This is the privacy notice of Breakthrough Counselling and was last updated on 24rd May 2018. Breakthrough Counselling is the trading name of Khurshid Ali (Sole trader). Khurshid Ali is an accredited Therapist working in Central Manchester and Chorlton.
- This is a notice to inform you of our policy about all information that we record about you. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.
- We regret that if there are one or more points below with which you are not happy, your only recourse is to leave our website immediately and not engage our services.
- We take seriously the protection of your privacy and confidentiality. We understand that all visitors to our website are entitled to know that their personal data will not be used for any purpose unintended by them, and will not accidentally fall into the hands of a third party.
- We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.
- Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).
- The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. We do this now, by requesting that you read the information provided at www.knowyourprivacyrights.org
- Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.
The bases on which we process information about you
The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.
If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.
If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.
Information we process which is special category data
Special category data is personal data which the GDPR says is more sensitive, and so needs more protection. For example, information you may provide to me during our counselling sessions may include personal details about your…
- ethnic origin
- sex life or
- sexual orientation
I collect this data to understand your medical history and the background conditions which may have contributed to a decline in well being. This is in order to provide counselling or hypnotherapy service. It will only be used by me to provide a service.
This data will allow me to provide you with appropriate tailored counselling sessions which are culturally sensitive. We feel holding detailed records securely is in your best interest.
To gather this data we are relying on the following as our lawful basis:
- the purposes of our legitimate interests (article 6)
- the data subject has given explicit consent to the processing of those personal data for one or more specified purposes (article 9)
How I will handle your data
Your personal data will be kept secured on encrypted laptop. Paper notes secured in a file until entered into the laptop. I will store the notes for 6 years and then destroy them unless there is a legitimate reason to process them for longer. Disposal of data includes data on laptops being deleted and paper based notes being shredded.
Information we process because we have a contractual obligation with you
When you decide to engage in our counselling services a contract is formed between you and me. In order to carry out my obligations under that contract we must process the information you give us. Some of this information may be personal information.
We may use it in order to:
- contact you for appointment scheduling
- provide you with our services
- verify you have paid for services received
- refer you to appropriate additional or substitute counselling services where this is believed to be in your best interest.
We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.
We shall continue to process this information during the course of the contract between us and where there is legitimate interest to retain this information we will continue to diligently process your information.
Information we process with your consent
Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, you provide your consent to us to process information that may be personal information.
Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply.
Information we process for the purposes of legitimate interests
We may process information on the basis there is a legitimate interest, either to you or to us, in doing so.
Where we process your information on this basis, we do after having given careful consideration to:
- whether the same objective could be achieved through other means
- whether processing (or not processing) might cause you harm
- whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so
For example, we may process your data on this basis for the purposes of:
- record-keeping for the proper and necessary administration of Breakthrough Counselling
- responding to unsolicited communication from you to which we believe you would expect a response
- protecting and asserting the legal rights of any party
- insuring against or obtaining professional advice that is required to manage our risk
- protecting your interests where we believe we have a duty to do so
Information we process because we have a legal obligation
We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation.
For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.
This may include your personal information.
Specific uses of information you provide to us
Information provided on the understanding that it will be shared with a third party
Our website may contain testimonials written by our clients. When providing a testimonial which could contain your personal information, it is up to you to satisfy yourself about the privacy level of every person who might use it. We do store this information, and we reserve a right to use it in the future in any way we decide.
Once your information enters the public domain, we have no control over what any individual third party may do with it. We accept no responsibility for their actions at any time.
Provided your request is reasonable and there is no legal basis for us to retain it, then at our discretion we may agree to your request to unpublish, amend or delete personal information that you have provided for use on our website. You can make a request by contacting me at email@example.com.
Complaints regarding content on our website
If you complain about any of the content on our website, we shall investigate your complaint.
If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate.
Free speech is a fundamental right, so we have to make a judgment as to whose right will be obstructed: yours, or that of the person who posted the content that offends you.
If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.
Information relating to your method of payment
Payment information is never taken by us or transferred to us either through our website or otherwise. At the point of payment, you are transferred to a secure page on the PayPal website or some other reputable payment service provider. That page may be branded to look like a page on our website, but it is not controlled by us.
Sending a message to us
When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need.
We record your request and our reply in order to increase the efficiency of our business. We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.
When we receive a complaint, we record all the information you have given to us.
We use that information to resolve your complaint.
If your complaint reasonably requires us to contact some other person or organisation such as an insurer, we may decide to share some or all of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.
Use of information we collect through automated systems when you visit our website
Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.
Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.
Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.
- to monitor how you use our website
- to record whether you have seen specific messages we display on our website
Personal identifiers from your browsing activity
Requests by your web browser to our servers for web pages and other content on our website can be recorded.
We may record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.
We could use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.
If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally.
Our use of re-marketing
Re-marketing involves placing a cookie on your computer when you browse our website in order to be able to serve to you an advert for our products or services when you visit some other website.
Disclosure and sharing of your information
Information we obtain from third parties
Although we do not disclose your personal information to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal information from third parties whose services we use.
Data may be processed outside the European Union
Our website is currently hosted by 1&1 who offers a wide range of Web hosting products, including email solutions and high-end servers in 10 different countries including Germany, Spain, UK and the United States. Accordingly data obtained within the UK or any other country could be processed outside the European Union.
Access to your own information
Access to your personal information
- At any time you may review or update personally identifiable information that we hold about you, by send me a request by email firstname.lastname@example.org
- After receiving the request, we will tell you when we expect to provide you with the information, whether identification will be required and whether we require any fee for providing it to you.
Removal of your information
If you wish us to remove personally identifiable information from our website, you may contact me at email@example.com. This may limit the service we can provide to you.
Verification of your information
When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
Use of site by children
- We do not provide services for purchase by children, nor do we market to children.
- If you are under 18, you may use our website only with consent from a parent or guardian
How you can complain
- If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
- If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office. This can be done at https://ico.org.uk/concerns/
Retention period for personal data
Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us.
- to provide you with the services you have requested;
- to comply with other law, including for the period demanded by our tax authorities;
- to support a claim or defence in court.
Typically this means we will stop processing your information 6 years after you have stopped using our services.
Compliance with the law
However, ultimately it is your choice as to whether you wish to use our website or engage our counselling services.
We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.