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Privacy Policy

1. Introduction

This privacy policy provides you with details on how Amy Thomas-Owen (referred to as ‘I’, ‘me’, ‘my’ in this policy) collects and processes your personal data through your use of this site www.seasonschangetherapy.com and through your use of any other online platforms you may use to communicate with me e.g. Psychology Today, 1Mind

This statement applies to your initial point of contact through to therapeutic services you may engage in.

​Amy Thomas-Owen is the data controller and is responsible for your personal data .

The information that I collect varies according to your type of interaction with me e.g. enquiry, consultation, therapeutic services.

No information gathered directly by me will be shared with third parties and will remain completely confidential except where I have legitimate concerns about your safety or the safety of someone else.

I follow the ethical guidelines of the British Association of Counselling and Psychotherapy (BACP) and I am registered with the Information Commissioner's Office (ICO) registration reference ZB427904.

Contact Details

Name: Amy Thomas-Owen

Email: amy@seasonschangetherapy.com

2. The Data I Collect and Why

Information Collected Automatically

What: information about you and the device you use to access the website. This may include data such as IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website and any actions you take whilst on the website. The source of this data is provided by Wix.com and Google Analytics

Why: this information is collected in order to operate and maintain the website, to identify you as a user of the website, to track and measure the performance of the website and to protect, investigate and deter against unauthorised/illegal activity. It is also used to maintain databases and to enable the publication and administration of the website and online services and business. The legal grounds for processing this information is to be able to properly administer the website and business and to also inform marketing strategy and business growth.

Information You Submit Voluntarily

Enquiries & Accessing Free Resources

What: information you submit through a contact form on this website or another platform (1Mind, Psychology Today) or by emailing me directly and information you submit when signing up to a newsletter or by downloading a free resource. I will collect your name, source of enquiry and date.

Why: this information is used to communicate with you, to measure or understand the effectiveness of marketing strategy and for the purposes of record keeping. It is used to reply to any communication that you send to me, to send you promotional material in the form of newsletters and/or resource downloads (where relevant) and to communicate with you regarding administrative functions such as confirmation emails, policy updates and technical notices. The legal grounds for processing this data is is the legitimate interests which are to decide our marketing strategy, to reply to communications you send, to provide services and to take steps towards entering into a contract at your request.

 

Newsletters

The newsletters sent may contain tracking pixels, embedded in the emails allowing me to analyse online marketing campaigns. I am able to see if and when you open an email and if you click on any links. This allows me to adapt the website in the interests of the user. This data will not be passed on to third parties.

Introductory Call

What: information you share during a free introductory call which includes full name and email address and sometimes preferred name, pronouns and telephone number. I will also collect information regarding your reasons for seeking therapy, your previous experience of counselling/therapy (if any), and any other information that is relevant or that you would like me to know e.g. disability and support needs, neurodivergence, personal history etc.

Why: This data is process for the purposes of providing an appropriate service and for recording keeping. The legal grounds for processing this data is to be able to enter into a contract to provide a service at your request and in order to fulfil my contractual commitment to work in accordance with the BACP's Ethical Framework for the Counselling Professions.

Therapeutic Services

What: Personal Health Information (PHI) will be collected including, your full name, preferred name, pronouns, date of birth, address, telephone and alternative telephone number (if relevant), email address, emergency contact information and GP contact information. I will also collect information regarding your current medication and any history of suicidal thoughts and attempts. I will keep records of your appointments, brief session notes on the topics covered during sessions and any letters concerning you. All information is stored on a secure cloud based server and/or password protected computer. Your personal (identifiable) information will be kept separately from your session notes, which will be anonymised using a numerical coding system.  All information will be kept completely confidential and not shared with third parties unless I have concerns over your safety or the safety of someone else or I am subpoenaed by the courts.

Why: This is information is processed for the purposes of providing an appropriate service, to protect your safety and the safety of others and for the establishment, pursuance or defence of complaints/legal claims. The legal grounds for processing this data is to be able to fulfil my contractual obligations, to fulfil my contractual commitment to work in accordance with the BACP's Ethical Framework for the Counselling Professions and for the establishment, pursuance and defence of complaints/legal claims. 

3. Data Retention

Automatically collected data will be recorded indefinitely. Any data that you submit voluntarily will be kept for the duration needed to provide the service to you or until you withdraw/opt-out or for 12 months if no further contact is made. For example, you submit an enquiry about engaging in therapeutic services but do not make any further contact – your information will be stored for 12 months and will then be deleted.

In the case of counselling records (session notes & attendance), insurance companies and ethical bodies require records to be kept for a period of 7 years post termination of therapy (only relevant to 'therapeutic services') before being destroyed.

 

When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

 

For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.

In some circumstances we may anonymise your personal data for research or statistical purposes in which
case we may use this information indefinitely without further notice to you.

 

4. Data Security

Security measures have been put in place to prevent your data from being accidentally lost, used, altered, disclosed or accessed without authorisation.

5. Third Party Services

This website includes links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. This privacy policy does not apply to them as I do not have control over them – please refer to their individual privacy policies for further information.

 

Google Analytics 

I use this service to track website usage and view information such as referring websites and user actions on the website. Google Analytics may collect your IP address but no other personal information is collected.
 

6. Your Rights

Under data protection laws you have rights in relation to your personal data that include the right to:

  • access your data

  • have your data corrected

  • be forgotten (erased)

  • restrict processing in certain circumstances

  • transfer data across different services

  • object to processing in certain circumstances

  • withdraw consent(where relevant)

  • to complain to the Information Commissioner’s Office (ICO)

Under the General Data Protection Regulations 2018, relevant to Seasons Change Therapy you have certain rights:

  • to be informed about the collection and use of personal data

  • to access your personal data

  • to have records amended (e.g. change of name/address)

  • to be forgotten (erasure) except where exclusions apply

  • to restrict processing of your data

 

In particular, you may request:

  • to see your sessions notes. This is facilitated by submitting a formal written request.

  • to have your records amended (e.g. change of name and address).

  • to be forgotten (with below exception)

Right to be forgotten - exclusion

Under GDPR you may request that your data be erased, however there are exceptions to this. In the case of counselling records (session notes & attendance), insurance companies and ethical bodies require records to be kept for a period of 7 years post termination of therapy before being destroyed. All information will be kept completely confidential and will not be shared with any third parties unless I have legitimate concerns about your safety or the safety of someone else or I am subpoenaed by the courts.

 

You can see more about these rights at:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

 

If you wish to exercise any of the rights set out above, please email me at
amy@seasonschangetherapy.com

 

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, I may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.

 

I may need to request specific information from you to help me confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. I may also contact you to ask you for further information in relation to your request to speed up our response.

 

I try to respond to all legitimate requests within one month. Occasionally it may take me longer if your request is particularly complex or you have made a number of requests. In this case, I will notify you.

 

If you are not happy with any aspect of how I collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). If you do have a complaint, I would appreciate you contacting me first so that we can try to resolve it for you.

 

There are situations where I may need to retain certain information, including when required by law e.g. the law requires that I keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.

 

7. Cookies

This website uses cookies and is hosted on the Wix.com platform. Wix.com uses cookies in order to:

  • provide a great experience for site visitors.

  • monitor and analyse the performance, operation and effectiveness of Wix's platform.

  • ensure the platform is secure and safe to use.

 

The data that Wix.com collects through cookies may be stored through Wix.com’s data storage, databases and the general Wix.com applications. Wix.com stores this data on secure servers behind a firewall. This information collected by cookies does not usually directly identify you but aims to improve and personalise your experience of the website. I do not collect any personally identifiable information about you from cookies. Some cookies are essential in order to operate the site however, you have the option of disabling some types of cookies.

Cookies operate through your web browser e.g. Google Chrome, Mozilla Firefox and most browsers allow you to block and/or remove cookies. The methods for doing so depends on your browser. To obtain up-to-date information about blocking and deleting cookies from your browser type “block cookies [insert browser name]”. Blocking all cookies generally impacts upon the usability of the website.

For more information about cookies generally please see All About Cookies.

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