Privacy Policy

Lime Counselling - GDPR & Data Privacy

This privacy policy applies between you, the User of this Website /potential client and Caroline Wright trading as 'Lime Counselling', the owner and provider of this Website. Caroline Wright trading as 'Lime Counselling' takes the privacy of your information very seriously. This privacy policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website.

Please read this privacy policy carefully.

Definitions and interpretation

1. In this privacy policy, the following definitions are used:

Data
collectively all information that you submit to Caroline Wright trading as 'Lime Counselling' via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;

Cookies
a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below ( Cookies);

Data Protection Laws
any applicable law relating to the processing of personal Data, including but not limited to the Directive 96/46/EC (Data Protection Directive) or the GDPR, and any national implementing laws, regulations and secondary legislation, for as long as the GDPR is effective in the UK;

GDPR
the General Data Protection Regulation (EU) 2016/679;

Caroline Wright trading as 'Lime Counselling',
we or us

Caroline Wright trading as 'Lime Counselling' of Lime Counselling, Hampshire;

UK and EU Cookie Law
the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011;

User or you
any third party that accesses the Website and is not either (i) employed by Caroline Wright trading as 'Lime Counselling' and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Caroline Wright trading as 'Lime Counselling' and accessing the Website in connection with the provision of such services;

and

Website
the website that you are currently using, https://www.lime-counselling.com/, and any sub-domains of this site unless expressly excluded by their own terms and conditions.

2. In this privacy policy, unless the context requires a different interpretation:

a. the singular includes the plural and vice versa;
b. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;
c. a reference to a person includes firms, companies, government entities, trusts and partnerships;
d. "including" is understood to mean "including without limitation";
e. reference to any statutory provision includes any modification or amendment of it;
f. the headings and sub-headings do not form part of this privacy policy.

Scope of this privacy policy

3. This privacy policy applies only to the actions of Caroline Wright trading as 'Lime Counselling' and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.

4. For purposes of the applicable Data Protection Laws, Caroline Wright trading as 'Lime Counselling' is the "data controller". This means that Caroline Wright trading as Lime Counselling determines the purposes for which, and the manner in which, your Data is processed.

Data collected

5. We may collect the following Data, which includes personal Data, from you:

a. name;
b. contact Information such as email addresses and telephone numbers;
c. IP address (automatically collected);
d. web browser type and version (automatically collected);
e. operating system (automatically collected);
in each case, in accordance with this privacy policy.

How we collect Data

6. We collect Data in the following ways:

a. data is given to us by you ; and
b. data is collected automatically.

Data that is given to us by you

7. Caroline Wright trading as 'Lime Counselling' will collect your Data in a number of ways, for example:

a. when you contact us through the Website, by telephone, post, e-mail or through any other means;
b. when you use our services;
c. contact form;
in each case, in accordance with this privacy policy.

Data that is collected automatically

8. To the extent that you access the Website, we will collect your Data automatically, for example:

a. we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.
b. we will collect your Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the section below, headed "Cookies".

Our use of Data

9. Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:

a. internal record keeping;
in each case, in accordance with this privacy policy.

10. We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed "Your rights" below).

Who we share Data with

11. Lime Counselling will not share any data provided to the business to any other third-party.

Keeping Data secure

12. We will use technical and organisational measures to safeguard your Data, for example:

a. access to your account is controlled by a password and a user name that is unique to you.
b. we store your Data on secure servers.

13. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: limecounselling@outlook.com.

14. If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

Data retention

15. Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this privacy policy or until you request that the Data be deleted.

16. Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

Your rights

17. You have the following rights in relation to your Data:

a. Right to access - the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is "manifestly unfounded or excessive." Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
b. Right to correct - the right to have your Data rectified if it is inaccurate or incomplete.
c. Right to erase - the right to request that we delete or remove your Data from our systems.
d. Right to restrict our use of your Data - the right to "block" us from using your Data or limit the way in which we can use it.
e. Right to data portability - the right to request that we move, copy or transfer your Data.
f. Right to object - the right to object to our use of your Data including where we use it for our legitimate interests.

18. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: limecounselling@outlook.com.

19. If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner's Office (ICO). The ICO's contact details can be found on their website at https://ico.org.uk/. Caroline Wright trading as 'Lime Counselling' is registered with the ICO and complies with it's data storage and protection policies.

20. It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.

Links to other websites

21. This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.

22. This Website may place and access certain Cookies on your computer. Caroline Wright trading as 'Lime Counselling' uses Cookies to improve your experience of using the Website and to improve our range of services. Caroline Wright trading as 'Lime Counselling' has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.

23. All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.

24. Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling Caroline Wright trading as 'Lime Counselling' to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.

25. This Website may place the following Cookies:

Type of Cookie

Purpose

Strictly necessary cookies. These are cookies that are required for the operation of our website.

Analytical/performance cookies
They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

26. You can find a list of Cookies that we use in the 'Cookies Schedule'.

27. You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.

28. You can choose to delete Cookies at any time; however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.

29. It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.

30. For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.

General

31. You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.

32. If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.

33. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

34. This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.

Changes to this privacy policy

35. Caroline Wright trading as 'Lime Counselling' reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations. You may contact Caroline Wright trading as Lime Counselling by email at limecounselling@outlook.com.

Attribution

36. This privacy policy was created using a document from Rocket Lawyer (https://www.rocketlawyer.com/gb/en).
05 October 2020. It was last updated on 05/01/2022.

Cookies

Below is a list of the cookies that we use. We have tried to ensure this is complete and up to date, but if you think that we have missed a cookie or there is any discrepancy, please let us know.

Strictly necessary

We use the following strictly necessary cookies:
Description of Cookie: Session Cookies
Purpose: We use this session cookie to remember you and maintain your session whilst you are using our website.

Analytical/performance

We use the following analytical/performance cookies:
Description of Cookie: Analytics
Purpose: We use this cookie to help us analyse how users use the website.

GDPR & your personal data:

What is the General Data Protection Regulations 2018 (GDPR) and how does it affect me?

GDPR replaced the 1998 Data Protection Act, which all reputable business abide to. This act protects your personal and confidential data and ensures that it is kept private / stored/ processed in the way that you have agreed to. It is there to protect your rights as a consumer of a service or product that might involve your identifiable data, e.g. your name and address or whether you have a specific condition. It also covers but it not limited to any session records I make, any online sessions we have, any form of communication we have including text messages, social media messages or emails.

How long will you hold my information for?

I will keep your record for 7 years. After this time your records will be completely destroyed. I will delete any email correspondence one month of us ending our working relationship together, however I will retain your personal details, forms, notes and payment information for 7 years to adhere with both my insurance and HMRC regulations.

What if I don’t want my records to be held for that long?

Under GDPR, you can make a request in writing to me, for all your records to be deleted. In this case all your paper records would be shredded and any electronic data will be permanently deleted. I would have to save the request for deletion you made but would not save any other data. Before doing this, I will need to seek advice from my insurance to ensure that I am abiding to their regulations. Once I have been advised, I will of course reply to your request. I will also need to keep full details of any payments you made to me, as your counsellor, to abide with HMRC regulations.

Why do you need to record this information?

I collect small amounts of information about you, purely to support the services that I offer: These are listed below:

Personal contact details
Client & Counsellor working agreement
Why you have come to counselling including a wellbeing questionnaire.
Limited medical information
Named emergency contact details
Session notes
Payment details including amount.

All of the above information enables me to provide a professional service to my clients, ensuring that I am equipped with the knowledge of our sessions and to aid me in clinical supervision. I may need to speak to my clinical supervisor, the emergency services, your GP, or your named emergency contact, if I believe it to be necessary. I will always aim to inform you before I take any action, however, it may not always be possible to do so.

What lengths are taken to ensure my information is held securely?

Hardcopy documents are stored within a locked filing cabinet, which is behind a locked door.

Electronic documents are fully protected by a password, which only I am aware of.

Text / Social media messages are deleted once we start our sessions together and are not stored. My work phone is full secure by secured by a pin number which only I am aware of.

Any emails are stored on the yahoo.com server and to access these either on my computer or telephone, I need a pin number, password and/or access code.

Email attachments - I will send you blank forms to complete prior to commencing sessions with you. These will be password protected and I will inform you of the password once we agree to work together. The forms are then saved on my computer and are fully password protected.

Online working

I use Zoom for online sessions as it is specifically designed to meet the privacy and standards required when working with personal /sensitive information for professional services such as counselling. Information about Zoom's security features can be found here. Zoom's own privacy policy can be found here.

Will our sessions be confidential?

Data protection and confidentiality are important aspects of our working relationship. Anything that is discussed during sessions is kept confidential, however there are extraordinary situations where this may not be the case. If I need to use my professional judgement to determine on whether I must break confidentiality, it will be based on, but not limited to the following criteria:

If in my professional opinion a client is in danger to themselves or others
Anything disclosed in relation to the Children’s Act 2004
Anything disclosed under the Prevention of Terrorism Act 2005
Anything disclosed in relation to drug trafficking / money laundering
If I am ordered by a court of law to release any client confidential information

I may need to speak to my clinical supervisor, the emergency services, your GP, or your named emergency contact, if I believe it to be necessary. I will always aim to inform you. However in order to safeguard you, as my client and those around you, if you were to disclose that you were going to carry out significant harm to yourself or someone else, then I am obligated by law to inform the relevant authorities. This is also part of my commitment to working ethically as a member of the BACP.