach.
Privacy Impact Assessment (PIA)
A Data Protection Impact assessment (DPIA) must be carried out at the start of any work which changes or introduces new technology, or processing that has a high risk to the privacy of individuals.
Supporting Minds will carry out a DPIA for any new projects which include processing personal data.
Data Protection Officer
All public authorities need to appoint a Data Protection Officer (DPO). The DPO for Supporting Minds is Jenine Butroid, The Company Director.
(Last updated January 2019)