This is our updated Privacy Policy, which sets out how we handle your personal information if you’re a WDP client or visitor to our website, in accordance with the General Data Protection Regulations (GDPR), effective from 25th May 2018.
These regulations aim to increase the accountability of organisations who handle personal data. Individuals are granted specific rights regarding their personal information, and how it is collected, stored, used, shared and protected. You can read more about the GDPR requirements on the Information Commissioner’s Office website.
We’ve tried to make this policy as transparent and ‘readable’ as possible. If you don’t understand any part of it, think that something in this policy is wrong or missing, or have any questions regarding your personal data, please contact us.
Definitions
- We, us or The West Dorset Practice – this business and the people directly involved in running it.
- Policy – this Privacy Policy.
- Our website or site – this website
- Client – any person or company who uses our services.
- Visitors – any person who visits our website or social media profiles
- Our services – therapy, counselling, assessment, consultation, supervision & training
The type of personal information we collect
- Names, email addresses and telephone numbers when someone requests an initial consultation or becomes a client (usually via our website or in person/by phone).
- Details of the business/organisation and the proposed service for the preparation of a quotation (usually via email or by post).
- IP addresses, location (by country), browser type and other web analytics data when someone visits our website.
- General queries via a general contact form on our website.
How we collect personal information
We collect personal information directly when you provide it to us – as described above- or automatically as you navigate through the website
Why we collect your personal information
We need to collect and use your personal information:
- To fulfil our contractual obligations to our clients and to carry out our services.
- To create and send invoices for completed work or provision of services to our clients.
- To verify identity and prevent unauthorised access to websites or services.
- To monitor visitor traffic to our site and secure our site against malicious human and automated visitors
- We also need to collect personal information where this is necessary for purposes which are in our legitimate interests.
These interests include:
- Operating our website
- Protecting our website
- Providing you with services described on the website.
- Carrying out technical analysis to determine how to improve our website and the services we provide or resolve any technical problems.
- Monitoring activity on our sites, in order to identify potential fraudulent activity and prevent spam and ‘hacking’
- To ensure compliance with our website Terms of Use.
- Managing our relationship with you, e.g. by responding to your comments or queries submitted to us on our website or asking for your feedback.
- Managing our legal and operational affairs (including, managing risks relating to content and fraud matters).
- Improving our products and services.
- Providing general administrative and performance functions and activities.
- Providing clients with important information about changes to products and services e.g. forthcoming holiday dates and emergency contact procedures, changes to website requirements, regulations or ‘best practice’ guidance.
- We may be required by law to collect personal information when responding to requests by government, a court of law, or law enforcement authorities conducting an investigation.
When we disclose your personal information
We do not usually need to disclose your personal information to any third party in order to deliver our services.
There may be certain circumstances in which we need to disclose your personal information, for example:
- To regulators and government authorities in connection with our compliance procedures and obligations.
- A purchaser or prospective purchaser of all or part of our assets or our business, and their professional advisers, in connection with the purchase.
- A third party to respond to requests relating to a criminal investigation or alleged or suspected illegal activity.
- A third party, in order to enforce or defend our rights, or to address financial or reputational risks.
- A rights holder in relation to an allegation of intellectual property infringement or any other infringement.
- Other recipients where we are authorised or required by law to do so.
If we were required to disclose your personal information at any time, you would always be informed.
Where we transfer and/or store your personal information
We are based in the United Kingdom, and your data is processed and stored in a single location (a private office) in the United Kingdom.
How we keep your personal information secure
We do our best to keep all information secure, especially any personal data. Most of our data is kept in digital form. All digital personal information (including names, addresses, telephone numbers and email addresses) is stored on a protected local computer network, to which only people engaged in activities directly relating to the business have access. The internet connection, local area network (LAN), computer terminals and documents containing personal data are all password protected and never routinely shared via email or stored on ‘cloud’ services.
Our website is secured by an SSL Certificate which uses end to end encryption on every page. We have a website security package which includes a firewall, ‘brute force’ attack protection, file system and database enhanced security and an instant alert system which notifies us of any unexpected changes to our website files and database.
Our host provider is UK-based company with a UK-based data centre with biometric passkeys and 24/7 security.
Our back up procedure involves the copying of personal and other data locally (not via WIFI/internet or any ‘cloud’ services), to cabled, physical external hard drives. These back up drives are kept separately in locked, secure locations to which only the business owner has access.
Very occasionally we collect personal data in hard copy form, usually during a consultation when we’re collecting information in order to provide a quotation. These documents are destroyed as soon as the information has been transferred to digital form.
In the meantime (i.e. in between writing notes and making them digital) that we do hold paper copies of files in a locked filing cabinet. We are required by our governing bodies e.g. BPS, BABCP to keep clinical information and not to destroy it, where in such cases i.e. after the client is discharged we would archive the information for a period of 3 years.
Third Party Services
We occasionally use third party services as part of providing services to our clients. Some of these have access to your personal information – either provided by us or by you. These third parties include:
20i.com – hosting provider and domain registrar. We will provide personal data (including name, address and telephone number) as required by UK and international law for domain registration purposes only. We do not need to provide clients’ personal information for web hosting services. Clients may collect, process and store their own and their customers/clients personal information on the 20i hosting system, and should include details in their own privacy policies. You can read the 20i Privacy Policy here.
AwStats – website analytics application. AwStats is an ‘open source’ log file analyser, which operates on the website server, collecting and logging website traffic information. It does not use cookies, or any kind of tracking code, and collects anonymous data which helps us to monitor visitor traffic to our website.
Baloogi Studio – our web developer. May require access to website general contact form (or other form) submissions when conducting updates or maintenance, or troubleshooting technical issues.
Communications regarding your personal information
Where we have your consent to do so (e.g. if you have subscribed to an email newsletter), we send you communications by email about products and services that we feel may be of interest to you. You can ‘opt-out’ of such communications if you would prefer not to receive them in the future by using the “unsubscribe” facility provided at the bottom of the communication itself.
You also have choices about cookies. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject cookies some parts of our sites may not work properly in your case. You can find out more about what cookies are at the All About Cookies website.
Cookies and web analytics
We use AwStats (which does not use cookies or tracking codes) to collect anonymous web traffic data, such as:
- Your IP address or proxy server IP address
- The domain name you requested
- The name of your internet service provider is sometimes captured depending on the configuration of your ISP connection
- The date and time of your visit to the website
- The length of your session
- The pages which you have accessed
- The number of times you access our site within any month
- The file URL you look at and information relating to it
- The website which referred you to our site
- The operating system which your computer uses.
We may in the future choose to install cookie-based analytics and tracking code (eg Google Analytics tracking code or Facebook ‘pixels’) on our website, and some elements of the website framework may use cookies. We therefore include of a ‘Cookies Declaration’ (in accordance with the PECR 2011).
How you can access your personal information
Under the GDPR guidelines, you have the right to:
- Request access to the personal data we hold about you.
- Request corrections of any errors in that data.
- Request erasure of the personal data we hold about you.
- To make any of these requests, please contact us via our general enquiries form.
Information about children
Our website and services are not suitable for children under the age of 16 years, so if you are under 16 we ask that you do not use our website or give us your personal information.
If you are from 16 to 18 years, you can browse our site but you’ll need the supervision of a parent or guardian to request a quotation or become a client. It’s the responsibility of parents or guardians to monitor their children’s use of our website.
Information you make public or give to others
If you make your personal information available to other people, we can’t control or accept responsibility for the way they will use or manage that data. There are lots of ways that you can find yourself providing information to other people, like when you post a public message on a forum thread, share information via social media, or make contact with another via a website or directly by email. Before making your information publicly available or giving your information to anyone else, think carefully. If you’re sharing information via another website, check the privacy policy for that site to understand its information management practices.
How long we keep your personal information
We retain your personal information for as long as is necessary to provide the services to you and others, and to comply with our legal obligations. If you no longer want us to use your personal information or to provide you with our services, you can request that we erase your personal information. Please note that if you request the erasure of your personal information we may retain some information from deleted accounts (in a static, archived form) as necessary to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce the Terms of Use and take other actions permitted by law. The information we retain will be handled in accordance with this Privacy Policy.
When we need to update this policy
We will need to change this policy from time to time in order to make sure it stays up to date with the latest legal requirements and any changes to our privacy management practices. When we do change the policy, we’ll notify you about the changes, via our newsletter (if we have your consent) or here on this page. A copy of the latest version of this policy will always be available on this page.
How you can contact us
If you have any questions about our privacy practices or the way in which we have been managing your personal information, please contact us.
Alternatively, you can write to us at:
West Dorset Practice Ltd
Armitage House
Victor Jackson Avenue
Poundbury
DT1 3GY
United Kingdom
Reporting Concerns
If you have unresolved concerns you also have the right to complain to data protection authorities. In the UK, the relevant authority is the Information Commissioner’s Office.