Privacy Policy

Privacy Policy - Updated 24 June 2024

This notice is in regard to data protection laws, and is regarding information that is both requested by Caroline Sharp Therapies and that which emerges as a result of the counselling service that we provide to yourself and also if providing services to a child/young person that you have parental responsibility for.

Who we are

Caroline Sharp Therapies provides counselling for children, young people and adults ranging for 5 years old and above. We help people with a wide range of issues such as depression, anxiety, anger management difficulties, relationships, abuse, bereavement, low self-esteem, etc.

Caroline Sharp Therapies offers services solely from Caroline Sharp who is responsible for for the data processing and data control.

Our Commitment

Caroline Sharp Therapies applies the UK Data Protection Act 2018 privacy standard. We are committed to:

protecting the confidentiality, integrity and availability of the information it collects, stores, transfers and processes in accordance with UK law and international good practice, and to meeting its legal requirements and contractual obligations
explaining why it needs personal information, only asking for and collecting personal information it needs and only sharing personal information within Caroline Sharp Therapies and with other organisations where legally necessary.
allowing people to request access to the personal information it holds on them and to complain if they believe their information has been mishandled
not keeping personal information for longer than necessary
ensuring that actual or suspected breaches of information security are reported and investigated
assessing and reviewing its information security controls annually
applying these standards to its Third Parties it may use in delivering its services.

We will provide adequate and appropriate resources to implement this policy and will ensure it is communicated and understood.

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What information we collect from you/about you

We collect the information about you from the following contact points:

On our website through our booking system
By email when you complete self-referral and enquiries forms
Over the telephone when you contact to register/book our services
During counselling consultation sessions we make notes
Cookies on our websites which you consent to
Third Party Partners we use to provide service, e.g. PayPal, Stripe and Wix

Our Website

Our website address is: www.carolinesharptherapies.co.uk

We collect and use personal data to offer people information and services. This policy will apply in all locations where we operate, to all forms of information and to all systems used to collect, store, process or transfer information.

The purpose of this notice is to make you aware of what information we collect and how we will handle your information.

Self-Referral, Contact forms and Appointment Bookings

We collect the following information about you from self-referral, contact forms and when booking your sessions when we or you complete these on our website and via email:

Contact details including name, address, telephone number and email.
Contact details of parent/carer/guardian for child and young person services.
Contact details for child services if child is 14 years or older and is arranging sessions independently with permission from responsible adult.
Type of service required and preferred day, time and location.
Relevant life data which may help to inform the counselling treatment plan eg. Medical history, family set up, bereavement or losses, personal and emotional challenges, school history for child/young person, etc.
Any additional notes requested and gathered from other professionals. For child/young person these could be teachers, SENCos, educational psychologists, speech therapists, etc.

Telephone Conversations

We take personal information similar to that on our referral or contact form above when you contact us over the phone. In addition we also collect your postal address and next of kin details.

Email communications

On receipt of an email enquiry and/or consultation call we ask you to complete a contract and assessment form which requests personal information for our counsellors to assess their suitability for your requirements. In addition we also collect your postal address and next of kin details. These personal details are kept on an encrypted file which is stored on a secure password protected system.

Counselling Sessions

Our counsellor collects information specific to your counselling requests and make notes during our sessions as part of our professional practice and to ensure continuity of support from one counselling session to another.

Notes collected by the counsellor are kept on an encrypted file which key code protected and is stored in a password protected location.

We also collect phone numbers, email address and physical address and next of kin details.

Why we collect this information from you

We collect this information from you to help support and inform our work with you. Contact details are also necessary to maintain contact throughout the duration of the counselling.

Who we might share this information with and why

Due to the confidential nature of the counselling service, we aim to keep any sharing of information given to an absolute minimum. Circumstances where sharing might/will be necessary are as follows:

Supervision - all counsellors are required to attend regular supervision to support their practice. Details of your case may be shared during supervision yet you remain anonymous and your contact details or name are not disclosed.
Anonymous case studies - ongoing training may require the completion of case studies, all personal details will be omitted from these and remain anonymous.
Safe guarding concern - if we believe there is risk of serious harm to yourself or another or there is a safe guarding or child protection concern for a child/young person.
Legal duty - if you share information in relation to acts of terrorism, money laundering, drug trafficking we have a legal obligation to share this with the relevant authorities.
Accounts - as part of the accounting process your name, address and email will be shared with any accountant we use for tax return assistance. Payment methods will also gather personal contact information which is described in more detail below.

Third Party Partners

The following Third Parties will also collect data from you to support the services they provide as part of our website and booking system. The data they collect will be governed by their privacy policies detailed below:

Zoom Inc

We use Zoom Video Communications Inc for our online counselling sessions. Zoom Inc is a US based company based outside of the UK. All Zoom calls are end-to-end encrypted and our account settings are set so that sessions cannot be recorded.

Zoom collects the following information about you so that you can gain access to the online video screen:

E-mail address, name, display name, picture, phone number, job information, stated locale, user ID if you have an account with Zoom

We do not store this information in any of our systems. Zoom Video Communications Inc privacy policy can be found here: https://explore.zoom.us/en/privacy/

Stripe Inc & PayPal Inc

We use Stripe Inc. and PayPal Inc for taking online payments for the services you select from our website. Both Stripe and PayPal are US based companies based outside the UK.

Stripe collects the following information about you for processing online payments:

E-mail address, card information, name on card, billing address

We do not store this information in any of our systems. Stripe Inc privacy policy can be found here: https://stripe.com/gb/guides/general-data-protection-regulation‍

PayPal collects a variety of personal information depending on whether you have an account with them. Among the Personal Data collected you may find:

trackers,
usage data,
first name,
last name,
phone number,
email address,
username,
password,
various types of data as specified in the privacy policy of the service,
billing address,
payment info,
device information,
purchase history.

For more information on how PayPal processes personal data, please see their privacy policy or check their main website. We do not store this information in any of our systems

QuickFile

We use QuickFile for our accounts. We provide only your contact name, address and email for invoicing purposes if payments are being made directly into our bank. For online payments via Stripe or PayPal your personal information is not provided to QuickFile and you remain anonymous.

The information QuickFile collects about you is detailed in their privacy policy which can be found here. https://community.quickfile.co.uk/t/privacy-policy/18934

Wix

We use Wix Website Hosting cloud services for our website. The information Wix. collects about you is detailed in their privacy policy which can be found here. https://www.wix.com/about/privacy

Google Analytics

We use Google Analytics to collect information about how our website visitors are using our website - what information they look at, how they use a web page, how long they spend on the site, etc.

You may opt-out of Google Analytics for Display Advertisers including AdWords and opt-out of customised Google Display Network ads by visiting the Google Ads Preferences Manager.

To provide website visitors more choice on how their data is collected by Google Analytics, Google has developed an Opt-out Browser add-on, which is available by visiting Google Analytics Opt-out Browser Add-on, to enable you to opt-out of Google’s programs.

To opt out of the collection and use of information for ad targeting please feel free to exercise your rights

How we use information about you

We need your information and will use your information to:

undertake and perform our obligations and duties to you in accordance with the terms of our contract with you;
enable us to supply you with the services and information which you have requested;
analyse the information we collect so that we can administer, support and improve and develop our business and the services we offer;
to contact you in order to send you details of any changes to our counsellor service which may affect you; and
for all other purposes consistent with the proper performance of our operations and business.

‍How we protect your information

When you give us information we take steps to make sure that your personal information is kept secure and safe.

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We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Some of the specific measures Caroline Sharp Therapies has put in place include the following:

Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
Performing regular checks and scans to ensure security hardware and software is functioning properly.
Evaluating any third-party services the organisation is considering using to store or process data. For instance, cloud computing services, social media, or other communication platforms.
Using SSL (Secure Sockets Layer) encryption for our website which ensures that any personal information you submit through our website is not visible to anybody else when in transit between your computer and our server. However, the transmission of information via the internet is not completely secure. We cannot therefore guarantee the security of your data transmitted to our site: any transmission is at your risk.
Email systems have built-in end-to-end encryption when sending personal information
We use of codes and/or pseudonyms for our clients
We use password facilities on phones, computers and (software applications)
Data is backed up on cloud based servers and on secure local back-up devices for which passwords are required to access the data
We implement physical security measures to our server rooms
Keeping your information up to date

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The accuracy of your information is important to us. The law requires the Caroline Sharp Therapies to take reasonable steps to ensure data is kept accurate and up to date. It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.

Data should be updated as and when inaccuracies are discovered. Please help us keep our records updated by informing us of any changes to your email address and other contact details.

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How long we retain your information

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

We keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for seven (7) years after they cease being customers, for financial audit purposes.
We keep adult client notes for three (3) years after finishing with the client.
For children and young adult we keep client notes for seven (7) years after the client has reached 25 years of age.
If a client does not engage with the service after we have collected their information, we delete the information within six months

We review our data retention periods regularly and will only hold your personal data for as long as is necessary for the relevant activity, or as required by law.

How we dispose of the information

Notes and contact information that are held securely on an encrypted and encoded filing system as well as a back-up on a further encrypted and encoded file. When notes are disposed of they are permanently erased from each of the file and folder locations.

Contact information that is held externally through a third party is permanently deleted using their deletion process.

Your right to access your data

All individuals who are the subject if personal data held by Caroline Sharp Therapies are entitled to:-

Ask for a copy of the information Caroline Sharp Therapies holds about them and why.
Ask how to gain access to it.
Require us to correct any inaccuracies in your information.
Be informed how the Caroline Sharp Therapies is meeting its data protection obligations.
Make a request to us to delete it.

When exercising your rights, you must give us a request in writing, by post or by email. If you would like to exercise any of your rights above please contact carolinesharptherapies@gmail.com

Limitations to your rights

In certain circumstances, the GDPR allows personal data to be disclosed to law enforcement agencies without the consent of the data subject. In these circumstances, Caroline Sharp Therapies will ensure the request is legitimate, the organisation's legal advisers where necessary.

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What we may need from you

We may need to request specific information from you to help us confirm your identity, proof of your address and ensure your right to access your personal data (or to exercise any of your other rights) or any other information that we reasonably need to locate the information you have requested. 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.

We will not start looking for your information until we confirm your identity.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may 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.

Complaints Process

Should you wish to exercise all relevant rights, or to submit queries or complaints about the use of your information, we would ask that you contact us in the first instance at:

Caroline Sharp, Holly Cottage, 18a Century Road, Gillingham, ME8 0BG Phone: +44 (0) 7875 992408

You also have the right to complain to the Information Commissioner’s Office in relation to our use of your information. The Information Commissioner’s contact details are noted below:

Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Telephone: 0303 123 1113

Email: casework@ico.org.uk

What happens in the event of a data breach

In the unlikely event of a data breach, we have a duty to inform you and the ICO within 72 hours of it occurring.

Changes to our Privacy and Data Protection Policy

Caroline Sharp Therapies will review this policy statement regularly to reflect new legal and regulatory developments and ensure good practice.

I will keep you informed of any further relevant changes to the policy that may affect you.

Data Controller

Caroline Sharp is notified as a Data Controller with the Office of the Information Commissioner (ICO) under registration number ZB498503 and is the data controller of any personal data that you provide to us.

Contact details: Caroline Sharp, Holly Cottage, 18a Century Road, Gillingham, ME8 0BG

Any questions relating to this notice and our privacy practices should be sent to Email: carolinesharptherapies@gmail.com