PRIVACY NOTICE

Introduction

This privacy notice describes how we process your personal data to deliver our services. These are our reasons for collecting it, what we do with it and what your rights are under the UK’s data protection laws.

Who we are

Face to Face Counselling is a registered charity (1141342) whose volunteer counsellors provide counselling support for individuals on low incomes resident in Greater Manchester.

Our registered address is Face to Face Counselling, c/o St Clement’s Church, St Clement’s Road, Chorlton, Manchester M21 9AE

We are the data controller for the processing described in this notice and are registered with the Information Commissioner’s Office – reference number ZB513445.

We have appointed the Co-ordinating Group members as volunteer Data Protection Officers who can be contacted at the above address, or via [email protected]

Purpose of processing personal data

We process your personal data to:

Ensure that individuals wishing to access Face to Face Counselling’s services can access therapy support, and to ensure that psychiatric or safeguarding risks (when disclosed) are safely and appropriately managed;

To be able to respond to your enquiries, and requests for support, whether by email, or via our telephone number;

To process donations;

To keep a record of your relationship with us;

To administer appropriate records where you are volunteering with us.

Unfortunately, if you do not provide this information, then we will not be able to process your donation, sign you up as a volunteer or provide the products/services you have requested. _

What Personal Data do we process?

For those contacting Face to Face Counselling for any of the following purposes: volunteering and placement enquiries/therapist applications/research requests, fundraiser and fundraising requests/ advertising and sponsorship enquiries/therapy support requests, we will collect all/some of the following information:

Name / name of company;

Gender;

Contact information including email address;

Date of birth;

Demographic information such as postcode, ethnic background, sexual orientation, religion, presenting support need / condition e.g., anxiety/depression/relationship issues/abuse issues etc.;

Details of fundraising activity/event;

Details of research project including contact details of researcher and (supervisor);

Whether you wish to participate in volunteering /placement opportunities

Where you heard about Face to Face Counselling

Details of amount paid /donation given;

Details of training undertaken including professional body membership, qualifications, DBS status, referee information (and contact details);

For therapy support requests only:

We collect information as follows: -

GP contact details, mental health history including details of medication taken and interventions undertaken including support from crisis services, suicidal ideation risk rating, treatment preference, details of visual, hearing or learning difficulties and other access and disability information;

We do not obtain data about you from any third party without your knowledge or written consent.

The above information is collected by Face to Face Counselling to ensure that the services provided are accessible and for monitoring, improving and evaluating our services together with enabling us to conduct research and/or fundraise. We collect all/some of the above information depending on the service that you wish to access and/or your reason for contacting us.

Special Category Data

Some types of personal data are more sensitive and require additional protections – these are known as Special Category Data and include details of your ethnicity, beliefs, health and sexuality.

If you are a beneficiary then it is highly likely that we will be processing special category data about you, particularly those which deal with your health.

If you share your personal experience of a mental health & wellbeing issue with us or any data about your health and wellbeing, we will treat this information with the upmost confidence and always in accordance with this notice. In the event you provide us with any special category data we will only use this information: For the purposes of dealing with your enquiry, providing a service, training, inclusion and quality monitoring or reviewing the services we provide.

We will never pass on your details to anyone else without your permission except in exceptional circumstances. Examples of this might include anyone reporting serious self-harm or when posing a threat to themselves or others.

The lawful basis for processing your data

We can only process your personal data where we have a lawful basis to do so, which varies according to the purpose of processing and the nature of your relationship with us.

Is my information being held securely?

All data is stored in the UK.

Sharing your personal data

Face to Face Counselling will never sell or rent your personal information to third parties and we promise to keep your details safe and secure. We will not share your personal information with third parties for marketing purposes.

Third Party Service Providers and Associates working on our behalf: We may pass your information to our third-party service providers, agents’ subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf (for example to process donations and send you mailings). However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the service and we have a contract in place that requires them to keep your information secure. Please be reassured that we will not release your information to third parties beyond the Face to Face Counselling service network for them to use for their own direct marketing purposes, unless you have requested us to do so, or we are required to do so by law or for reasons of safety, for example, by a court order or for the purposes of prevention of fraud or other crime, or to comply with our safeguarding, confidentiality and risk assessment policies and processes.

Face to Face Counselling will not divulge information unless there are exceptional circumstances that we become aware of and after due consideration there is overriding reason that we may need to make a disclosure to appropriate authorities (police, courts, GP, social services etc.). Face to Face Counselling would not usually need to contact your GP. However, as your welfare is of paramount importance, if issues of safety arise – for example, we believe or if you disclose that you are a risk to yourself or to others – we may need to contact your GP or relevant professional.

We may from time to time create statistical and aggregated data derived from your personal data to enable Face to Face Counselling to share aggregated outcome data for the purpose of evaluation, promotion, marketing and research of Face to Face Counselling therapy services or otherwise evaluate and try to improve our services. Any aggregated data will be in anonymous form and will not identify you as an individual in any way.

We use several third-party systems providers to deliver our services, some of which are cloud-based packages. When we are using such third-party systems, we ensure that we have a Data Processing Agreement (DPA) in place to protect your rights and comply with data protection laws.

How long do we keep your personal data for?

We aim to retain personal data for no longer than is necessary, which is a core principle of UK data protections legislation. Anonymised data which no longer relates to an identified or identifiable individual, and is therefore no longer personal data, may be retained for longer to assist us with identifying potential service improvements.

This section describes our data retention policy for different kinds of personal data and for the different purposes we have. We schedule data deletion activities on an annual basis in accordance with this schedule:

How we keep your personal data secure

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

The following key measures help keep us keep your personal data secure:

• Suitable encryption is used for data at rest and during transit

• We use multi-factor authentication where available

• We assess the security practices of our suppliers and partners

• We use encrypted email services where appropriate

• We restrict access to and/or password protect sensitive documents, where required

• We limit access to personal data to only those volunteers who need it

• All volunteers are required to adhere to the BACP Ethical Framework relating to human rights, data protection and confidentiality

• We provide data security training for our volunteers

• We ensure that any paper files are kept in locked cabinets

Links to other websites

Our website may, from time to time, contain links to enable you to visit other websites of interest easily. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy notice applicable to the website in question.

International transfers of personal data

We primarily process data in the UK: our website is hosted by Digital Ocean in their data centre in Frankfurt, Germany and our Microsoft Office 365 environment is hosted in the UK.

Your Rights

You have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.

• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

If you want us to establish the data’s accuracy.

Where our use of the data is unlawful, but you do not want us to erase it.

Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide you, or a third party you have chosen, with your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Please note, some of these rights only apply in certain circumstances and we may not be able to fulfil every request and there may be some circumstances where Face to Face Counselling Service is allowed to withhold information from you.

Please contact us using the details in “Who we are” to make any request in relation to your rights under data protection law.

If you have a complaint

If you would like to lodge a complaint with us regarding the processing of your personal data, then please contact us at: [email protected]

You also have the right to complain to the Information Commissioner’s Office (ICO). You can contact the ICO on their helpline 0303 123 1113 or online at www.ico.org.uk. If you should contact the ICO they will normally ask you to contact us first.

Review of this privacy notice

We keep this privacy notice under regular review. This privacy notice was last updated in July 2023.