1.1 I am committed to safeguarding the privacy of my website visitors and service users.
1.2 This policy applies where I am acting as a data controller with respect to the personal data of my website visitors and service users; in other words, where I determine the purposes and means of the processing of that personal data.
1.4 In this policy, “I”, “me” and “my” refer to Peter Cartwright and “my website” refers to www.peter-cartwright.co.uk.
2.1 In this Section 2 I have set out:
(a) the general categories of personal data that I may process;
(b) the purposes for which I may process personal data; and
(c) the legal bases of the processing.
2.2 I may process data about your use of my website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is my legitimate interests, namely monitoring and improving my website and services.
2.3 I may process your personal data that are provided in the course of the use of my services (“service data”). The service data may include your name and email address. The source of the service data is my website contact form. The service data may be processed for providing my services and communicating with you. The legal basis for this processing is your consent.
2.4 I may process information contained in any enquiry you submit to me regarding my services (“enquiry data”). The enquiry data may be processed for the purposes of offering services to you. The legal basis for this processing is your consent.
2.5 I may process information relating to my client relationships, including client contact information (“customer relationship data”). The client relationship data may include your name, your contact details, and information contained in communications between me and you. The client relationship data may be processed for the purposes of managing my relationships with clients, communicating with clients, and keeping records of those communications. The legal basis for this processing is my legitimate interests, namely the proper management of my client relationships.
2.6 I may process information contained in or relating to any communication that you send to us (“communication data”). The communication data may include the communication content and metadata associated with the communication. My website will generate the metadata associated with communications made using the website contact forms. The communication data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is your consent.
2.7 In addition to the specific purposes for which I may process your personal data set out in this Section 2, I may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which I am subject, or in order to protect your vital interests or the vital interests of another natural person.
2.8 Please do not supply any other person’s personal data to us, unless I prompt you to do so.
3.1 I may disclose your first name only and information about what brings you into counselling to my clinical supervisor for the purposes of obtaining professional advice to assist in my providing you with counselling.
3.2 Your personal data held in my website database will be stored on the servers of my hosting services providers identified at https://www.34sp.com/.
3.3 In addition to the specific disclosures of personal data set out in this Section 3, I may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which I am subject, or in order to protect your vital interests or the vital interests of another natural person.
4.1 In this Section 4, I provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
4.2 Google analytics processes your usage data in the United States. The European Commission has made an “adequacy decision” with respect to the data protection laws of the United States Transfers to the United States will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which you can obtain from https://gdpr-info.eu/art-45-gdpr/
5.1 This Section 5 sets out my data retention policies and procedure, which are designed to help ensure that I comply with my legal obligations in relation to the retention and deletion of personal data.
5.2 Personal data that I process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.3 I will retain your personal data as follows:
(a) usage data will be retained for a minimum period of 26 Months following the date of collection, and for a maximum period of 36 months following that date;
(b) service data will be retained for a minimum period of 26 months following the termination of the contract under which the service was provided, and for a maximum period of 36 months following that date;
(c) enquiry data will be retained for a minimum period of 26 months following the date of the enquiry, and for a maximum period of 36 months following that date;
(d) client relationship data will be retained for a minimum period of 26 months following the termination of the relevant client relationship, and for a maximum period of 36 months following that date; and
(e) communication data will be retained for a minimum period of 26 months following the date of the communication in question, and for a maximum period of 36 months following that date.
5.4 In some cases it is not possible for me to specify in advance the periods for which your personal data will be retained. In such cases, I will determine the period of retention based on the following criteria:
(a) the period of retention of information about the reasons you wanted to have counselling will be determined based on my clinical needs to facilitate counselling you and will be no more than ten years.
5.5 Notwithstanding the other provisions of this Section 5, I may retain your personal data where such retention is necessary for compliance with a legal obligation to which I am subject, or in order to protect your vital interests or the vital interests of another natural person.
6.1 I will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
6.2 I will store all your personal data on secure servers and personal computers, and in secure manual record-keeping system.
6.3 Data relating to your enquiries that is sent from your web browser to my web server, or from my web server to your web browser, will be protected using encryption technology.
6.4 You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and I cannot guarantee the security of data sent over the internet.
7.1 In this Section 7, I have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in my summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
7.2 Your principal rights under data protection law are:
(a) the right to access – you can ask for copies of your personal data;
(b) the right to rectification – you can ask me to rectify inaccurate personal data and to complete incomplete personal data;
(c) the right to erasure – you can ask me to erase your personal data;
(d) the right to restrict processing – you can ask use to restrict the processing of your personal data;
(e) the right to object to processing – you can object to the processing of your personal data;
(f) the right to data portability – you can ask that I transfer your personal data to another organisation or to you;
(g) the right to complain to a supervisory authority – you can complain about my processing of your personal data; and
(h) the right to withdraw consent – to the extent that the legal basis of my processing of your personal data is consent, you can withdraw that consent.
7.3 You have the right to confirmation as to whether or not I process your personal data and, where I do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, I will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
7.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
7.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
7.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; I no longer need the personal data for the purposes of my processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, I may continue to store your personal data. However, I will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
7.7 You have the right to object to my processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest; or the purposes of the legitimate interests pursued by me or by a third party. If you make such an objection, I will cease to process the personal data unless I can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
7.8 To the extent that the legal basis for my processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract.
and such processing is carried out by automated means, you have the right to receive your personal data from me in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
7.9 If you consider that my processing of your personal data infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
7.10 To the extent that the legal basis for my processing of your personal data is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
7.11 You may exercise any of your rights in relation to your personal data by written notice to me using the website contact form, in addition to the other methods specified in this Section 7.
8.1 Our website includes hyperlinks to, and details of, third party websites.
8.2 I have no control over, and are not responsible for, the privacy policies and practices of third parties.
9.1 My website and services are targeted at persons over the age of 18.
9.2 If I have reason to believe that I hold personal data of a person under that age in my databases, I will delete that personal data.
10.1 Please let me know if the personal information that I hold about you needs to be corrected or updated.
11.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
11.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
14.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647 (Chrome);
(c) https://help.opera.com/en/latest/security-and-privacy/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
16.1 I may update this policy from time to time by publishing a new version on my website.
16.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
17.1 This website is owned and operated by Peter Cartwright.
17.2 You can contact me using my website contact form.