Privacy Policy

1. Introduction

This privacy notice provides you with details of how we collect and process your personal data through your use of our site www.csrnet.org.uk and our connected sites (including www.goodneighbours.org.uk and www.allsaintscounselling.org.uk) including any information you may provide.

By providing us with your data, you warrant to us that you are over 13 years of age.

CSR is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

We have appointed a nominated person who is in charge of privacy related matters for us. If you have any questions about this privacy notice, please contact them using the details set out below.

Contact Details

Our full details are:
The Director of Social Enterprise and Engagement
Portsmouth Diocesan Council for Social Responsibility

Email address: data@csrnet.org.uk

Postal address: CSR, 1^st Floor Peninsular House, Wharf Road, Portsmouth, PO2 8HB

If you are not happy with any aspect of how we 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). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us using the above information.

2. What data do we collect about you

Personal data means any information capable of identifying an individual. It does not include anonymised data.

We may process certain types of personal data about you as follows:

• Identity Data may include your first name, maiden name, last name, username, marital status, title, date of birth and gender. It may also include data such as passport, utility bills and other identifying data when requesting access to records.
• Financial Data may include information about your current financial position for fee based treatment assessments
• Contact Data may include your billing address, delivery address, email address and telephone numbers.
• Medical Data may include GP details, any medical conditions, drug or alcohol,
  

Sensitive data

We may collect Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, information about your health. We may also collect information about criminal convictions and offences.

We may need to collect the following sensitive data about you in order to provide you with the counselling support offered.

• Medical Data

We require your explicit consent for processing sensitive data, so when you submit your details, we will send you a further communication asking for you to confirm your consent to this processing.

Where we are required to collect personal data by law, or under the terms of the agreement between us and you do not provide us with that data when requested, we may not be able to perform the agreement (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.

3. How we collect your personal data

We collect data about you through a variety of different methods including:

• Direct interactions: You may provide data by filling in forms or by communicating with us by post, phone, email or otherwise, including when you:
  • Book appointments
  • Have an assessment
• Third parties or publicly available sources: We may receive personal data about you from various third parties. For details on who sends us data about you please do contact us.
• We do not share your data with any party unless we have a legal basis to do so or when your rights override that request.

4. How we use your personal data

We will only use your personal data when legally permitted. The most common uses of your personal data are:

• Book appointments
• Have an assessment
• Subscribe to our services (e.g. Good Neighbours e-learning portal)

Our legal basis options are:

1. Consent – i.e. to share medical data
2. Legal Obligation – i.e. required by law
3. Contract – i.e. formal agreement between us
4. Vital Interest – i.e. life or death situation
5. Public Interest – i.e. public event
6. Legitimate Interest – i.e. to share information as part of the services we offer

Purposes for processing your personal data

Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.

We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us at: data@csrnet.org.uk if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing communications

We do not send marketing communications but we may opt to email you communications about our relationship together. You may have the option to opt out of this where other communication methods are available when it is pertinent to providing the service to you that we do.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us as above. In doing so we will need to demonstrate why the use your personal data for a purpose unrelated to the purpose for which we collected the data. We would always seek to notify you in advance and explain our new legal ground of processing.

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:

• Other companies in our group who provide IT and system administration services and undertake leadership reporting.
• Service providers who provide IT and system administration services.
• Professional advisers including counsellors, medical professionals.
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

6. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

8. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

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 us at data@csrnet.org.uk.

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

We may need to request specific information from you to help us 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. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.