Policy updated on 26 June 2020
This policy document explains how we use any personal information we collect about you when you use our online services. These online services include our websites, nominated event booking websites (including Eventbrite) and social media channels. It is a document that will continue to change and develop over time, so please check it regularly. By using our online services, you agree to the terms of this policy.
Any personal data provided by you to Wellspring Scotland through any means (verbal, written, in electronic form, or by your use of our website) will be held and processed in accordance with the data protection principles set out in the Data Protection Act 2018 and the General Data Protection Regulation for the purposes for which you have given consent, to provide the services you have requested from us, and to meet the legitimate interests of the charity.
This policy only applies to data collected by Wellspring staff, therapists, volunteers and trainees and via our own forms and website. Third-party agents, and websites which are linked to ours, are not covered by this policy. If you have any queries concerning your personal information or any questions about our use of the information, please contact the Clinical Managers.
When you request counselling with Wellspring, become an employee, volunteer or trainee with Wellspring, or otherwise provide your personal details to us, you will be asked to consent to our processing of your data under the terms of this policy.
What information do we collect?
Counselling Requests– Registering with us to request access to our counselling service can be done online, on paper or in person. Our request process involves providing us with your name, address, telephone number and email address. We may also request information on your availability, therapeutic issues, GP details and consent to contact them, and other details which we deem relevant to processing your request.
Trainee Placements – Counsellors, receptionists and other trainees may apply for placements by form, letter, or email. They will also be interviewed. We will ask about your background, qualifications, experience, and professional memberships. We also ask for your name, address, telephone number, email address, and address and telephone details for referees and people we may need to contact for you in emergencies.
Employment – In order to apply for job opportunities advertised on our website and elsewhere, and to become an employee of the charity, you will be required to provide your contact details and other personal information (such as employment history and qualifications), as well as contact details of referees. This information is only processed for the purpose of considering your job application, making any offer of employment, and administering your contract of employment.
Donors – The information you give us when making a donation may include your name, postal address, email address, phone number, amount donated, Gift Aid status, and messages.
Website – We use Google Analytics to collect anonymous data relating to user behaviour and ‘web traffic’ statistics. The collection and use of this data by Google Inc. is subject to their own Privacy Policies.
Other Forms – The information you give us on our forms (including all enquiry and application forms) may include your name, postal address, email address, phone number and other messages to us.
What do we use your information for?
We use information held about you in the following ways:
To provide clients with the professional counselling service requested from us.
To enable us to offer appropriate opportunities and support to our counsellors, administrators and other volunteers and trainees.
To offer suitable counselling appointments, and to allocate clients and counsellors for counselling.
To notify you about changes to your appointments and other changes to our services.
To improve our service to ensure that it is provided in the most effective manner for you and for us.
To administer our service, including the arrangement of appointments, the handling of payments and donations, and for financial control, data analysis, research, statistical and survey purposes.
To keep in touch with those who consent to this, for the purposes of organisational, service and professional development.
To fulfil our administrative, legal and contractual obligations as an employer.
What information do we share?
We will not share any information about you with other organisations or people, except in the following situations:
Consent – Wellspring may share your information with professional carers or others whom you have requested or agreed we should contact.
Serious harm – Wellspring may share your information with the relevant authorities if we have reason to believe that this may prevent serious harm from being caused to you or another person.
Compliance with law – Wellspring may share your information where we are required to by law or by the regulations and other rules to which we are subject.
It is necessary to provide your employee details to our payroll management company.
As part of the backups of encrypted data processed and held by professional IT security companies.
How do we keep your information safe?
All information you provide to us is stored as securely as possible. All paper forms and correspondence are kept in locked filing cabinets on our premises. All electronic records are stored securely on a cloud server using the latest firewalls and data security protocols, and all access is by password-protected authentication, or by our IT service provider using secure cloud technology.
Unfortunately, the transmission of information via the internet is never completely secure. Although we will do our best to protect your information using industry-standard protocols and encryption, we cannot guarantee the security of your data transmitted to us via email, including forms completed on our website which are transmitted by email; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Your identifiable personal information is kept separately from any session notes and other descriptive material. Client notes and other documentation are destroyed 7 years after the end of counselling. Gift Aid declarations are destroyed/deleted after 7 years, and personal contact details are destroyed/deleted after 7 years of no contact or updates.
You have the right to ask us to provide a copy of the information held by us in our records. You also have the right to require us to correct any inaccuracies in your information. If you would like to do this, please contact the Clinical Managers.
You may withdraw your consent for us to hold and process your data at any time. However, if you do this while actively receiving counselling at Wellspring, your counselling would have to end. You can withdraw your consent by contacting the Clinical Managers.
Google Analytics – Like hundreds or thousands of websites you visit, we use Google Analytics to collect generic, anonymous data from all visitors to monitor how our website is used. This data is shared with Google in return for the service they provide.
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Changes to this policy
We may edit this policy from time to time. If we make any substantial changes we will notify you by posting a prominent announcement on our website.