Data Protection & Privacy Policy

This policy is in addition to our digital policy. Please take a moment to read both.

Any personal data provided by you to Key for Change 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 1998 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.

Introduction

Key for Change (the ‘data controller’, referred to below as “us” or “we”) is committed to protecting your privacy. Please read the following in order to learn more about Key for Change’s privacy policy and our information collection and use practices.

This policy only applies to data collected by Key for Change, 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 Key for Change using our contact form.

When you request services from Key for Change, 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?

When you communicate with us, you are voluntarily giving us information that we collect and may process. We also use various technologies including Cookies to collect and store information when you visit our website.

Our legal basis for processing your personal information is as follows:

Either, we have obtained your consent to do so (or the consent of a parent or guardian in the case of a child)

Or we need to process your data for the fulfilment of the contract, which you have entered into with us. Please note if you choose not to provide any information requested, this may limit our ability to fulfil our contract with you.

Or we are processing your data as you are an existing client (or have been in touch with us in the past). This is known as legitimate interest.

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 numbers and email address. We may also request information on your availability, therapeutic issues, and other details which we deem relevant to processing your request.

Initial Assessment Appointments – At an initial appointment we ask about your current personal, social, medical and financial circumstances. We may also ask about your background and family history, as well as the issues which are affecting you now. We require this information so that we can decide about our offer of counselling to you and to manage the service we provide to you.

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 offer suitable counselling appointments.

To notify you about changes to your appointments and other changes to our services.

To seek feedback from you on your experience with us.

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, for financial control, data analysis, research, statistical and survey purposes.

To keep in touch with those who consent to this, for the purposes of service development.

What information do we share?

We do not disclose information to companies or organisations outside of Key for Change unless we have your consent to do so, we are obliged to for legal reasons, or we need to do so for the fulfilment of our contract with you.

We also process data through third-party companies who supply our email newsletter services (Active Campaign), online advertising (e.g. Facebook, Google Adwords, Bing and Instagram) and sales management platforms, our payment system, and those who conduct postal mailings on our behalf. Some of these service providers may be based outside of the EEA (European Economic Area). However, if this is the case, these will be within countries that the EU has determined offer an adequate level of data protection, like the US, where personal information is protected by the EU-US Privacy Shield.

We will not otherwise share any information about you with other organisations or people, except in the following situations:

Consent – Key for Change may share your information with professional carers or others whom you have requested or agreed we should contact.

Serious harm – Key for Change may share your information with the relevant authorities if we have reason to believe that this may prevent serious harm being caused to you or another person.

Compliance with law – Key for Change may share your information where we are required to by law or by the regulations and other rules to which we are subject.

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 secure 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 prevent unauthorised access.

Your rights

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 Key for Change using the contact form.

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 the Key for Change, your counselling will have to end.

Cookies

We do not use cookies to collect any personal information on our website or to share your browsing behaviour with any third party except:

Google Analytics – Like hundreds of 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.

Cookie Notice – Ironically, the law requires that you receive a notification about our use of cookies, and so we have to use another set of cookies specifically and only to collect the information that you have seen this notice and agreed to it.

Meta Pixel – we use this information to target and retarget content that we think you may find useful.

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.

Last updated: August 2022