Headstrong Counselling respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
1.Important information and who we are
Purpose of this privacy policy
This privacy policy aims to give you information on how Headstrong Counselling collects and processes your personal data through your use of this website, including any data you may provide through this website when you book an assessment.
This website is not intended for children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
Controller
Bammens CIC trading as 'Headstrong Counselling' is the controller and responsible for your personal data (collectively referred to as “Headstrong Counselling”, “we”, “us” or “our” in this privacy policy).
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
contact details
If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:
DPO: Heward-Mills
Email address: DPO@headstrongcounselling.co.uk
You have the right to make a complaint at any time to the Information Commissioners Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last updated on May 21st, 2024.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-Party Links and Services
This website may include links to third-party websites, plug-ins, and applications. Clicking on these links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. We strongly encourage you to read the privacy policy of every website you visit, particularly before you submit any personal information.
Assessment Bookings
For scheduling assessments, we use a third-party platform called Acuity Scheduling. Acuity is GDPR and HIPAA compliant, ensuring that your data is handled securely. Please review Acuity’s privacy policy to understand what data may be collected and how it is used.
Payment Processing
To process payments for assessments, we use Square. Square is committed to protecting your privacy and does not sell your information to third-party vendors. For more detailed information about how your payment data is handled, please refer to Square’s privacy policy.
Counsellor Applications
For processing counsellor applications, we utilize a third-party platform called Neeto Form. Neeto is committed to protecting your privacy and adheres to stringent data protection standards. Neeto does not sell your information to third-party vendors. We encourage you to review Neeto Form's privacy policy to understand how your data is handled during the application process.
Transfer of Assessments to Headstrong PRO
When a client consents to be matched with a therapist via Headstrong PRO (company Bammens Ventures T/A Headstrong PRO), assessment data may be transferred to the Headstrong PRO platform. It is important to note that Headstrong PRO does not directly provide counselling services. Instead, it serves as an intermediary platform that connects clients with independent, qualified practitioners in the counselling and psychology profession. These practitioners are committed to providing low-cost, high-quality therapy services.Client data transferred to the Headstrong PRO platform is stored securely and is not shared with or transferred to the personal devices or storage of the therapists. All client data on the PRO platform is retained for a period of seven years to ensure compliance with legal and regulatory requirements.
2. The Data We Collect About You
General Website Usage Data
- We collect non-identifiable log data related to your activities on our website, such as pages visited, duration of visits, and other relevant statistics. This information helps us improve website functionality and user experience.
Assessment Booking Data
- Identifiable Information: For booking assessments and contacting you about your appointments, we collect personal data such as your name, phone number, email address, and physical address. This information may be collected directly by us or through third-party platforms like Square, which handles billing and payment processing.
- Sensitive Information: During the booking process, you may choose to provide additional details such as gender identity and racial identity to help us match you with a suitable therapist. This information is used solely for service enhancement and statistical analysis, is provided voluntarily, and you can withdraw your consent at any time. In the event of withdrawal, we will stop processing and delete this data. Otherwise, data is retained for 7 years in compliance with regulatory requirements.
- Health Information: Essential health information, including mental health history and general practitioner (GP) details, is collected for your safety and to ensure the effectiveness of our services. This information is vital for conducting assessments and cannot be omitted. Our terms and conditions outline circumstances under which this information might be shared with your GP.
Counsellor Applications
- For individuals applying to be counsellors, we collect necessary information to evaluate qualifications and suitability. This includes personal data which is kept for 7 years if the application is successful, and for 6 months if not.
Aggregated Data
- We collect, use, and share Aggregated Data, such as statistical or demographic data, for various purposes. This data does not reveal your identity directly or indirectly and is therefore not classified as personal data under the law. If Aggregated Data is combined with your personal data in a way that could identify you, it is treated as personal data and handled according to this privacy policy.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
4.How is your personal data collected?
We use different methods to collect data from and about you including through:
- direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by email or otherwise.
- apply for our products or services
- give us feedback or contact us.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- To manage your account, provide you with customer support, and ensure you are receiving quality service.
- To contact you or provide you with information, alerts and suggestions that are related to the service.
- For billing-related purposes.
- To reach out to you, either ourselves or using the appropriate authorities, if either we or a Counsellor have a good reason to believe that you or any other person may be in danger or may be either the cause or the victim of a criminal act.
- To match you with a Counsellor.
- To enhance and validate our internal matching system.
- To enable and facilitate the Counsellor Services.
- To supervise, administer and monitor the service.
- To measure and improve the quality, the effectiveness and the delivery of our services.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- To comply with applicable laws, including, but not limited to laws related to protecting client and public health and safety.
- To provide, support, personalize, and develop our Platform and Counsellor Services.
- To personalise your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Websites, third-party sites, and via email or text message (with your consent, where required by law).
- To comply with a legal obligation.
- To inform medical professionals if the service user is harming themselves or others or we see that there is a potential they will harm themselves or others.
- To inform the authorities if the service user is involved in, or has knowledge of, an act of terrorism.
5. Data security
We have implemented robust security measures to protect your personal data from being accidentally lost, improperly used or accessed, altered, or disclosed without authorization. Access to your personal data is strictly limited to personnel who need it to perform their job functions, such as assessors, the safeguarding team, the clinical team and your counsellor. These individuals are instructed to handle your personal data solely based on our directives and are bound by confidentiality obligations.
Furthermore, we have established procedures to address any suspected personal data breaches. Should a breach occur, we will promptly notify you and any relevant regulatory authorities, as required by law.
6. Data retention
How long will you use my personal data for?
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) seven years after they cease being customers. In some circumstances, we will keep your anonymise personal data (so that it can no longer be associated with you) for statistical purposes, in which case we may use this information indefinitely without further notice to you.
In some circumstances, you can ask us to delete your data: see your legal rights below for further information.
7.Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
- Request access to your personal data.
- Request erasure of your personal data.
- Request transfer of your personal data.
- Request correction of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Your legal 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 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
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, 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.
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.
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 particular 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 override 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.
- Withdraw consent at any time where we are relying on consent only 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.
Contact us: DPO@headstrongcounselling.co.uk