Privacy Policy

This privacy policy applies between you, the User of this Website, and Gracious Therapy, the owner and provider of this Website. Gracious Therapy 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.

Your privacy is very important to me and you can be confident that your personal information will be kept safe and secure and will only be used for the purpose it was given to me. I adhere to current data protection legislation, including the General Data Protection Regulation (EU/2016/679) (the GDPR), the Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
This privacy notice tells you what I will do with your personal information from initial point of contact through to after your therapy has ended, including:

  • Why I am able to process your information and what purpose
    I am processing it for
  • Whether you have to provide it to me
  • How long I store it for
  • Whether there are other recipients of your personal
    information
  • Whether I intend to transfer it to another country,
  • Whether I do automated decision-making or profiling, and
  • Your data protection rights.
    I am happy to chat through any questions you might have about
    my data protection policy and you can contact me via email hello@gracioustherapy.co.uk
    ‘Data controller’ is the term used to describe the person/
    organisation that collects and stores and has responsibility for
    people’s personal data. In this instance, the data controller is
    me, Naomi Sinclair.
    I am registered with the Information Commissioner’s Office
    [Ref: ZB533422].

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 Gracious Therapy 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 GDPR, and any national implementing and supplementary laws, regulations and secondary legislation;
    • GDPR
      the UK General Data Protection Regulation;
    • Gracious Therapy,
      we       or us
      Gracious Therapy of 1 Harrowby Road, Merseyside, L21 1DP;
    • 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 & the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2018;
    • User or you
      any third party that accesses the Website and is not either (i) employed by Gracious Therapy and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Gracious Therapy and accessing the Website in connection with the provision of such services; and
    • Website
      the website that you are currently using, https://www.gracioustherapy.co.uk/, 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:
    1. the singular includes the plural and vice versa;
    2. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;
    3. a reference to a person includes firms, companies, government entities, trusts and partnerships;
    4. “including” is understood to mean “including without limitation”;
    5. reference to any statutory provision includes any modification or amendment of it;
    6. the headings and sub-headings do not form part of this privacy policy.

Scope of this privacy policy

  1. This privacy policy applies only to the actions of Gracious Therapy 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.
  2. For purposes of the applicable Data Protection Laws, Gracious Therapy is the “data controller”. This means that Gracious Therapy determines the purposes for which, and the manner in which, your Data is processed.

The GDPR states that I must have a lawful basis for processing your personal data. There are different lawful bases depending on the stage at which I am processing your data. I have explained these below:
– If you have had therapy with me and it has now ended, I will use legitimate interest as my lawful basis for holding and using your personal information.
– If you are currently having therapy or if you are in contact with me to consider therapy, I will process your personal data where it is necessary for the performance of our contract.
– The GDPR also makes sure that I look after any sensitive personal information that you may disclose to me appropriately. This type of information is called ‘special category personal information’. The lawful basis for me processing any special categories of personal information is that it is for provision of health treatment (in this case counselling) and necessary for a contract with a health professional (in this case, a contract
between me and you).

Data collected

  1. We may collect the following Data, which includes personal Data, from you:
    1. name;
    2. contact Information such as email addresses and telephone numbers;
    3. IP address (automatically collected);
    4. web browser type and version (automatically collected);
    5. operating system (automatically collected);
    in each case, in accordance with this privacy policy.

How we collect Data

  1. We collect Data in the following ways:
    1. data is given to us by you; and
    2. data is collected automatically.

Data that is given to us by you

  1. Gracious Therapy will collect your Data in a number of ways, for example:
    1. when you contact us through the Website, by telephone, post, e-mail or through any other means;
    2. when you elect to receive marketing communications from us;
    3. when you use our services;
    in each case, in accordance with this privacy policy.

Data that is collected automatically

  1. To the extent that you access the Website, we will collect your Data automatically, for example:
    1. 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.
    2. 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

  1. 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:
    1. internal record keeping;
    in each case, in accordance with this privacy policy.
  2. 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).

Initial contact.
When you contact me with an enquiry about my counselling services I will collect information to help me satisfy your enquiry. This will include your name, preferred contact no and email, your address, an emergency contact, GP address and contact. Alternatively, your GP or other health professional may send me your details when making a referral or a parent or trusted individual may give me your details when making an
enquiry on your behalf.

If you decide not to proceed I will ensure all your personal data is deleted within one month. If you would like me to delete this information sooner, just let me know.

While you are accessing counselling.
Rest assured that everything you discuss with me is confidential. That confidentiality will only be broken if I have a legal obligation to disclose the information shared. These include:

  • If you or anyone else is at risk of serious harm or abuse.
  • Something that you mention breaks one of these 4 laws:
  1. The Prevention of Terrorism Act 2005
  2. Money Laundering Regulations 2017
  3. Drugs Trafficking Act 1994
  4. Protection of Children’s Act 1999
  • Or, if I received a court order or subpoena for any notes made.

I will always try to speak to you about this first, unless there are safeguarding issues that prevents this.

I will keep a record of your personal details to help the counselling services run smoothly. These details are kept securely in a password protected file, on a password encrypted computer and are not shared with any
third party. I will keep written notes of each session, these are kept at my business address, in a locked filing cabinet for 5 years, and are then destroyed, as per my insurance policy.
For security reasons I do not retain text messages for more than one month, and I do not store client contact numbers onto my mobile phone. I ask, for this reason, that communication is made primarily via my business email. Email correspondence will be deleted after one month if it is not important. Any relevant information on emails that needs to be kept as part of the counselling process, will be kept until the ending of the sessions.
After counselling has ended, your personal details will be be removed & deleted, and only your notes will be kept for the required insurance time frame, and then destroyed. I will also keep a record of your name, and which coded notes they correspond to.

Keeping Data secure

  1. We will use technical and organisational measures to safeguard your Data, for example:
    1. access to your data is controlled by a password and a coded user name that is unique to you.
    2. we store your Data on secure servers.
  2. 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: hello@gracioustherapy.co.uk.
  3. 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

  1. 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.
  2. Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

Your rights

  1. You have the following rights in relation to your Data:
    1. 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.
    2. Right to correct – the right to have your Data rectified if it is inaccurate or incomplete.
    3. Right to erase – the right to request that we delete or remove your Data from our systems.
    4. 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.
    5. Right to data portability – the right to request that we move, copy or transfer your Data.
    6. Right to object – the right to object to our use of your Data including where we use it for our legitimate interests.
  2. 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: hello@gracioustherapy.co.uk.
  3. 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/.
  4. 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.

If you have any complaint about how I handle your personal data please do not hesitate to get in touch with me by writing or emailing to the contact details given above. I would welcome any suggestions for improving my data protection procedures.
If you want to make a formal complaint about the way I have processed your personal information you can contact the ICO which is the statutory body that oversees data protection law in the UK. For more information go to ico.org.uk/make-a-complaint.

Links to other websites

  1. 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.

Changes of business ownership and control

  1. Gracious Therapy may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Gracious Therapy. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us.
  2. We may also disclose Data to a prospective purchaser of our business or any part of it.
  3. In the above instances, we will take steps with the aim of ensuring your privacy is protected.

Cookies

  1. This Website may place and access certain Cookies on your computer. Gracious Therapy uses Cookies to improve your experience of using the Website and to improve our range of services. Gracious Therapy has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.
  2. All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.
  3. 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 Gracious Therapy 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.
  4. This Website may place the following Cookies:
    • Strictly necessary cookies
      These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
    • 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.
    • Functionality cookies
      These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region). By using the Website, you agree to our placement of functionality cookie.
  5. You can find a list of Cookies that we use in the Cookies section.
  6. 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 see the help menu in your internet browser. You can switch off Cookies at any time, however, you may lose any information that enables you to access the Website more quickly and efficiently.
  7. 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.
  8. 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.
  9. 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

  1. 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.
  2. 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.
  3. 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.
  4. 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

  1. Gracious Therapy 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 Gracious Therapy by email at hello@gracioustherapy.co.uk.

Document Date

This privacy policy was created on 19 January 2023.

Comments

When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymised string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service Privacy Policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Media

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Cookies

If you leave a comment on our site you may opt in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.