Open Minds Counselling Service may update this policy.
You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from 20.05.18.
Open Minds Counselling Service is a registered Charity number: 1155119.
We comply with the Data Protection Act 1998. All electronic communications are made in accordance with The Privacy and Electronic Communications (EC Directive) Regulations 2003.
Open Minds Counselling Service is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified, then you can be assured that it will only be used in accordance with this privacy statement.
Open Minds Counselling Service’s data protection officer is Helen Mason
You have the right to withdraw consent at any time.
Open Minds is the data controller
The data subject is any person whose information we hold or process
Open Minds’ basis for processing information under article 6 of Regulation (EU) 2016/679 (General Data Protection Regulation) is as follows:
the data subject has given consent to the processing of his or her personal data for one or more specific purposes
You as the data subject give consent for us to process basic information about you in order for us to contact you about appointments, scheduling and service provision.
We can offer you services without this consent but it does mean that we will not be able to inform you of changes to your appointments.
You have the right to withdraw consent at any time. This will not prevent you accessing services from Open Minds.
However consent does not apply to every aspect of Open Minds’ information processing. In some areas of information processing we refer to point 2 below.
processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
Open Minds requires you to enter into a contract with us as service provider. This contract specifies the nature of the service we are providing to you, for example counselling or training.
We require your information in order to assess whether the service we are providing is most suitable to address your needs.
We also require basic information about you to allow us to complete referrals or safeguarding if these are required. This also fits into point 3 below.
processing is necessary for compliance with a legal obligation to which the controller is subject;
Open Minds work very often with vulnerable people, both adults and children, who might present a risk to themselves or other people, or be at risk from other people. For this reason we may ask for information about you or about children or vulnerable adults in your life. If necessary we then have the appropriate information to act upon any safeguarding concerns which may be raised.
This is the only time we would share your information without your prior knowledge and consent.
We do ask for your consent to share information with specified third parties, which is described under point 6.
processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
Open Minds is funded by third party organisations such as Big Lottery Fund, who may require us to provide basic information about people using our service in order to evidence to them that we are fulfilling the terms of their contracts with Open Minds.
This is only to prove to the funders that Open Minds is indeed working with the numbers of people we claim to.
We ask for your consent to share this information and will tell you which information we are being asked to share.
You can refuse Open Minds permission to share this information with third parties and we will continue to offer you services.
Your rights to be forgotten, to object to information processing and to opt out of processing
You have the right to opt out of the following use of your information by Open Minds:
Open Minds contacting the client about appointments (cancellations, change of times etc)
For example if your counsellor is off sick we would with your permission contact you to let you know. You can opt out of this contact at any time but this will mean we cannot inform you if your counsellor is unavailable
For example if you have difficulties with memory and have asked to be reminded about your appointments we would with your permission contact you remind you before your appointments. You can opt out of this contact at any time but this will mean we cannot remind you about appointments
Open Minds contacting the client about referrals and other service provision
For example if we have made a referral on your behalf we would with your permission inform you of any contact we receive which follows that referral up. You can opt out of this contact at any time but this will mean we cannot update you about such referrals
For example if you have expressed interest in other services such as training, art or relationship therapy, other than services you already attend or have received. We would with your permission contact you to let you know services have become available. You can opt out of this contact at any time but this will mean we cannot inform you of service provision
Open Minds contacting the client about feedback on our services in order to improve our work
For example we audit our work every 6 – 12 months in order to assess ho well we are doing. We would with your permission contact you, normally by text, with a link to an online survey and ask you to complete it anonymously. This allows us to gather information in a confidential way which we can use to change how Open Minds work for the better. The information provided by clients is prepared into a report for the public which shows how we are doing and what changes we are making. You can opt out of this contact at any time but this will mean we cannot ask you for feedback about our work with you
Open Minds sharing your data with third party (funder) to confirm service attended
For example we code our clients by initials and year of birth and with your permission would give the funder your name, address and phone number or email to prove that we are working with real people, not falsifying our data. The funder does not receive information about the content or reasons that you attended therapy at Open Minds. You can opt out of this contact at any time but this will mean we cannot prove to our funders that we are working with real people
Open Minds sharing your data with a third party (agency) for Open Minds to refer you externally
For example if you have asked to be referred to the NHS for CBT we need to share some of your information in order to do this. You can opt out of this information sharing at any time but this will mean we cannot complete the referral.
Open Minds sharing your data with specified third party (eg probation) for Open Minds to confirm attendance
For example if you have been asked to attend Open Minds as part of a requirement of your terms of probation, or by Social Services or by another agency we would with your permission inform that third party agency of your attendance. You can opt out of this information sharing at any time but this will mean we cannot confirm your attendance to other agencies.
For example if you want us to provide a report to Social Services about your suitability for contact with your children we would with your permission write a report on your behalf. You can opt out of this information sharing at any time but this will mean we cannot provide such reports to other agencies.
THIS DOES NOT APPLY TO SAFEGUARDING CONCERNS; WE WOULD DISCLOSE SAFEGUARDING CONCERNS WITH OR WITHOUT PERMISSION
Open Minds does however need to process some information about you, as explained on page 2 and 3, in order to provide you with services.
You have the right to object to Open Minds processing and holding this data, or the right to ask to be forgotten. In this event we will take the following actions:
If you have not accessed any services at Open Minds and are only on the waiting list you can object and we will destroy your referral.
If you have attended assessment or counselling you can object to Open Minds processing or holding your data and we will physically archive this data and destroy it 7 years after your contact with us.
We do not destroy data for service users because of the risk to Open Minds if allegations are made against our employees or volunteers. We will not allow any personnel to access your data in the archive unless such allegations pertaining to you or our work with you were made.
Electronic information held on you will be printed out and attached to your physical data file and archived.
If you have attended training at Open Minds and there is no outstanding financial consideration we will destroy the data we hold on you.
If you have attended other services at Open Minds and there is no outstanding financial consideration we will destroy the data we hold on you.
We are committed to ensuring that your information is secure.
In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect.
Security of physical information:
The files in the filing cabinets are coded for confidentiality and anonymity.
Cardboard files are encoded and kept in locked filing cabinets
Filing cabinets are covered 24/7 by CCTV.
The filing cabinets are only unlocked in the morning for administrative staff to put the previous day’s files away and remove the current day’s files.
Files for clients attending on the current day are placed in a separate drawer which remains unlocked during the working day.
Counsellors can only access client files for the day on which they are attending.
Counsellors do not know the names of people attending on days they are in who are not their own clients.
If counsellors ask to access files for clients they are not seeing on that day they can only do so under observation and with good reason.
The locked filing cabinets are themselves kept in a locked office
The building has two separate internal burglar alarms
CCTV covers the ground floor and entrances and parts of the first floor
CCTV only covers public areas of the building and records for 14 days before automatically being overwritten
The building is locked overnight
The building is only accessible during the day by those with a key or by a security system of electronic door access
Security of electronic information:
Electronic information is password protected at computer, e-mail and pen drive access point
Data breach = accidental/illegal/unauthorised destruction, loss, alteration or access to or disclosure of someone’s personal data.
If a member of staff or a service user or someone else believes there has been a data breach by Open Minds then you must in the first instance report this to the data protection officer at Open Minds. This is Helen Mason, the Managing Director of Open Minds.
The data protection officer will investigate how the data breach occurred, what the likelihood and severity of the risk to people is from the breach, and how it can be prevented in future. If necessary the data protection officer has the power to begin disciplinary proceedings against those responsible for data breaches.
Not all data breaches need to be reported to the ICO. The ICO steps in when the breach of data is likely to place the person whose data it is at risk of harm to their freedom or personal rights.
For example if the data which had been lost or disclosed revealed that the person was homosexual to people who might then commit hate crimes against them then this would threaten the individual’s right and freedom.
If necessary breaches can be reported to the ICO here:
In the event of a data breach for your information we will contact you as soon as this is identified, and provide all the details we can on how such a breach occurred and how it will be prevented in the future.
Who can access what information at Open Minds:
Who normally has access? And Why?
How is it protected?
Office mobile with your client code and phone number / text messages to Open Minds
If you have given us permission to communicate with you between sessions abut appointments then the admin team, and your counsellor, have access to this. If you have opted out of such contact your details will not be in the phone
The office mobile does not leave the office
Emails you have sent to Open Minds or which have been sent about you
The admin team know the computer password and email password and can access e-mails. If an email is headed FAO a specific person it is filed separately for their attention, or printed out and put in your file,
The computer and emails are password protected
Electronic database with your contact details
Office Team of our administrators. This is to allow them to contact you about appointments etc if you have given permission
The computer is password protected
The information is not kept online
Appointment management Calendar (print outs or on computer)
Only the admin team or internal supervisors access the computer calendar, eg in order to schedule appointments.
Calendar print outs only contain client codes and counsellor name and are placed on the wall of the office on the relevant day, in order to indicate who is attending that day and what room they have been allocated
Paperwork such as your referral form, case-notes, and any paperwork completed during counselling sessions
Only your counsellor would access these normally and only on days you are seeing them. In special circumstances the data protection officer or an internal supervisor might do so if we needed to safeguard you or someone in your life
See Page 7 for description of physical security
We collect the personal data that you volunteer as part of booking appointments for counselling or other therapies, booking on events/workshops/projects, signing up for e-newsletters, attending sessions as a participant, becoming a volunteer, member or trustee, engaging in fundraising activity or making a donation.
Personal information that we collect may include:
• Your full name, title and date of birth / age range
• Your postal address, e-mail address and phone number
• Reasons you may have been referred for counselling (if applicable)
• Diversity monitoring information as volunteered by you
We will also collect and hold information about any appointments you have with us as a client of Open Minds Counselling Service.
This is so that we can track attendance, communicate with you during your participation in therapy or service provision, evaluate the impact of our work and report back to the organisations that fund our programmes.
We may also use this information to improve our programmes, products and services.
Ways we collect information might include:
• Calendar bookings of appointments attended or missed
• Contact preferences
• Details of correspondence sent to you, or received from you
• Diversity monitoring information
• Donor status/Amounts paid
• Gift Aid status
• Gift/donation information, including payment details where applicable
• Reports we have written on your behalf
• Reports which you have agreed or us to receive
• Ticket purchases/booking and event/workshop/project attendance (at internal venues or at external venues)
• Volunteer hours
• Any other information provided by you at the request of Open Minds Counselling Service
We may also use profiling and screening techniques to analyse your personal data and create a profile of which of our services, or external services, might best suit your therapeutic needs. We will do this in a transparent and legitimate way and will communicate what we are doing, ensuring that you have the opportunity to opt out.
Gathering information in this way might make use of additional information about you, including thorough exploration of your experiences (this is known as a history) which led you to seek our support, any additional psychological treatments you may have had in the past, and any risk factors such as if you present a risk to yourself or to other people, and if you are at risk from other people.
When we ask you to provide your personal information, we will let you know why we are asking and how we will use your data, by directing you towards this notice.
Where we are approaching potential corporate or Trust partners, we will follow a Legitimate Interest Assessment to ensure we have legitimate reason to contact an individual, that any direct contact is in a professional context, that the individual concerned knows that we are processing their data and for what purpose, and that they have the option to opt out of further communications if they wish.
Depending on your relationship with Open Minds Counselling Service, and the preferences you have indicated, data we hold may be used by us for the following purposes:
• To send you promotional, marketing or fundraising information by post, telephone or electronic means
• To inform you of other products, services or events related to Open Minds Counselling Service, such as events, volunteering opportunities, or retail offers.
• News and updates about Open Minds Counselling Service and marketing or supporter e-newsletters
• Information on our fundraising operations, including occasional targeted requests to consider giving financial support to Open Minds Counselling Service, or to ask you to consider supporting us in other ways
• Other relevant communications based upon your relationship with Open Minds Counselling Service, including direct contact during a project that you are participating in
We understand that your personal information and privacy are important to you.
We make every effort to ensure that the information you share with us is recorded accurately, retained securely and used only according to your wishes.
We protect your personal information and adhere to all current data protection act legislation with respect to protecting privacy.
We do not give out, sell or trade our data with third parties except in the circumstances described previously such as for safeguarding, referral or to provide you with reports and attendance confirmation at your request.
The information you provide will be used primarily to protect your attendance.
The information we share with funders is normally anonymous and enables us to demonstrate the impacts of our work and the difference that the funding has made. If funders request identifying information in order to confirm that we are indeed working with the numbers of people we claim to then we would contact you to ensure you were willing to consent for us to share your name and contact details (address, phone number, email address) with the funder so that you could confirm that you had attended Open Minds’ services. You can withdraw consent for this at any time.
We will hold personal data on our internal systems for a maximum of 7 years for adults and 7 years after your 18th birthday for children before contacting you to check that you are still happy for us to keep your data for the original reasons that you identified, or destroying the data we hold.
You can sign up to be informed about appointments and so forth when we first take your referral, or you can contact us by phoning 01302 344192 or 07765 224564 or emailing email@example.com to opt in if you did not do so at the point of referral. This contact would be by text, telephone, email or letter.
You can opt out of receiving information at any time by
phoning 01302 344192 or 07765 224564 or emailing firstname.lastname@example.org.
If you are referring yourself, or someone else, or booking an appointment over the telephone, we will ask you for your consent to keep the data you give on our internal systems for monitoring.
When you attend an Open Minds Counselling Service initial assessment, therapeutic appointment, workshop, session or event, you may be asked to complete a registration form or contract, or asked for your contact details for a register. Information about opting in will be clearly stated at the top of the registration form and register.
By completing the forms and registers, you are giving us permission to hold the personal information given for monitoring and reporting purposes.
We may also contact you during your participation in therapy or other services for administrative reasons e.g. to provide specific information – change of time/venue or a session cancellation.
From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone, or post. We may use the information to customise the website and our services according to your interests.
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Links to other websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
Controlling your personal information
You may choose to restrict the collection or use of your personal information in the following ways:
• Whenever you are asked to fill in a form on the website, look for the box that you can click to indicate that you do not want the information to be used by anybody for direct marketing purposes
• If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing to or emailing us at email@example.com
• We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you relevant promotional information about third parties which we think you may find interesting
You may request details of personal information which we hold about you under the Data Protection Act 1998. A small fee will be payable. If you would like a copy of the information held on you please write to Open Minds Counselling Service Ltd., 28 Christchurch Road, Doncaster, DN1 2QL
If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.
The data controller and data protection officer for Open Minds Counselling Service is Helen Mason – 01302 344192. If you are unhappy with the way that we have handled your data, do contact us to discuss how we could improve our processes. If you still have a concern about our information rights practices, you are entitled to contact the Information Commissioner’s Office (ICO) on 0303 123 1113 or via their website https://ico.org.uk/concerns/.
The information contained in this policy and on the website is for general information purposes only. The information is provided by Open Minds Counselling Service and while we endeavour to keep the information up to date and correct, we make no representations or warranties of any kind, express or implied, about the completeness, accuracy, reliability, suitability or availability with respect to the website or the information, products, services, or related graphics contained on the website for any purpose. Any reliance you place on such information is therefore strictly at your own risk.
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you may print or download to a local hard disk extracts for your personal and non-commercial use only
you may copy the content to individual third parties for their personal use, but only if you acknowledge the website as the source of the material
You may not, except with our express written permission, distribute or commercially exploit the content. Nor may you transmit it or store it in any other website or other form of electronic retrieval system.
Terms and Conditions of website use
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