privacy policy
We want to continue to keep you updated with information about the Banbury Therapy Group and we need your permission to do this.
On the 25th May 2018, the General Data Protection Regulation (GDPR) came into effect and we are required to provide you with information on the lawful grounds for our ongoing processing of your personal data. We have put together a privacy policy that clearly sets out how we collect and process your personal data, for what purposes we use your data, the legal grounds of processing such data, how we keep your data secure and your rights in relation to such data.
1. Introduction
Banbury Therapy Group are committed to protecting and respecting your privacy. This privacy policy provides you with details of how we collect and process your personal data through your use of our website (www.banburytherapycentre.com) and other methods such as completing assessment forms, feedback surveys etc. This policy also includes how we use it, the conditions under which we may disclose it to others and how we keep it secure. By using our website and services, you’re agreeing to be bound by this policy.
By providing us with your data, you warrant to us that you are over 16 years of age, or a legal guardian of someone under 16.
Banbury Therapy Group is the data controller and we are responsible for your personal data. We have appointed a Data Protection Officer who is in charge of privacy related matters for us. If you have any questions about this privacy notice, please contact the Data Protection Officer using the details set out below.
Any questions regarding this policy and our privacy practices should be addressed to Beverley Charman, Data Manager.
Who are we?
Banbury Therapy Group is a private company, dedicated to providing counselling & psychotherapy, counselling training courses and CPD training days.
Contact Details
Our full details are:
Full name of legal entity: The Banbury Therapy Group is a trading style of PB&H Ltd. Company Registration Number 06244697
Data Protection Officer: Beverley Charman
Email address: beverley@banburytherapygroup.com
Postal address: Banbury Therapy Group, 69 Oxford Road, Banbury, Oxon, OX16 9AJ
Telephone number: 01295 231320
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 at info@banburytherapygroup.com
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 title, first name, last name, date of birth and gender.
Contact Data may include your property address, email address and telephone numbers.
Financial Data may include your bank account and payment card details.
Transaction Data may include details about payments between us and other details about services you have used or requested.
Technical Data may include your internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.
Profile Data may include your interests, preferences, feedback and survey responses.
Usage Data may include information about how you use our website, products and services.
Marketing and Communications Data may include your preferences in receiving marketing communications from us and our third parties and your communication preferences.
We may also process Aggregated Data from your personal data but this data does not reveal your identity and as such in itself is not personal data. An example of this is where we review your Usage Data to work out the percentage of website users using a specific feature of our site. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data.
Sensitive Data
We do not collect any sensitive data about you except during an initial assessment and in the Banbury Counselling Academy application forms. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.
3. How do we collect information from you?
We collect data about you through a variety of different methods including:
Direct interactions: You may provide data by filling in forms on our website (or otherwise) or by communicating with us by post, phone, email or otherwise, including when you:
Attend an assessment;
Complete a Banbury Counselling Academy Application form;
Subscribe to our service or publications;
Request resources or marketing be sent to you;
Make enquiries via our website;
Buy goods or services from us;
Join our EAP schemes;
Enter a competition, prize draw or survey; or
Give us feedback.
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:
Where we need to perform the contract between us;
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing us at info@banburytherapygroup.com
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 info@banburytherapygroup.com 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
You will receive marketing communications from us if you have:
Requested information from us or purchased goods or services from us
If you provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications; and
In each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing us at info@banburytherapygroup.com at any time.
Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.
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 at info@banburytherapygroup.com
If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
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:
Service providers who provide IT, financial and system administration services;
Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services;
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;
Third party businesses to process your booking to study or take part in training at the Banbury Therapy Group. When you make a booking, the relevant third-party business will use your details to contact you to process the outstanding balance of the booking and to provide you with further details about the training and your booking;
CPCAB (the awarding organisation associated with Banbury Counselling Academy Courses) who will upload candidates’ achievement data to the Learning Record Service, who then in turn will update the candidates personal learning records. Useful guidance from the Skills Funding Agency (now known as the Education & Skills Funding Agency or ESFA) can be found at: https://www.gov.uk/government/organisations/education-and-skills-funding-agency
Third parties to whom we sell, transfer, or merge parts of our business or our assets.
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.
Any sensitive information (such as credit/debit card details) is encrypted and protected. When you are on a secure page, a lock sign icon will appear at the top of the internet browser you are using.
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 customers (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.
We may anonymise your personal data in some circumstances (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:
If you wish to exercise any of the rights set out above, please email us at info@banburytherapygroup.com
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.
9. Third-party links
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.