PRIVACY POLICY
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Introduction
This is the privacy notice of Find Your Feet CIC. In this document, "we", "our", or "us" refer to Find Your Feet CIC. Your confidentiality and privacy are extremely important to us and we take the protection of such most seriously.
This privacy policy outlines your rights and our obligations to you in regard to the storing, recording and processing of your personal information. The Data Protection Act 1988 (DPA) and the General Data Protection Regulation (GDPR) are laws that protect your personal information. We will treat your personal information in a way that is legally compliant with these laws. The DPA defines "personal information" as any information that can be used to identify a living individual. Examples include names and email addresses. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information. The law requires us to tell you about your rights and our obligations to you in regard to the processing and control of your personal data. We do this now, by requesting that you read the information provided at knowyourprivacyrights.org
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We regret that if there are any points below with which you are not happy, your only recourse is to leave our website immediately. ​
The Personal Information We Record
Your personal information may be collected by us via the website (www.findyourfeetcic.org.uk), over the telephone, email, other forms of writing, text, WhatsApp, and in-person during our meetings. When you contact us, you will most likely provide us with personal details such as your name, email address, phone number, address and availability. Before your initial session, we will ask you to read and sign a counselling contract electronically. We will also complete forms to collect personal information including name, address, date of birth, telephone numbers, email address and information relevant to your referral. Furthermore, we may ask for information on goals for therapy; previous therapy; current medication; a network of support; financial and employment circumstances; health and physical issues; mental health history; alcohol and drug use; appetite and sleep; family structure and any information we deem beneficial to your therapy. Aside from the generic details, this information helps to establish your perception of the situation, how it is affecting you, and to discuss what you would like to achieve from therapy.
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In addition, when you visit www.findyourfeetcic.org.uk we may collect the following information about your visit: I.P. address, location, search engine, date, time, web pages visited, operating system, and device.
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Storing and Processing Personal Information
The GDPR defines a "data controller" as the person who "determines the process and means of processing personal data". The data controller for Find Your Feet CIC is Emmanuel Balogun. We store your personal information both electronically and physically. Personal information is stored electronically on devices that are password and/or fingerprint I.D. protected, and in files that are further password protected and only accessible by us. Names and contact details are stored separately to other personal information (anonymised format). Information is stored physically using paper records held securely in locked storage in an anonymised format. These records are also only accessible by us. Your telephone number may be stored on a mobile phone and deleted one month from your last session. Your phone number will not be linked to your name (anonymised format).
All text messages and WhatsApp messages are deleted within one month of sending if you are not a client, and within one month of the termination of your therapy if you are a client. All personal information and session notes are retained for the legal requirement of 7 years following the termination of your treatment, after which time they will be shredded and/or destroyed. However, we may need to store your information longer than this on rare occasions e.g. in a claim situation or to comply with my insurance terms and conditions.
Some of your personal information such as may be picked up by the website provider, mobile phone operator, and card payment provider. These providers operate under their own privacy policy. Note that clients' phone numbers are stored under a code i.e. anonymised.
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Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to agree to our use of cookies. Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply. Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example, to monitor the performance of a particular page on our website. You may withdraw your consent at any time by instructing us at emmanuel@findyourfeetcic.org.uk However, if you do so, you may not be able to use our website or our services further.
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Confidentiality
All sessions will be conducted in confidence. Some brief session notes may be documented which include the date and session number. During consultations with professional supervisors, client’s names are anonymised. Confidentiality, in accordance with the GDPR (2018), will be maintained and applied to all records with the exception of the following:
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When you have given your permission to share information, for example, statistical data or you write a review.
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In cases where we consider there is a real possibility of serious harm to yourself or others.
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In cases in which information is of such gravity that confidentiality cannot be maintained e.g. safeguarding an adult (adult protection), safeguarding a child (child protection), offences involving children under the age of 18,
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In cases where we have a duty to share information regarding but not limited to, being compelled to give evidence by a court of law.
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If we are required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.
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In cases of terrorism, fraud or money laundering.
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Cookies
Cookies are small text files that are placed on your computer's hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved. Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely. Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use. Our website uses cookies. They are placed by software that operates on our servers, and by software operated by third parties whose services we use. If you choose not to use cookies or you prevent their use through your browser settings, you will not be able to use all the functionality of our website.
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We use cookies in the following ways:
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To track how you use our website
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To record whether you have seen specific messages we display on our website
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To keep you signed in our site
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To record your answers to surveys and questionnaires on our site while you complete them
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Accessing my personal information
You have the right to find out what information we store about you. You can email emmanuel@findyourfeetcic.org.uk ​ to ask for a copy of this information. We may charge a fee for providing this information based on the administrative costs involved.
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Use of Site by Children
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We do not sell products to, or provide services to children, nor do we market to children.
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If you are under 18, you may use our website only with consent from a parent or guardian
How you can complain
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We have endeavoured to create a policy that will be sufficient to assure you of the security of your personal information. However, if you are not happy with our privacy policy or if have any complaints, please feel free to communicate this to us by email and will attempt to address your concerns. Our email address is: emmanuel@findyourfeetcic.org.uk ​
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If a dispute is not settled, then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
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If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner's Office. This can be done at https://ico.org.uk/concerns/
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Review of this Privacy Policy
We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records. If you have any questions regarding our privacy policy, please contact us at emmanuel@findyourfeetcic.org.uk ​