Professional:

We abide by the British Association for Counselling and Psychotherapy’s Ethical Framework for the Counselling Professions:

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

The Harlow’s policies and procedures are informed by this framework and best practice guidance.

Staff:

All staff have enhanced checks with the DBS service prior to providing services.

All practitioners are individual members of appropriate professional organisations and are accountable for their work.

Information governance:

Harlow Therapies Ltd is registered as a Data Controller with the Information Commissioner’s Office (ICO).

ICO reference number: ZB3242

The Harlow complies with all the requirements of the General Data Protection Regulations (GDPR).

This Privacy Notice was last updated on 15/07/2022 and is applicable to all companies under Harlow Therapies Limited, trading as ‘The Harlow’.

When we update this notice, we will post details on our website.

This privacy notice is for clients who are receiving, or have received, services from The Harlow. A separate privacy notice for colleagues (affiliates and employed staff) is available on request.

We take confidentiality and data protection seriously; this means that we take great care to respect your rights and ensure that your information is managed appropriately. Harlow Therapies Limited complies with the General Data Protection Regulation (GDPR, 2016) and is registered as a Data Controller with the Information Commissioners Office (www.ico.org.uk).

This Privacy Notice covers:

• How we collect and use personal data
• What personal data we collect
• How we store your personal information
• Protection of your personal information
• How we use your personal information
• Disclosure to third parties
• Accuracy and retention of personal information
• Access to Personal Information
• Additional rights

1. How we collect and use personal data

We collect personal data about our clients and users of our services. Personal data is any information that can be used to identify you.

You may be asked to provide your personal information anytime you are in contact with us. We and our staff and affiliates may share this personal information with each other and will always use it in accordance with this Privacy Notice. We may also combine it with other information to provide and improve our services.

For the provision of services such as therapy and coaching we will gather additional personal and sensitive information which are necessary for practitioners to supply the agreed services.

You are not required to provide any personal information that we may request. However, if you chose not to do so, in some cases, we will not be able to provide you with our services or respond to any queries you may have.

The CCTV system (located at the entrances to the premises) capture images of people in and around where a camera is located. Our cameras are fixed and we do not operate any hidden CCTV.

We use CCTV to:
• Manage security at the entrance/exit to the premises
• Promote safety and enhance a sense of safety
• Protect The Harlow’s property
• Assist in investigation of any untoward incidents

2. What personal data we collect

When you contact us, we may collect a variety of information. Here are some examples of the types of personal information we may collect:

• Name
• Date of birth
• Address
• Telephone number
• Email address
• Contact preferences
• Payment information (such as credit card, bank account details)
• Physical and mental health information
• Marital Status
• Gender
• Racial or ethnic origin

During the course of your relationship with us we will keep information about you in your personal records, together with details of any counselling, therapy, coaching, workshops or other sessions that you attend.

Additional personal and sensitive information we may collect from you could include:
• Reasons for referral and information supplied by a referrer or medical advisor. This may include certain health information.
• The information supplied by you at first contact and in your assessment session (where appropriate); with additional information from professionals where applicable.
• Assessments and plans relating to your treatment.
• Summaries of the content of counselling, therapy/coaching/other sessions.
• Copies of any letters or emails sent to you or received from you.
• Details of any contacts you have with us, including sessions and telephone conversations.
We collect this personal information in order to provide services to you (including communicating with you, your referrer and medical advisors as appropriate).
The lawful basis for processing the data and information we collect about you for the services we provide, is based on your consent and/ or in accordance with the performance of our agreement in supplying services.

In addition, we capture CCTV images of everyone who approaches the entrances to our buildings. This is in the public interest and is a necessity for providing our services in keeping with health and safety requirements.

3. How we store your personal information

The personal information we collect is mostly stored in electronic format with occasional notes being compiled by hand and transferred to our secure database. Whether stored in electronic or paper format, we have appropriate and adequate technical and administrative processes in place to make sure that all your information is kept secure.

4. Protection of your personal information

We take the security of your personal information very seriously. To make sure your personal information is protected, we have a series of technical and administrative measures in place. Access is limited only to those colleagues who need to access it to provide services to you.

All members of staff and affiliate practitioners are required to abide by our data protection and confidentiality policy. Our privacy and security guidelines and processes are communicated to everyone with access to our personal data that we hold. These privacy safeguards are monitored and strictly enforced.

All data is stored on servers within data centres in the UK, although at times they may be temporarily outside the UK but within the European Economic Area or within the USA and covered by the safe harbour agreement.

5. How we use your personal information

The personal information we collect and store about you allows us to provide services to you. We also use it to help us to develop, operate, deliver, and improve the quality or type of services we offer.

We may also use personal information for internal purposes such as auditing, data analysis, and research to improve our services and our communication with you. If you don’t want to be contacted by us after you are no longer using our services, you can opt out anytime by letting us know.

We will not sell, share or give information to third parties for marketing purposes.

6. Disclosure to third parties

We will only share your personal information with third parties in the following circumstances:

• Where you have given your consent to the information being shared;
• Where there are serious concerns about the health and safety of yourself or others; or
• Where there is a legal requirement or responsibility to share the information or it is deemed to be in the ‘public interest’.

Your personal information may also need to be shared with third parties to make arrangements for the funding and/or payment of services received (e.g. if your sessions are funded by an insurer or other third party).

Our website operates with third-party suppliers who may also use cookies on our site, for example, Twitter and Facebook. They have full responsibility for these cookies, if you want further information about these cookies, and how they use your information please visit their website.
7. Accuracy and retention of personal information

We wish to make it easy for you to keep your personal information accurate, complete, and up to date. If any of your information changes please let us know so that we can update our records.

We are legally required to hold certain information about you for a set period of time (e.g. in case of complaint and for legal purposes). All personal information will be deleted or securely destroyed at the appropriate time and we will not keep your personal information for longer than is required or permitted by law.

8. Access to personal information

You are entitled to see what personal information we hold about you at any time. This Privacy Notice outlines the information we hold about you and why. If you wish to access your personal information, please contact us at the address below.

We are not required to process any request for access which is vexatious, or if it affects the privacy of others, or for which access is not otherwise required by law. We will let you know in writing if any of these circumstances apply to your request.

9. Additional rights

At any point while we are in possession of your personal information, you have the following rights:
• Right of access – you have the right to view or request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct factual information that we hold about you that is inaccurate or incomplete.
• Right to erasure – in certain circumstances you can ask for the data we hold to be erased from our records; however there are limits to how far we have to comply.
• Right to restriction of processing – in certain conditions you have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling.

If you wish to exercise any of these rights, please let us know.
You can find out more about your rights under the UK’s data protection laws at www.ico.org.uk

Privacy questions and concerns

If you have any questions or concerns about this Privacy Notice or how we process your information please contact us:

Email: info@theharlow.co.uk

Postal address:
Data Protection Officer
The Harlow
1 Cardale Park
Beckwith Head Road
Harrogate
HG3 1RZ

We take data security extremely seriously and we will respond to your queries or concerns as soon as practically possible. If you are unsatisfied with the reply you receive, you may refer your complaint to the Information Commissioner’s Office (www.ico.org.uk)