PRIVACY POLICY AND STATEMENT
1. Introduction
Bedfordshire Open Door offers free, confidential counselling to young people aged 13 – 25 years who live in Bedfordshire. We are a registered charity. We are accredited by the British Association of Counselling & Psychotherapy. To enable us to provide an appropriate counselling service, it is necessary to keep records of relevant personal information. Your privacy is very important to us and you can be confident that your personal information is kept safe and secure and will only be used for the purpose that it was given to us. We adhere to the current data protection legislation including the General Data Protection Regulation (EU/2016/679) (the GDPR), the Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
This privacy statement tells you what we will do with your personal information from initial point of contact through to after your counselling has ended, including
- Why we can process your information and what purpose we are processing it for
- If you have to provide it to us
- How long we store it for
- If there are other recipients of your personal information
- If we do automated decision making or profiling and
- Your data protection rights
“Data controller” is the term used to describe the person/organisation that collects and stores and has responsibility for people’s personal data. We are registered with the Information Commissioner’s Office as Bedfordshire Open Door Z1556945. In this instance the Data Controller is the Bedfordshire Open Door and the registered person is the Operations Manager.
A printed copy of this statement will be given to you when we first meet for counselling.
2. Our lawful basis for holding and using your personal information
The GDPR states that we must have a lawful basis for processing your personal data. There are different lawful bases depending on the stage at which we are processing your data. We have explained these below:
- If you have had counselling with us and it has now ended, we will use legitimate interest as our lawful basis for holding and using your personal information.
- If you are currently having therapy or if you are in contact with us to consider therapy, we will process your personal data where it is necessary for the performance of our contract.
The GDPR also makes sure that we look after any sensitive personal information that you may disclose to us appropriately. This type of information is called ‘special category personal information’. The lawful basis for us processing any special categories of personal information is consent initially. We will then retain any counselling records in case of the need to reference them in the future (the official legal basis is to defend against potential legal claims).
3. HOW WE USE YOUR INFORMATION
When you contact us with an enquiry about our counselling services we will collect information to help us satisfy your enquiry.
When you first contact us
- Name
- Age
- Date of Birth
- Address
- Mobile/landline phone number
- Email address
- School / College / Uni
- Occupation
- GP details
- Access requirements
- If you have used our service before
Alternatively, your GP or other health professional may send us your details when making a referral or a parent or trusted individual may give us your details when making an enquiry on your behalf. We will not register you for our service without your permission. If you do not register with our service, we will ensure all your personal data provided is deleted within 6 months. If you would like us to delete this information sooner, just let us know.
When you attend for a counselling assessment
We will ask for further information at the assessment appointment. So we can make sure everyone can access our service we have an equal opportunity form that asks questions about gender; religion; disability/additional needs; sexual identity and ethnicity. We always give our clients an option of “prefer not to say” when completing the equal opportunities data form. We use this information as part of anonymised reports about our whole service to demonstrate how our service is accessed by different groups of people.
While you are accessing counselling
Bedfordshire Open Door is committed to providing a professional service with a high degree of confidentiality. Whatever you say to your counsellor is confidential and will not be disclosed to anyone apart from those who provide the professional support, known as clinical supervision, required for all practising counsellors.
The only exceptions to this are if counselling records are ordered by a court of law or if you were to disclose any serious risk to yourself and/or to another person. This may include physical, sexual, psychological, emotional abuse and/or neglect, significant harmful behaviour that puts your or others safety at risk and includes actions of a criminal offence such as drug-trafficking, sexual exploitation of a child or vulnerable adult or money laundering offences and information about an act of terrorism.
Where we believe it is in your and/or others best interests to break confidentiality, we will always try to speak to you first and seek your consent wherever possible. Information will only be shared to people who absolutely need to know except for disclosures related to terrorism where we are required by law to report directly to the authorities.
Counsellors at Bedfordshire Open Door are required to keep brief factual notes. These are linked to you by a reference number and are stored separately from any of your personal information, such as your name, address, and contact details, so that your identity is protected. Personal information and counselling notes will be securely kept by Bedfordshire Open Door for 7 years post the age of 18 years old and are available to you on request.
General statistics are anonymously recorded. These statistics do not contain information from which you can be identified and are only used to monitor and improve the effectiveness of the service and for funding application purposes.
When we have finished working together
Bedfordshire Open Door will hold onto your information for up to seven years past the end of our working together or 7 years following your 18th birthday whichever is longer. This is so that we have a reference of our work in situations such as you returning to counselling in the future. After this date, Bedfordshire Open Door will shred all written documentation and delete electronic records.
- THIRD PARTY RECIPIENTS OF PERSONAL DATA
We sometimes share personal data with third parties, for example, where we have contracted with a professional supplier to carry out specific tasks. In such cases we have carefully selected which partners we work with. We take great care to ensure that we have a contract with the third party that states what they are allowed to do with the data we share with them. We ensure that they do not use your information in any way other than the task for which they have been contracted.
- Microsoft Office 365 – for emails and cloud services
- Survey Monkey – for sending out surveys
- MailChimp – for our newsletter
- Lamplight – for our database
- Visible Systems Limited – for our IT support
5. YOUR RIGHTS
We try to be as open as we can be in terms of giving people access to their personal information. You have a right to ask us to delete your personal information, to limit how we use your personal information, or to stop processing your personal information. You also have a right to ask for a copy of any information that we hold about you and to object to the use of your personal data in some circumstances. You can read more about your rights at Information Commissioner’s Office
If we do hold information about you we will:
- give you a description of it and where it came from
- tell you why we are holding it
- tell you how long I will store your data and how we made this decision;
- tell you who it could be disclosed to
- let you have a copy of the information in an intelligible form
You can also ask us at any time to correct any mistakes there may be in the personal information we hold about you. To make a request for any personal information we may hold about you, please put the request in writing addressing it to the Manager at counselling@bedfordopendoor.org.uk.
- DATA SECURITY
We take the security of the data we hold about you very seriously and as such we take every effort to make sure it is kept secure.
Paper Records
all written records are stored securely in locked filing cabinets in a locked office with restricted access. We keep a paper copy of any letters we send to you in the post. We keep your counselling notes separate from your contact details.
Bedfordshire Open Door Mobile Phone
Bedfordshire Open Door allocates a number to each of our clients to keep information confidential. Your mobile phone contact details are stored under your BOD number rather than your name.
If you contact us by email your email contact details will be stored in the Bedfordshire Open Door email account. We delete emails from this account when we no longer need them for reference, usually within one month. Emails we might need to refer to in the future are printed off and stored with the paper records.
Website
None of your personal information is stored on the Bedfordshire Open Door website.
Documents Held
Paper:
- Client Code (BOD number)
- Contact Sheet
- Contract/Agreement
- Assessment Record
- Brief Session Notes
- Confidentiality Agreement
- Case Study Consent Form (if agreed)
- Consent to Share Form (if agreed)
Electronic:
- Contact name & telephone
- Email/SMS
- VISITORS TO OUR WEBSITE
When someone visits our website, we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way that does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website.
We rely on legitimate interests as our lawful basis for processing this information when you visit our site. This helps us to understand how our website is being used and to improve the experience for users.
We use Google Analytics so that we can continually improve our service to you. You can read Google’s privacy policy here.
Our website is built using WordPress, a popular content management system. You can find out more about WordPress and data protection here.
Like most websites, we use cookies to help our site function more efficiently. For more details, please read our Cookie Policy.
- COMPLAINTS
We welcome any suggestions for improving our data protection procedures. We are happy to chat through any questions you might have about our data protection policy and you can use the email or phone number above to contact us.
If you have any complaint about how we handle your personal data please do not hesitate to get in touch with us by writing or emailing to the contact details given below.
Contact Details
- Our postal address is 120 Tavistock Street, Bedford MK40 2SA.
- Our phone number is 01234 360388.
- Our main office email is counselling@bedfordopendoor.org.uk.
If you want to make a formal complaint about the way we have processed your personal information you can contact the ICO which is the statutory body that oversees data protection law in the UK. For more information go to ico.org.uk/make-a-complaint
Should you wish to report a complaint or if you feel that Bedfordshire Open Door has not addressed your concern in a satisfactory manner, you may contact the Information Commissioners Office at the link below.
Further Information on General Data Protection Regulation (GDPR)
https://www.gov.uk/government/publications/guide-to-the-general-data-protection-regulation