Privacy Policy

The following privacy policy sets out where and how The Lochs Counselling records your personal data, what we do with it and what we do to keep it secure. It also outlines your rights over the personal data we hold about you.

This privacy policy applies to you if you use our services in our locations, over the telephone, online or through mobile applications or otherwise by using our website or by interacting with us on social media, via telephone, by post or by email (our “Services”).

Who are we?

The Lochs Counselling is the trading name of The Lochs, a Scottish registered charity (SC054360). We provide accessible counselling services to individuals across Fife and surrounding areas.

The Lochs Counselling may update this Privacy Policy from time to time. Any changes will be published on this page and will take effect immediately upon publication.

What types of information do we hold?

The Lochs retains different types of information in order to provide you with our Services.

Adults

Name and contact details including email address, postal address and telephone number
Date of birth and gender
Relationship status
Ethnic origin
Occupation
Anonymised counselling notes from any counselling sessions undertaken.
Relevant health information
Emergency contact details

Online

The pages visited
When and how long our website was visited
Each device’s IP (Internet Protocol) address
The type of Internet browser used (e.g. Chrome, Safari or Firefox)
Referring website

What sorts of sensitive information do we hold?

In some cases, The Lochs will hold what is classed as sensitive information in order to provide you with our Services.

Adults

In order to monitor equal opportunities, we will use ethnic origin, religious beliefs, sexual orientation and gender
(For those attending counselling) health details
(For those attending counselling sessions) we may record counselling sessions with the appropriate written consent
(For those attending counselling sessions) where relevant to counselling sessions, your sexual life, sexual orientation, beliefs and other sensitive data

Lawful Basis for Processing Personal Data

The Lochs Counselling processes personal information in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. We process personal information under one or more of the following lawful bases:

Contract – to provide counselling and related services.
Legitimate Interests – to manage and improve our services and ensure the effective operation of the charity.
Consent – where you have given us permission to process specific information.
Legal Obligation – where we are required to process information to comply with legal or regulatory requirements, including safeguarding responsibilities.

How We Use Your Information

The information The Lochs collects may be used to complete the following:

Adults

To provide you with our Services
To communicate with you and provide details of our Services
To arrange, cancel or reschedule appointments for counselling
Personalising the delivery of our Services to you
Statistical analysis
Research purposes
To find ways to improve our Services
To monitor diversity and equal opportunities
To maintain a record of our correspondence with you
To record your attendance and record anonymised notes of your counselling sessions
To flag risks.

In order to provide some of our Services to you it is necessary to share your information with a small number of our 3rd party partners and suppliers.

We share your information with the following 3rd party partners and suppliers:

Stripe
Microsoft 365
Microsoft Sharepoint

We may also use services such as Microsoft Outlook, Microsoft Bookings, Microsoft Teams (for online counselling where applicable), and Wix (website hosting and enquiry forms).

These organisations process information on our behalf and are required to comply with UK GDPR and relevant data protection legislation.

This information is shared in order to provide you with our Services and specifically to process your data for the following:

To securely process payments
To communicate by telephone with clients
Record anonymised notes of counselling sessions.

The following information is retained by these 3rd party partners and suppliers:

Name

Billing Address
Telephone number
Card Payment Details, Card Type and Authorising Bank.

Personal data is shared with Counselling and Psychotherapy in Scotland (COSCA) for courses accredited with them.

Confidentiality is fundamental to the counselling process. Information shared during counselling sessions will remain confidential except in circumstances where:

There is concern about serious harm to yourself or another person.
Safeguarding concerns arise involving a child or vulnerable adult.
Disclosure is required by law or court order.
Information is discussed anonymously within professional supervision in accordance with ethical practice.

Wherever possible, we will discuss any necessary disclosure with you before information is shared.

Your Rights

Under General Data Protection Regulations, you have the following rights regarding the data that we collect and process in the delivery of our services:

The right to be informed about the collection and processing of your data – covered by this privacy policy statement
The right of access to your data, specifically:
The right to confirmation that your data is being processed
The right to access your personal data held by The Lochs
The right to rectification of your data if it is inaccurate or incomplete
The right to be forgotten – your right to request deletion or removal of data held by The Lochs
The right to restrict processing of your data by The Lochs: You have the right to object to us processing your personal information if we are not entitled to use it anymore, to have your information deleted if we are keeping it too long or have its processing restricted in certain circumstances.
The right to data portability – your right to obtain and reuse your personal data where:
It is personal data you have provided to The Lochs
Data is processed by your consent, and
Data is processed automatically.
The right to object to:
Processing of your data based on legitimate interests or concerns
Direct marketing
Processing for purposes of scientific/historical research and statistics

An Assessment of Risk will be undertaken before providing counselling notes and some of these may be redacted where there are concerns for example about Child Protection.

How Long Do We Keep Your Information For?

We will keep your personal data in order to provide you with our Services. Your personal information will be retained in accordance with law and regulation, and we will never retain your data for longer than permitted under law and regulation.

Adults

Counselling records and case notes: retained for 7 years following the conclusion of counselling services.
Appointment records: retained for 7 years.
Payment and financial records: retained for 7 years in accordance with HMRC requirements.
Website enquiries: retained for 12 months.
Anonymised website analytics: retained for up to 24 months.

Where information is no longer required, it will be securely deleted or anonymised.

Online

Details of online enquiries regarding any of our Services are retained for 1 year
Anonymised details of your use of our website and online Services are retained for 24 months.

If asked to do so by you, we will delete your personal data if it is no longer necessary for the provision of our Services to hold it.

Links To Other Websites

From time to time, we will provide you with links to other websites. These websites are not under our control and as a result, we will not be liable to you for any issues arising in connection with their use of your personal data, the website content or the services offered to you. You should exercise caution and look at the privacy statement applicable to the website in question.

Sharing Data On Social Media

In the process of using our Services, you may have the opportunity to share information through social media networks like Twitter and Facebook. This can be, for example, when you ‘retweet’, ‘like’, ‘share’ or review our Services.

When you do this your personal information may be visible to the providers of those social media services, their other users and other third-party organisations. It is, therefore, your responsibility to be aware of this and use the appropriate privacy settings on your social media accounts so that you have control over how your data is used and shared.

Security

In order to prevent unauthorised access or disclosure of your data, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

For example, all data is stored securely on designated drives and servers and is only accessible to authorised individuals.

Information exchanged via our website using live chat and contact forms are securely encrypted before being transmitted over the Internet. Encryption makes it difficult for unauthorised people to view information travelling between computers.

If a security breach is suspected, we have a procedure in place to ensure the breach is limited and the security restored and updated accordingly. High risk breaches will be reported to the individuals concerned and the Information Commissioner’s Office (ICO) within 72 hours.

How We Use Cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added. Please note you cannot be identified from the data we collect.

The Lochs website uses four types of cookies:

‘Necessary cookies’ to allow our website to function;
‘Preference cookies’ to enhance your website experience by remembering things like your preferred language;
‘Statistic cookies’ to anonymously analyse your use of our website; and
‘Marketing cookies’ used to track visitors across websites.

Necessary cookies allow our website to function properly. These cannot be deselected as they allow basic functions like page navigation. Our website cannot function properly without these cookies.

Preference cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use statistic cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. This data is anonymous and we only use this information for statistical analysis purposes.

Marketing cookies are used by other organisations in order in order to display ads that should be relevant and engaging to you based on the websites you have visited.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept all cookies, decline cookies or select individual cookie types to accept/decline. Adjust your preference to each cookie type by visiting our Cookie Policy and clicking ‘Changing your consent’.

Website Accessibility

The Lochs Counselling is committed to ensuring that our website and services are accessible to all members of the community.

If you require information in an alternative format or need support accessing our services, please contact us and we will do our best to accommodate your needs.

Controlling Your Personal Information

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.

If you have any questions regarding this Privacy Policy, wish to exercise your data protection rights, or have concerns about how your information is handled, please contact:

Data Protection Lead
The Lochs Counselling
Ore Valley Business Centre
93 Main Street
Lochgelly
Fife
KY5 9AF

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO). Further information can be found at https://www.ico.org.uk