Privacy Notice
Introduction
LPG Counselling is committed to transparency and to complying with its responsibilities in accordance with the laws of Scotland and any dispute or difference in relation to this agreement shall be subject to the exclusive jurisdiction of the Scottish Courts. The purpose of the Privacy Notice to provide you with the relevant information about what information we collect from you; what it is used for; and your rights, under the legislation, to access your information as is required by the Data Protection Act 2018. This Privacy Notice relates to employees and individual clients.
The legislation
The General Data Protection Regulation (GDPR) came into force from May 25th 2018 and it regulates how organisations are allowed to use personal data. This notice is intended to meet the transparency requirements of GDPR and to ensure all clients and employees know how their data will be processed.
Who will process your information?
Under data protection legislation LPG Counselling is the Data Controller. This means that the managing directors of LPG Counselling are responsible for how your data is used and processed; and for complying with requests from you in relation to your personal data, where appropriate.
How we use your information?
Your information is used to process payments and refunds; to collate statistics to improve our services; and to send you information and marketing regarding the services we offer. Your contact information, if you have provided this information, can only be used to contact someone in an emergency if you have given consent.
Telegram/ WhatsApp/ other Instant Messaging platforms
One of the services we offer is the ability to be able to communicate with your counsellor via Instant messaging platforms before, during and after your sessions. For this service we require your mobile number. Periodically your chats will be exported and stored on an encrypted device and held for 6 years. After this time period your chats will either be deleted or anonymised. Due to the nature of messaging apps we cannot guarantee confidentiality. No member of LPG Counselling would willingly breach your confidentiality without seeking your permission, but we understand that third party companies do collect your data. If you decide to communicate with LPG Counselling via these platforms, we assume you have taken careful consideration and made an informed choice before using these methods of communication. Here we have included the links to WhatsApp’s (https://www.whatsapp.com/legal/#privacy-policy) and Telegram’s (https://telegram.org/privacy) Privacy Policies to enable you to make an informed decision.
Zoom for online counselling
All counsellors at LPG Counselling use the virtual video chat platform Zoom to carry out counselling sessions online. We have chosen Zoom due to the many security features it offers and we feel it is the one of the most secure video platforms available at the moment. We understand that you may have concerns over Zoom’s use of your data we direct you to Zoom’s Privacy Policy (https://zoom.us/privacy).
Is my data secure?
Your personal data is kept electronically and managed securely via encryption software. Access is restricted to only the managing directors of LPG Counselling and will only be accessed on a need to know basis.
Keeping information up to date
LPG Counselling will strive to keep your information accurate and up to date. If there are any changes to be made to your information, we would ask that you inform us at your earliest convenience.
Retention of personal data
LPG Counselling will keep your information for a total of 6 years after you have completed your counselling. The purpose of this time period is to allow us to be able to comply with any requests made for your information should a situation arise in which you require said information. Your information will also be used in order to compile statistics for the analysis and improvement of our business services. After the 6 year time period, any personal information we hold on you will either be deleted or anonymised.
What does anonymised mean?
This refers to the process by which all identifiable information is removed from any records or notes we have for you in order to safeguard your data.
Your rights
You have the right to:
· Find out what personal data we process about you and obtain a copy of the data, free of charge within one month of you request. We may make a charge for additional copies of the same information
· Ask us to correct inaccurate or incomplete data.
· Withdraw consent to process your personal data at any time, if you asked and provided consent.
If you think we are acting unfairly or unlawfully you can:
· Object to the way we are using your data
· Complain to the UK Information Commissioner’s Office (ICO)
Under certain conditions you also have the right to ask us to:
· Restrict the use of your data (e.g., if you have raised issues about the accuracy or use of your personal data, until we have investigated and responded to your concerns)
· Erase your information or tell us to stop using it to make decisions about you
· Comply with your wishes where you have previously agreed to us processing your data for a particular purpose and have withdrawn your consent to further processing
· Provide you with a portable electronic copy of any data you have given us.
If you wish to find out more about data protection and your rights, please see:
· The Information Commissioner’s Office website
Please contact us if you wish to inquire about any of these rights.
What information do we collect and for what purpose?
Personal information will be held on electronic formats on various encrypted systems relating to:
· Personal and contact information (including emergency contacts, if applicable) – to contact and inform you or any applicable changes to the service we offer.
· Banking details – to obtain and refund payments
· Notes and attendance record – a legal requirement
Who do we share your data with?
At the time of use of this Privacy Notice (2019), LPG Counselling will not share your information with any third party unless you have specifically requested, given your consent and signed a Consent To Disclose.
What if I request/agree to you sharing my data with a third party?
In the instance that you wish for your counsellor to disclose information about your sessions to a third party we will ask for your written consent. We will ask you to fill out a Consent to Disclose form.
What is a Consent To Disclose?
This is a form that will be signed by both yourself and your counsellor. It lays out what information is to be shared; to whom that information is to be shared; and the purpose of sharing said information.
Can I record my sessions?
Yes, you can record your sessions. Recordings are considered personal data and as such there are a few considerations to contemplate beforehand. You must seek the permission of your counsellor; fill out a Permission to Record form; and both parties (yourself and your counsellor) must have copies of the recording(s). Because you will hold personal data of your counsellor be aware that you must, also, comply with GDPR legislation and you cannot distribute any recording (s) without your counsellor’s permission or hold onto them longer than is necessary.
What is a Permission to Record form?
This is a form that is filled out signed by both yourself and your counsellor. It is similar to the Consent to Disclose form in that it will detail the period of time over which the sessions are to be recorded; how long both you and your counsellor will hold the recording(s); and the purpose of the recording(s).
Who has access to your data?
The Company Directors of LPG Counselling will have access to your information.
What if you do not provide personal data?
Certain information, such as contact details and your payment details, must be provided to enable LPG Counselling to enter into a contract with you. If you do not provide the required information, this will hinder the organisation’s ability to provide you access to our services.