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This website is owned by Suzanna Williams (‘I’, ‘my’, or ‘me’).

If you have any concerns about this notice or your privacy please tell me. You can contact me through this website.
 

Introduction
 

This notice describes how I collect, store, transfer and use personal data. It tells you about your privacy rights and how the law protects you.
 

In the context of the law and this notice, ‘personal data’ is information that clearly identifies you as an individual or that could be used to identify you if combined with other information. Acting in any way on personal data is referred to as ‘processing’.
 

I am committed to preserving the confidentiality of all information you provide to me including your personal data.

Personal data I process
 

1. How I obtain personal data
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The information I process about you includes information:
 

• you directly provide to me; and

• collected as a result of monitoring how you use this website

2. Types of personal data I process directly

When you enquire about, book or attend a counselling or therapy session, you disclose personal data to me which may include:
 

• personal identifiers, such as your first and last names and your date of birth

• contact information, such as your email address, your telephone number and your postal address

• clinical information that you provide during a session, such as information about events in which you were involved, your circumstances and your beliefs;
   

• medical information, such as details about your general practitioner and your past and current health;

• transaction information, such as information about payments and other bookings you have made or attended; and

• records of communication between us including messages sent through this website, email messages and telephone conversations.

3. Types of personal data I collect from your use of my website

When you visit my website, I process:
 

• technical information about the hardware and the software you use to access this website, including your Internet Protocol (IP) address, your browser type and version and your device’s operating system; and

• usage information, including the frequency you use this website, the pages that you visit, whether you receive messages from me and whether you reply to those messages.
   

4. Special personal data
 

Special personal data is data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. It also includes information about criminal convictions and offences.
 

Because of the nature of the services I provide, in order to do so to you, I may need to process information that falls into the types classed as special category data.
 

For example, during a therapy session, you may tell me about a previous experience that has influenced your beliefs. Following the session in which you do so, I may record notes in order to recall in a later session clinical or medical information that is important.
 

The law enables me to process special category data where doing so is necessary for health or social care purposes or where you have given explicit consent for me to do so.
 

If I process special category data relating to you then I ensure that additional care is given in safeguarding it.
 

5. Membership of professional bodies
 

I am a member of the British Association for Counselling and Psychotherapy (‘BACP’).
 

In addition to following the requirements of the law, the BACP requires me as a member to comply with its code of ethics, which includes principles relating to the confidentiality and privacy of client information.
 

This code can be found at:
 

https://www.bacp.co.uk/events-and-resources/ethics-and-standards/ethical-framework-for-the-counselling-professions/

If, as a requirement of my ongoing professional registration to uphold my standard of care, I discuss my clinical work with a supervisory member of the BACP, then I will protect your personal data through pseudonymisation. Any supervisor, like me, is subject to rigorous ethical standards as well as the law.
 

6. Use of aggregated information
 

I may aggregate anonymous information such as statistical or demographic data for any purpose. Anonymous information is that which does not identify you as an individual. Aggregated information may be derived from your personal data but is not considered as such in law because it does not reveal your identity.
 

However, if I combine or connect aggregated information with your personal data so that it can identify you in any way, I treat the combined information as personal data, and it will be used in accordance with this privacy notice.
 

7. If you do not provide required personal information
 

Unless you provide me with the information I need to provide my services, I may not be able to perform all or part of any contract between us. If so, I will notify you of this at the time.

 

The bases on information about you is processed
 

The law requires me to determine under which of six defined bases I process different categories of your personal information, and to notify you of the basis for each category.
 

If a basis on which I process your personal information is no longer relevant then I shall immediately stop processing your data.
 

If the basis changes then if required by law I shall notify you of the change and of any new basis under which I have determined that I can continue to process your information.
 

8. Information processed under a contract

To provide my services, or in situations where you have requested that I provide my services, I must collect and record your personal data.
 

For example, before I provide my services to you, I ask to tell me about yourself and your circumstances so that I can assess whether my services are suitable and how best I may be able to help you. I process this information on the basis of contract because there is a reasonable presumed intention to enter into a contract.

I continue to process this information until the contract between us ends or until I am otherwise no longer required to keep it.
 

9. Information I process with your consent
 

Through actions when otherwise there is no contractual relationship between us, such as when you agree to use of non-essential cookies on this website, you consent to me processing personal data, including personal identifiers, contact information and technical information.

I continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.

You may withdraw your consent at any time by telling me. However, if you do so, you may not be able to use this website or my services further.

Please be aware that I am not obliged by law to delete your personal data or to stop processing it simply because you do not consent to me doing so. While having your consent is an important consideration as to whether to process it, if there is another legitimate basis on which I may process it, I may do so on that basis.
 

10. Information I process for the purposes of legitimate interests

I may process personal data on the basis there is a legitimate interest, either to you or to me of doing so.

Where I process your information on this basis, I do so 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; and

• whether you would expect me to process your data, and whether you would, in the round, consider it reasonable to do so.
   

For example, I may process your information on this basis for the purposes of:
 

• record-keeping for the proper and necessary administration of my business;

• protecting and asserting the legal rights of any party

• protecting your interests where I believe I have a duty to do so

Where there is a legitimate interest such as where I perceive an imminent risk of death or serious harm to you or someone else, or to prevent a crime or a civil wrongdoing, I am permitted by law to disclose your personal data (for example, to your GP).
 

11. Information I process because I have a legal obligation

Sometimes, I must process your information in order to comply with a statutory obligation.

For example, I may be legally required to disclose personal data where I am concerned about terrorism or money laundering, or where I am required by a court of law.  
 

This may include your personal information.
 

12. Information I process to protect vital interests

In situations where processing personal data is necessary to protect someone’s life, where consent is unable to be given and where other lawful bases are not appropriate, I may process personal data on the basis of vital interests.

For example, I may inform relevant organisations if I have a safeguarding concern about a vulnerable person you have mentioned.
 

Other uses of information
 

13. Cookies

Cookies are small text files that are placed on your computer's hard drive by your web browser when you visit a website that uses them. They allow information gathered on one web page to be stored until it is needed for use at a later date.

They are commonly used to provide you with a personalised experience while you browse a website, for example, allowing your preferences to be remembered.
 

They can also provide core functionality such as security, network management, and accessibility; record how you interact with the website so that the owner can understand how to improve the experience of other visitors; and serve you advertisements that are relevant to your browsing history.
 

Some cookies may last for a defined period of time, such as one visit (known as a session), one day or until you close your browser. Others last indefinitely until you delete them.
 

Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use. Your web browser may support a plug-in or add-on that helps you manage which cookies you wish to allow to operate.

The law requires you to give explicit consent for use of any cookies that are not strictly necessary for the operation of a website.
 

This website is hosted by Wix, which uses cookies for a number of different reasons including for security purposes; for monitoring the performance of this website; and for providing a good experience for visitors. You can read more about how Wix uses cookies at https://support.wix.com/en/article/cookies-and-your-wix-site
 

14. Personal identifiers from your browsing activity
 

Requests by your web browser to the servers for web pages and other content on this website are recorded.

This information is technical information, recorded for security purposes. Theoretically, if combined with other information known about you from previous visits, the data possibly could be used to identify you personally. However, I do not use it in such a way.
 

Other matters
 

15. Your rights
 

The law requires me to tell you about your rights and my obligations to you in regard to the processing and control of your personal data.
 

I do this now, by requesting that you read the information provided at http://www.knowyourprivacyrights.org
 

16. Delivery of services using third party communication software
 

With your consent, we may communicate using software provided by a third party such as Apple (Facetime), Microsoft (Skype) or Zoom Video Communications (Zoom).

The providers of such software secure your personal data using encryption and other technologies and comply with all applicable privacy laws, rules, and regulations, including the GDPR.
 

If you have any concerns about using a particular software for communication, please tell me.
 

17. Data may be processed outside the UK
 

My business is based in England.

The headquarters of my website hosting provider, Wix, are in Israel. Israel is considered by the United Kingdom to offer an adequate level of protection for the personal information of UK and EU Member State residents.
 

Your personal information may be stored through Wix’s data storage, databases and the general Wix applications. Data is stored on secure servers behind a firewall.

Your data may be maintained, processed and stored by Wix and their authorised affiliates and service providers in the United States of America, in Europe (including in Lithuania, Germany and Ukraine), in Israel, and in other jurisdictions as necessary for the proper delivery of their services and/or as may be required by law.

Wix affiliates and service providers that store or process your data on Wix’s behalf are each contractually committed to keep it protected and secured, in accordance with industry standards and regardless of any lesser legal requirements which may apply in their legal jurisdiction.
 

Wix’s full privacy policy can be viewed at: https://www.wix.com/about/privacy
 

18. Control over your own information
 

It is important that the personal data I hold about you is accurate and current. Please keep me informed if your personal information changes.
 

At any time you may contact me to request that I provide you with the personal information I hold about you.

Please be aware that I am not obliged by law to provide you with all personal data I hold about you, and that if I do provide you with information, the law allows me to charge for such provision if doing so incurs costs for me. After receiving your request, I will tell you when I expect to provide you with the information, and whether I require any fee for providing it to you.
 

19. Communicating
 

When you contact me, whether by telephone, through this website or by email, I collect the information you have given to me in order to reply.
 

I may keep personal information associated with your message, including your Identity and Contact Information so as to be able to respond to you.
 

20. Complaining

If you are not happy with this privacy policy or if you have any complaint then you should tell me.

When I receive a complaint, I record all the information you have given to me.
 

I use that information to resolve your complaint.
 

If your complaint reasonably requires me to contact some other person, I may decide to give to that other person some of the information contained in your complaint. I do this as infrequently as possible, but it is a matter for my sole discretion as to whether I do give information, and if I do, what that information is.
 

If a dispute is not settled then I hope you will agree to attempt to resolve it by engaging in good faith with me in a process of mediation or arbitration.
 

If you are in any way dissatisfied about how I process your personal information, you have a right to lodge a complaint with the Information Commissioner's Office (ICO). This can be done at https://ico.org.uk/make-a-complaint/. However, I would appreciate that if you have a concern, you raise it with me before complaining to the ICO.
 

21. Retention period for personal data
 

I keep your personal information only for as long as required:
 

• to provide you with the services you have requested;

• to comply with other law, including for the period demanded by tax authorities; and

• to support a claim or defence in court.
   

22. Compliance with the law
 

My privacy policy complies with the law in the United Kingdom, specifically with the Data Protection Act 2018 (the ‘Act’) accordingly incorporating the EU General Data Protection Regulation (‘GDPR’) and the Privacy and Electronic Communications Regulations (‘PECR’).
 

23. Review of this privacy policy
 

I may update this privacy notice from time to time as necessary.

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