CHOICES Privacy Policy

When you request information from CHOICES, or self-refer to use any of our services, we obtain information about you. This statement explains how we look after that information and what we do with it.

We have a legal duty to ensure that the data we hold about you is accurate, adequate, relevant and not excessive. Normally the only information we hold comes directly from you. Whenever we collect information from you, we will make it clear which information is required in order to provide you with the information and/or appropriate service you need. You do not have to provide us with any additional information unless you choose to. We store your information securely on our computer system, we restrict access to those who have a need to know, and we train our staff in handling the information securely. We may want to contact you in future to tell you about other services we provide, and ways in which you might like to support CHOICES. You have the right to ask us not to contact you in this way. We will always aim to provide a clear method for you to opt out. You can also contact us directly at any time to tell us not to send you any future information about our services or fundraising events.

For the purpose of the Data Protection Act 1998 (the Act) and the EU General Data Protection Regulation 2016/679 (“Data Protection Law”) CHOICES is a “data controller”. This means that we are responsible for, and control the processing of, your personal information.

What data do we collect?

We collect information you provide, like your name, email address, and postal address
This happens directly when you register your interest in accessing one of our services, either on the phone, via email, or through our website

and indirectly through third parties such as when a health professional contacts us on your behalf

Also we collect them as you navigate through our website
This includes your IP address, how much time you spend on the site, and what you like or view. Wherever possible we use anonymous information which does not identify individual visitors to our website.

Why do we collect data and what do we do with it?

We collect this information in order for you to access our services in the safest way possible and also to keep in touch with you about our work. We will mainly use this information:

• to provide you with the services or information you have requested such as specialist counselling
• to process Gift Aid donations and comply with our legal obligations
• to send you any information on our support services, fundraising appeals, campaigns, and awareness events
• to notify you of changes to our policies
• to keep a record of your relationship with CHOICES
• to administer the volunteering arrangement in case you volunteer with us
• to process your data in connection with internal monitoring and evaluation of our services
• when taking up references or obtaining a disclosure from a DBS check.

What is sensitive personal information?

Data Protection Law recognises that some categories of personal information are more sensitive than others such as information about a person’s health, race, ethnic origin, political opinions, sex life, sexual orientation or religious beliefs.

If you contact us over the phone or by any other means and complete a registration form to access one of our services, you may get asked for details of a sensitive nature. It is your right not to disclose any of those details, except basic contact details which will allow us to stay in touch with you and complete the registration process for our services.
We may need to disclose your details if required to the police, regulatory bodies or legal advisors.

How do we use Cookies?

Our website uses cookies to distinguish visitors. This helps us to provide a better user experience when the website is browsed. Cookies also allows us to assess how our visitors’ use of the website and the journey through it, and we use this information to improve its functionality.

As part of respecting the privacy of our website visitors, we do not use any cookies that collect personal information about you. By using and browsing the CHOICES website you are giving consent for cookies to be used according to our policy. If you do not consent to cookies being used, you can block or restrict any of the cookies through your browser settings or refrain from using the website.

Details of the cookies we use, their names and why we use them are outlined below.

Allowing the website to operate
To make sure that the website operates correctly and runs smoothly we use cookies which assign a session name to each visit, these cookies are removed on closing the browser. Cookies are also used to identify whether Adobe Flash is available or not for a visitor.

Understanding website usage
To better understand how our website is used and improve its performance we use Google Analytics cookies. Google Analytics is an analytical web service provided by Google, Inc. Cookies are used to collect information such as the time of day a visit occurred, which pages were visited, how long was spent on the site and to identify the point of origin and any search keywords used. This helps us to provide a better website experience and improve its performance.

Third party cookies
To allow functionality from social media networks such as Twitter and Facebook, third party cookies are used on the CHOICES website. We have no control over these third-party cookies. To find out more about any third-party cookie it is advisable to visit the respective site and to review their individual cookie policy.

How do we store your data and data protection?

When you give us your details, you agree to us recording them on our secure database and server. However, the transmission of information over the Internet is never completely secure so although we do our best to protect your personal information sent us to us online, we cannot guarantee the security of any information you submit to us via our website.

We also take appropriate measures to ensure that the information we receive is kept secure, accurate and up to date and kept only for so long as is necessary for the purposes for which it is used. All access to our secure server is restricted only to authorised staff.

The personal information collected from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). By submitting your personal data, you agree to this transfer, storing and processing at a location outside the European Economic Area.

We do our best to ensure that your data is kept securely and in accordance with this privacy policy. We review our use of external services on an annual basis to ensure it complies with European data protection regulations.

How long will we keep your data for?

We will not keep your data for longer than necessary in relation to the purposes for which it was originally collected.

We will keep personal information for the following periods:

Data subject	Retention Period	Reason
Accessing one of our support services	For 7 years from the last time you used the service	We need to make sure that we can provide a safe service – this means keeping information so that we can respond to risk. You may want information on your support at CHOICES for future services you engage with or if you report to the police. We also need to be able to respond to any complaints made against us.
Information on employees	For 6 years after you stop working for us	By law we need to keep certain financial information. We also need to be able to respond to complaints made against us.
Information on job applicants	For 1 year after the job closes	We need to show we have fair application processes and may wish to contact you regarding other jobs.
Information on volunteers	For 6 years after you stop volunteering for us	We need to be able to respond to complaints made against us.

Donations you’ve made to us	For 7 years since the date of your last donation	As a charity, we need to keep robust financial records.
Purchasing services, like training or venue hire	For 3 years	As a charity, we need to keep robust financial records.
Information on training course participants	For 3 years after the course finishes	You may want to volunteer for us

We are legally required to hold some personal information to fulfil statutory obligations, for example the collection of Gift Aid or to support certain financial transactions.

You can withdraw your consent to us keeping your data at any time without needing to specify a reason. To withdraw your consent, please contact us using the methods below. If you ask us not to contact you, we will keep limited information about you to ensure we respect this.

Communication with you and the marketing of our services to you

We will only contact you about our services and how you can support CHOICES by email, text message, post or phone if you have agreed for us to contact you in this manner.

You can update your choices or stop us sending you these communications at any time by contacting admin@choicescousnellling.co.uk or calling us on 01223 358149.

Who has access to your data?

All information provided voluntarily by you is used exclusively by CHOICES; we do not sell, trade or transfer our data to any third parties unless express consent is given, and we do not sell any information about your web browsing activity. The personal information we collect about you will be used by our staff and volunteers so that they can best support you.

Legal disclosure
We may disclose your information if required to do so by law (for example, to comply with applicable laws, regulations and codes of practice or in response to a valid request from a competent authority); in connection with any legal proceedings or prospective legal proceedings; or in order to establish, exercise or defend our legal rights.

► YOUR RIGHTS

You have a right to access and control your information and ask us to stop processing your personal data. We will respond to requests for information and, where applicable, will correct, amend, or delete your personal information.

If you wish to exercise any of these rights or make a complaint, you can do so by contacting our Data Protection Officer at CHOICES; Alex Wood Hall, Norfolk Street, Cambridge, CB1 2LD, by email: admin@choicescounselling.co.uk or by phone on 01223 358149.

In order to correct, amend or delete any of your personal information, we will need to carry out checks to make sure you are who you say you are.

It is sometimes not possible for us to delete all of the information we have on you. If you ask for us to delete your data, we will let you know if it has not been possible to delete everything we hold on you.

Should you wish to make a complaint about the way we keep your data you can do so by contacting the Information Commissioner’s Office, at ico.org.uk.

This privacy policy was last updated on 23^rd May 2018.