Privacy Notice
Date: 1 January 2025
Who we are
Bammens CIC (“Headstrong Counselling”) provides a counselling service with therapy being delivered by trainee counsellors.
1. Purpose of this privacy notice
This privacy notice will inform you how Headstrong Counselling collects and processes your personal data through your use of this website and respective services, and how the law protects your privacy rights.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice 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 notice supplements other notices and is not intended to override them.
- 2. Data Controllers
For Headstrong Counselling clients:
- Bammens CIC (“Headstrong Counselling”), registered address Newport House, Newport Road, Stafford, Staffordshire, ST16 1DA, is the data controller
Email address: Dpo@headstrongcounselling.co.uk
- For clients receiving services from independent practitioners matched through Headstrong PRO platform: respective independent practitioners are thedata controllers.
- Bammens CIC (“Headstrong Counselling”), registered address Newport House, Newport Road, Stafford, Staffordshire, ST16 1DA, is joint data controller for the personal data related to the initial assessment of the client.
Email address: Dpo@headstrongcounselling.co.uk
- 3. Data Protection Officer (DPO)
Bammens CIC has appointed a data protection officer (DPO) who is responsible for overseeing all issues related to processing of personal data and to the exercise of rights provided to data subjects.
If you have any questions about this privacy notice, any other queries related to processing of your personal data, including any requests to exercise your legal rights, please contact the DPO using the following details:
HewardMills Ltd., 77 Farringdon Road, London, EC1M 3JU.
Email- address: headstrong@hewardmills.com
- Changes to the privacy notice and your responsibility to inform us of changes
We keep our privacy notice under regular review. This version was last updated on January 1, 2025
It is important that the personal data we hold about you are accurate and current. Please keep us informed if your personal data change during your relationship with us.
- 5. The Data We Collect About You and Its Source
|
Type |
Information Included |
Method of collection |
|
5.1. Website Usage |
Data related to your activities on our website, such as:
|
This is generally taken through: user-submitted data, cookies, log files, analytic tools, tracking pixels/tags, session replay tools. |
|
5.2. General Personal Data |
|
Data collected directly by us or through third-party platforms - for booking assessments and contacting you about your appointments via direct enquiry or form submission. |
|
5.3. Special Category Data |
|
We collect it from you directly during the booking and counselling sessions or Therapist/Counsellor documentation. |
|
5.4. Aggregated Data |
Statistical or demographic data. 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 notice. |
We collect this data through cookies, website analytics tools, and operational records. |
- 6. The Purposes of Data Processing and Legal Bases for Processing Your Data
We will process your personal data only in accordance with the applicable legal requirements and for the purposes we communicate to you in the table below or by other appropriate means.
We process your personal data based on one of the following legal grounds:
- Necessity to establish a contractual relationship with you and to perform our obligations under a contract (counselling and other related services)
- Provision of health care, social care or treatment on the basis of European Union, Member State or UK law or pursuant to contract with a health professional and when this data is processed under the responsibility of a professional subject to the obligation of professional secrecy
- Vital interests where life or safety is at risk.
- Legitimate interests provided that such interests do not have a negative impact on our clients’ fundamental rights and freedoms. Legitimate interests include the prevention and detection of fraud.
- Performance of legal obligation.
“To the extent that we process any special categories of Personal Data relating to you, such as health data, we will do so because either: (i) you have given us your explicit consent to carry out such processing; (ii) the processing is necessary for the establishment, exercise, or defense of legal claims; or (iii) you have made the data manifestly public. Where none of the above conditions apply, or where required by law, we will seek your explicit consent prior to processing your information.
The table below provides details on the purposes for which we use information about you, with corresponding legal basis for use:
|
Purpose |
Type of Data |
Legal Bases |
|
To manage your account, provide you with customer support, and ensure you are receiving quality service. |
5.1, 5.2, 5.3, 5.4 |
|
|
To contact you or provide you with information, alerts and suggestions that are related to the service. |
5.2 |
|
|
For billing-related purposes. |
5.2 |
|
|
To reach out to you, 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. |
5.2, 5.3 |
|
|
To match you with a Counsellor. |
5.2, 5.3 |
|
|
To enhance and validate our internal matching system. |
5.2, 5.3, 5.4 |
|
|
To enable and facilitate the Counsellor Services. |
5.2, 5.3, 5.4 |
|
|
To supervise, administer and monitor the service. |
5.2, 5.3, 5.4 |
|
|
To measure and improve the quality, the effectiveness and the delivery of our services. |
5.3, 5.3, 5.4 |
|
|
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations. |
5.2 |
|
|
To comply with applicable laws, including, but not limited to laws related to protecting client and public health and safety. |
5.2 |
|
|
To provide, support, personalize, and develop our Platform and Counsellor Services. |
5.1, 5.2, 5.4 |
|
|
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). |
5.1 |
|
|
To comply with a legal obligation. |
5.2
|
|
|
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. |
5.2 |
|
|
To inform the authorities if the service user is involved in, or has knowledge of, an act of terrorism. |
5.2 |
|
Failure 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.
Further processing for a purpose other than that for which your personal data were collected
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 at Dpo@headstrongcounselling.co.uk
If we need to use your personal data for a further purpose, we will notify you before such processing takes places and we will explain the legal basis which allows us to do so.
- 7. Cookies
7.1. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies.
7.2. Please see the separate cookies notice on https://headstrongcounselling.co.uk
- 8. Third-Party Links and Services
8.1. Our websites 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 notice of every website you visit, particularly before you submit any personal information.
8.2. Service providers: Other recipients of your Personal Data include our service providers who perform services on our behalf such as IT companies or service providers, cloud processors, cyber security companies and other service providers
These include
- When you opt to be matched with a counsellor via Headstrong PRO Platform, assessment data may be transferred to Bammens Ventures T/A Headstrong PRO (“Headstrong PRO”).
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. Client data transferred to the Headstrong PRO platform is stored securely.
For further information on cooperation between Headstrong Counselling and Headstrong PRO, please see terms and conditions: https://headstrongcounselling.co.uk/terms-of-service/
- All client information (including Assessment Bookings, Pre-Screening Questionnaires, Completed Assessments, Counselling Notes for each therapy and supervision session, any Risk and Safeguarding Issues, GP letters, Safeguarding Notes, Paid/Outstanding Invoices) are stored on Amazon Cloud, under their Privacy Policy
https://aws.amazon.com/privacy/?nc1=f_pr
- for scheduling assessments, we use a third-party platform that 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
https://www.squarespace.com/privacy
- to process payments for assessments, we use a provider that 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 Stripe’s privacy policy.
- Zoho Mail is used for all email communication. For more detailed information about please refer to their privacy policy.
https://www.zoho.com/privacy.html
8.3. Legal
- Personal Data may be disclosed to law enforcement agencies, regulatory bodies, public authorities or pursuant to the exercise of legal proceedings if we are legally required to do so, or if we believe, in good faith, that such disclosure is necessary to comply with a legal obligation or request, to enforce contractual terms, to prevent or resolve security or technical issues, or to protect the rights, property or safety of Company, our employees, a third party, or the public.
8.4. Transfer of data to third countries
- All data processed by vendors on behalf of Headstrong are either
i) Stored in UK
ii) When held in US, held under the UK-US data bridge certification, with vendors being informed on the special sensitivity of any data ; if applicable, Headstrong ensures that appropriate measures are in place to protect personal data.
- 9. Data security
9.1. We have implemented robust security measures to protect your personal data from being accidentally lost, improperly used or accessed, altered, or disclosed without authorization.
9.2. 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.
9.3. 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.
- 10. Data retention
In accordance with legal requirements, General Personal Data and Special Category Data will be retained for a period of seven (7) years following the termination of your contract or relationship with us.
Website Usage Data and Aggregated Data (which does not identify you directly) may be retained indefinitely, without further notice to you.
In certain circumstances, you have the right to request the deletion of your personal data. See your legal rights below for further information.
- 11. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
If you wish to exercise any of the rights set out below, please contact: Dpo@headstrongcounselling.co.uk
In cases when you opted for counselling services from a professional counsellor on the Headstrong PRO platform, you can also exercise your data subject rights by contacting this counsellor as a joint controller for your personal data.
11.1. Request access to personal data (commonly known as a data subject access request). This enables to receive a copy of the personal data we hold and to check that we are lawfully processing it.
11.2. Request erasure of personal data.This enables to ask 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.
11.3. Request 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.
11.4. Request correction of your personal data. 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.
11.5. Right to 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
11.6. Right to request restriction of processing your personal data when:
- you contest the accuracy of Personal Data, for a period enabling to verify the accuracy of the Personal Data in question;
- processing is unlawful and you oppose the erasure of the Personal Data and request the restriction of its use instead;
- the Personal Data are no longer needed for the purposes of the processing, but it is required by you for the establishment, exercise or defense of legal claims
- You have objected to processing pending the verification of whether the legitimate grounds of Headstrong Counselling override those of you (i.e. when Headstrong Counselling is relying on legitimate interests as the legal basis for processing Personal Data, which is the only instance where an individual can exercise their right to object to processing.
11.7. Right to withdraw consent at any time where we are relying on consent only to process personal data.
- However, this will not affect the lawfulness of any processing carried out before withdrawal of consent.
- If the individual withdraws consent, we may not be able to provide certain products or services. We will advise you if this is the case at the time of withdrawal of consent.
11.8. Right to Lodge a complaint with a supervisory authority.
- For UK, the individual has the right to make a complaint at any time to the Information Commissioners Office (ICO) and the UK supervisory authority for data protection issues (www.ico.org.uk)
11.9. Right against automated decision-making, including profiling
- Headstrong Counselling does not use personal data for any automated decision-making purposes.
11.10. Right to data portability
- In order for individuals to obtain their Personal Data for their own purposes and reuse it across different services, individuals have the right to receive their Personal Data in a structured, commonly used and machine-readable format, and also have the right to transmit those Personal Data to another organisation where the processing is carried out by automated means
11.11. 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.
11.12. 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.