The Association for Group and Individual Psychotherapy (AGIP)
Privacy and Cookies Policy
Our contact details:
Name: The Association for Group and Individual Psychotherapy
Address: 1 Fairbridge Road, London N19 3EW www.agip.org.uk
Phone: 020 7272 7013
AGIP collects and uses personal information about staff, members, trustees, students, third party suppliers, event bookers, contractors and patients. This information is gathered to enable it to provide psychotherapy services, psychotherapy training and other associated functions. In addition, there may be a legal requirement to collect and use information to ensure that AGIP complies with its statutory obligations.
AGIP currently collect and process the following information:
- Personal identifiers, contacts and characteristics (for example, name and contact details)
- Financial information
- Employee data
- Website user statistics
Personal information we collect includes details such as your name, date of birth, email address, postal address, telephone number and bank card details (if you are contributing to therapy or making a donation), as well as information you provide in any communications between us. You will have given us this information whilst making a donation, registering for therapy, training or an event, liaising with us on our website or any of the other ways to interact with us.
We will mainly use this information:
- To process your donations or other payments.
- To provide the services that you have requested.
- To update you with important administrative messages about your donation, an event or services you have requested.
- To comply with the Charities (Protection and Social Investment) Act 2016 and follow the recommendations of the official regulator of charities, the Charity Commission, which require us to identify and verify the identity of supporters who make major gifts so we can assess any risks associated with accepting their donations.
- To keep a record of your relationship with us.
- Where you volunteer with us, to administer the volunteering arrangement.
If you do not provide this information, we will not be able to process your donation, sign you up for a particular event, provide the services you have requested or process your application for training.
We may also use your personal information:
- To contact you about our work and how you can support AGIP.
- To invite you to participate in surveys or research.
Sensitive Personal Information
You can of course decide if you want to remain anonymous, if you are happy to share your personal details with staff members or if you would like us to share your story with the media or other parties as part of our work telling people’s personal stories about mental health (for example, on our social media or newsletters).
A special note about the Sensitive Personal Information we hold
Data Protection legislation recognises that some categories of personal information are more sensitive. Sensitive Personal Information can include information about a person’s health, race, ethnic origin, political opinions, sex life, sexual orientation or religious beliefs.
If you contact us at AGIP, you may choose to provide details of a sensitive nature.
We will only use this information:
- For the purposes of dealing with your enquiry, training, and quality monitoring or evaluating the services we provide.
- We will not pass on your details to anyone else without your explicit consent except in exceptional circumstances. Examples of this might include anyone reporting serious self-harm or posing a threat to others or children contacting us and sharing serious issues such as physical abuse or exploitation.
- Where you have given us your explicit consent or otherwise clearly indicated to us that you are happy for us to share your story, then we may publish it on our social media or newsletter.
How we get the personal information and why we have it
When you interact with us directly: This could be if you ask us about our activities, enquire or register with us for therapy, training or an event, make a donation to us, ask a question about our services, complete a survey providing feedback on our services, apply for a job or volunteering opportunity or otherwise provide us with your personal information. This includes when you phone us, visit our website, or get in touch through the post, or in person.
When you visit our website: We gather the information you supply AGIP through our enquiry forms. We may also gather general information which might include which pages you visit most often and which services, events or information is of most interest to you. We may also track which pages you visit when you click on links in emails from us. We also use “cookies” to help our site run effectively.
We use this information to personalise the way our website is presented when you visit to make improvements and to ensure we provide the best service and experience for you. Wherever possible we use anonymous information which does not identify individual visitors to our website.
Most of the personal information we process is provided to us directly by you for one of the following reasons:
- applying for therapy,
- applying to study or train,
- membership or
- other associations with AGIP.
Each aspect of data we collect is to fulfil a specific purpose to AGIP and we only use people’s data in ways they would reasonably expect, and which have a minimal privacy impact.
Sharing your information – Legal disclosure
The personal information we collect about you will be used by our staff so that they can support you.
We may disclose your information if required to do so by law (for example, to comply with applicable laws, regulations and codes of practice or in response to a valid request from a competent authority); or, in order to enforce our conditions of service and other agreements.
For patients, the personal information we collect about you will be used by our staff at AGIP so that they can support you. Individual AGIP members are also required to follow strict privacy rules, however, if a therapist is concerned about your welfare they may need to contact your GP or psychiatrist (if you have one). In the event that the therapist is concerned about the welfare of a third party, including a child, then the therapist might share information with social services. Normally the therapist would discuss this with you before taking such a step.
For students and trainees, personal information is shared amongst the Training Committee and the teaching team. For other members the information we collect is shared by staff to support your ongoing membership.
We will never sell or share your personal information with organisations so that they can contact you for any marketing activities. Nor do we sell any information about your web browsing activity.
Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing this information are:
(a) Your consent. You are able to remove your consent at any time. You can do this by contacting us at firstname.lastname@example.org or by writing to 1 Fairbridge Road, London N19 3EW.
(b) We have a contractual obligation.
(c) We have a legal obligation.
(d) We have a vital interest.
(e) We need it to perform a public task.
(f) We have a legitimate interest.
Legal basis for holding your information
In some cases, we will only use your personal information where we have your consent or because we need to use it in order to fulfil a contract with you (for example, because you have placed an enquiry or order on our website).
However, there are other lawful reasons that allow us to process your personal information and one of those is called ‘legitimate interests’. This means that the reason that we are processing information is because there is a legitimate interest for AGIP to process your information to help us to achieve our vision of ensuring that everyone experiencing a problem gets both support and respect.
Whenever we process your Personal Information under the ‘legitimate interest’ lawful basis we make sure that we take into account your rights and interests and will not process your personal information if we feel that there is an imbalance.
Some examples of where we have a legitimate interest to process your Personal information are where we contact you about our work via post, use your personal information for data analytics, conducting research to better understand who our supporters are, improving our services, for our legal purposes (for example, dealing with complaints and claims), or for complying with guidance from the Charity Commission.
Each website you visit can send its own cookie to your browser if your browser’s preferences allow it. To protect your privacy, your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other websites.
How to control and delete cookies: You may restrict or block the cookies which are set by our website, or any other website, through your browser settings. You can also ask your browser to alert you when a cookie is issued. For more information about cookies and how to manage them is available at www.aboutcookies.org
Keeping your information safe
We take looking after your information very seriously. We’ve implemented appropriate physical, technical and organisational measures to protect the personal information we have under our control, both on and off-line, from improper access, use, alteration, destruction and loss.
Unfortunately the transmission of information using the internet is not completely secure. Although we do our best to protect your personal information sent to us this way, we cannot guarantee the security of data transmitted to our site.
Our websites may contain links to other sites. While we try to link only to sites that share our high standards and respect for privacy, we are not responsible for the content or the privacy practices employed by other sites. Please be aware that web sites that have links on our site may collect personally identifiable information about you. This privacy statement does not cover the information practices of those websites or advertisers.
Any debit or credit card details which we receive on our website are passed securely to Paypal our payment processing partner, according to the Payment Card Industry Security Standards.
All physical copies of personal information are stored securely in lockable storage in locked offices or shredded on site.
Passwords used for working purposes are recommended to be carefully set to be highly secure and difficult to guess.
No emails nor documents containing personal or sensitive data are shared outside AGIP unless required to fulfil a contractual requirement, with password protections. In these instances, the security of the data is fully considered and measures put in place to ensure the full consent of data subjects and the secure sending of their data.
Any computers returned or disposed of which contained personal information will have their memory wiped and returned to factory settings.
Training staff in basic principles
All staff are briefed on data protection policies as part of their induction and then on a regular basis. All existing staff are informed of any updates or changes to existing policies.
How long do we keep your data?
We only keep it as long as is reasonable and necessary for the relevant activity, which may be to fulfil statutory obligations or to satisfy any legal, accounting or reporting requirements. We keep your contact details, such as name, address and email for the duration of your associating with AGIP.
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.
Your data protection rights
Under data protection law, you have rights including:
Your right of access – You have the right to ask us for copies of your personal information.
Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.
Your right to object to processing – You have the the right to object to the processing of your personal information in certain circumstances.
Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
Please contact us at email@example.com or write to us at 1 Fairbridge Road, London N19 3EW if you wish to make a request.
How to complain
If you have any concerns about our use of your personal information, you can make a complaint to us at firstname.lastname@example.org or write to us at 1 Fairbridge Road, London N19 3EW.
You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office
Cheshire. SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk