PLEASE READ CAREFULLY, IF YOU DO NOT ACCEPT THESE TERMS, YOU ARE ADVISED NOT TO USE THE WEBSITE
This policy was last updated: 22nd May 2018
Use of this website, www.anneturnbull.com constitutes your legal agreement to the terms within this policy and your acceptance of this policy is deemed to occur upon your first use of the website.
Anne Turnbull Counselling may change this policy from time to time by updating this page. You should check this page before using the website to ensure that you are aware of and accept any changes.
We will take all reasonable steps to ensure that personal information is safeguarded and kept in accordance with the law. We take additional measures when holding the data, including sensitive data, of those under 16 years of age.
Anne Turnbull Counselling Services and Training is a trading name of Collab Limited and is registered in England and Wales under Company Registration Number 06435126. Our registered office address is 22 Duarte Place, Chafford Hundred, Essex RM16 6PH. We are registered with the Information Commissioner’s Office (ICO) for data protection reference number ZA274002.
Where we manage personal data, we identify as a Data Controller and recognise and act on our obligations under applicable data protection laws. For any issues relating to data protection the person responsible is Anne Turnbull.
What personal data do we collect?
Information that you provide to us is retained and processed in accordance with UK data protection legislation. This includes data given to us from the following interactions:
Contact Us: We have a Contact Form and this is used to collect your first and last name and phone number as well as your message, so that we can contact you and provide details of our services to you, make bookings, confirm bookings and deal with general company enquiries. Data is held on the grounds of being legitimate to our business interests.
Phone calls: Phone calls to us may be recorded and any data relating to the call may be retained by us. The data will be held on the basis of being for our legitimate business needs or in order to fulfil our contractual obligations if you are a client of ours.
Social media: We use social media to engage with users and link to our Facebook and Twitter pages. We do not keep any specific data that identifies you as an individual user, but have some basic details of our followers on these platforms. You should refer to the Privacy Policies of these channels to understand how they treat your data in relation to linking to our site.
Testimonials: We may ask you for a testimonial in relation to our services that may be used on our website or social media. Only data that is non-identifiable is published.
Special categories of data
Some of the information you provide to us may be considered sensitive personal data which includes information about a data subjects ethnic or racial origin, political opinions, religious beliefs, trade union membership, physical or mental health, sexual life or criminal record.
Although we provide services to those under 18 years old, our website is not marketed at those under 18 years old and personally identifiable information from anyone under the age of 16 years old should not be given through any insecure communication channels.
We will take appropriate steps to delete any personal data of individuals less than 16 years of age that has been collected on our website upon learning of the existence of such data.
Information we get from other sources
From time to time, we may need to obtain information from third parties about you. This will only apply where it is necessary to provide our services and as permitted by law.
How do we use your data?
We may use the information we collect from you in the following ways:
- To administer and improve the website;
- To personalise the content and your experience of the website;
- To allow us to responding to communications sent to us;
- To process payments and transactions in relation to our services;
- To send you email notifications which you have specifically requested;
- To send to you marketing communications, where expressly agreed;
- To provide third parties with statistical information about our users;
- To ask for feedback or testimonials;
- To deal with enquiries and complaints made by or about you relating to the website.
Users contacting this website and/or its owners do so at their own discretion and provide any such personal details requested at their own risk. Your personal information is kept private and stored securely until a time it is no longer required or has no use.
We may use Data Processors who act on our instruction in relation to the management of your data and they must adhere to all data protection laws and regulations. We will ensure that any Data Processors used only operate on our written instructions and comply with their obligations under the GDPR. You will be informed of any other Data Controllers who have access to your data and who may determine processing activities separately to us, or as a Joint Data Controller.
Social media platforms
Communication, engagement and actions taken through external social media platforms that this website and its owners participate on are subject to our terms and conditions as well as the privacy policies held with each social media platform respectively.
Users are advised to use social media platforms wisely and communicate and/or engage with them with due care and caution in regard to their own privacy and personal details. This website nor its owners will not ask for personal or sensitive information through social media platforms and encourage users wishing to discuss sensitive details to contact them through primary communication channels such as by telephone or email.
Anne Turnbull Counselling uses social sharing buttons which help share web content directly from web pages to the social media platform in question. Users are advised that before using such social sharing buttons, that they do so at their own discretion, and should consider that the social media platform may track and save requests to share a web page, through the users’ social media platform account.
Anne Turnbull Counselling accepts payment by BACS. All third parties used to provide payment services will be secure, using up-to-date encryption via Secure Socket Layer (SSL) technology. Such data is not stored or processed on our servers.
We keep your personal information in accordance with our Data Retention Policy which reflects our needs to provide services to you as contracted and also as required to meet legal, statutory and regulatory obligations. The need to hold information is regularly reviewed and data will be disposed of when no longer required.
Your personal data is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential.
We take appropriate steps to ensure a safe processing of personal data, however, we cannot guarantee the security of data transmitted through our website or by email. Any transmission is at your own risk.
Rights of Data Subjects
Anne Turnbull Counselling recognises a data subjects rights and will uphold these in accordance with data protection laws. You are entitled to see the information held about you and you may ask us about any of the following:
Subject access requests
Data subjects (i.e. individuals) have the right to access personal data that is held by submitting a subject access request (SAR) to Anne Turnbull Counselling. We will endeavour to respond quickly to any such requests, which legally require us to respond within one month of receiving the request and necessary information. A subject access request can be made by emailing us firstname.lastname@example.org
Right to rectification
Data subjects have the right to request that we amend or change personal information that is inaccurate or incorrect.
Right to erasure
Data subjects have the right to ask us to delete personal information from our systems without giving any reason and at any time. We will act on any such request without delay.
Right to restrict processing
Data subjects have the right to rectification or erasure of personal data in the following circumstances:
- Personal data is not accurate;
- The processing of data is unlawful – data subjects may request that processing is restricted;
- Data is required to exercise legal rights or defend legal claims;
- Data is unlawful but there may be lawful grounds for processing, which override this right.
Right to data portability
Data subjects have the right to obtain and request the transfer of their data to different service providers.
Right to object
Data subjects have the right to object to the processing of data at any time based on their particular situation. This includes objecting to profiling unless it is in the ‘public interest’ or exercised lawfully by an official authority. We will only process data under lawful grounds.
Right not to be subject to decisions based on automated processing
We do not use any automated processing that results in any automated decision based on a data subject’s personal information.
Using your rights
If you wish to invoke any of these rights, you should contact the person responsible for data protection by emailing us at email@example.com
We will report any unlawful breach of data as required by the GDPR within 72 hours of the breach occurring, if it is considered that there is an actual, or possibility, that data within our control including the control of our data processors, has been compromised. If the breach is classified as ‘high risk’ we will notify all data subjects concerned using an appropriate means of communication. We will report any relevant breaches to the ICO, see below.
What are Cookies
Cookies are small files saved to the user’s computer hard drive that track, save and store information about the user’s interactions and usage of the website. This allows the website, through its server, to provide the user with a tailored experience when navigating the website. Session cookies may be used to validate your access to different parts of the website.