Essex Counselling Service

Privacy notice

How we manage your data

Catch22 Charity Ltd. manages the data you provide in accordance with the EU General Data Protection Regulation (GDPR).

• The Data Controller (the organisation that determines how your data is managed) is Catch22. Contact us if you have a query about how your data is managed.
• The Data Processor (the organisation that does data processing on behalf of Catch22) is Totally.Tech.
• We are committed to giving you (the Data Subject in legal terms) an easy way to exercise your eight rights under the GDPR.
• We retain your data for as long as you allow us to do so. You can exercise your right to erasure at any time however, there may be some instances where we need to retain your information for a longer duration for legal reasons, such as when applying for a job with Catch22.
• Catch22 uses Click4Asistance as an online chat tool. By providing information, you consent to Click4Assistance collecting and processing this information according to their privacy policy. 

What information do we collect?

Catch22 may collect, store and use the following kinds of personal data:

• information about your computer and your visits to and use of this website, including your IP address, geographical location, browser type, referral source, length of visit and number of page views (cookies),
• information that you provide to us for the purpose of applying for a job or receiving job alerts (job applications / job alerts),
• subscribing to email newsletters including your name and email address (email newsletter),
• If using our online chat service Click4Assistance, information such as IP addresses, and chat transcripts will be collected. If you choose to provide them, personal data such as names, email addresses will be collected, or
• information that you submit that relates to a complaint, service feedback or enquiry (complaints / feedback and enquiries).

Specific detail of each processing activity is provided below.

Cookies

Cookies are text files that are stored on your web browser by a website’s server. Each cookie is unique to your browser, and will contain some anonymous information such as a unique identifier and the website domain name. This information is sent back to the server each time your browser requests a page from it. This enables the website server to identify and track your web browser via your unique, anonymous, identifier.

Catch22 only uses cookies on its website where they will support the functioning of its website and to improve the experience of its website visitors. These cookies may be created by Catch22’s website, or by third-party services that Catch22 uses, to enable its website to be run effectively.

Some, ‘necessary’ cookies are essential to the running of our website and are exempt from the requirement of consent as per the GDPR and PECR. Functional, analytical and advertising cookies are all optional, and we will only store these cookies on your browser where we have received your freely-given, specific, informed, and unambiguous consent.

Any information that is collected by Catch22 via cookies is processed in a way which does not, and cannot, identify an individual person. We do not make any attempt to find out the identities of those visiting the Catch22 website.

You can find out more about Catch22’s use of cookies, and how to opt-out of or delete cookies from your browser via our Cookies Statement.

Job applications

If you apply for a job with Catch22 using our hosted online job application system, this service will be provided by a data processor on our behalf (SmartRecruiters).

To process your application, we ask for your personal details including name and contact details. We will ask you about your previous experience, education, referees and for answers to questions relevant to the role you have applied for. The hiring managers for the role, along with our Recruitment and HR teams will have access to all of this information.

Catch22 processes your job application data for the purpose of its legitimate interest to process your HR information.

• If you are successful, the information you provide during the application process will be retained by us as part of your employee file for the duration of your employment plus six years following the end of your employment.
• If you are unsuccessful at any stage of the process, the information you have provided until that point will be retained for six months from the closure of the campaign.
• Equal opportunities information is retained for six months following the closure of the campaign whether you are successful or not.

For more information, please see the SmartRecruiters privacy notice.

Job alerts

Through the SmartRecruiters job application system, it is also possible to sign up for job alerts, which will let you know when new jobs that meet your criteria have been posted.

These alerts are managed by the data processor (SmartRecruiters) on our behalf, and will only be processed using your freely-given, specific, informed and unambiguous consent.

If at any point you wish to unsubscribe from SmartRecruiters job alerts, this can be done by clicking the unsubscribe link on the latest email. You can also log into your SmartRecruiters candidate profile to modify or withdraw your details.

For more information, please see the SmartRecruiters privacy notice.

Email newsletter

If you subscribe to Catch22’s newsletter and/or event mailing lists, you will receive regular communications relating to our work. These mailings will be facilitated by a third-party provider, such as Mailchimp or Salesforce (marketing platforms), and your data will be processed by a third-party client relationship management platform, Salesforce.

Catch22 will only process your contact details and send you newsletters following your freely-given, specific, informed and unambiguous consent.

You have the right to unsubscribe from any of our email mailing lists at any time. If you wish to unsubscribe from a Catch22 mailing list please click the unsubscribe link on the latest email or contact dpo@catch-22.org.uk to ensure that you do not continue to receive email newsletters from us. We will need to continue to hold your details after you have unsubscribed to ensure that we do not send you further communications.

For more information, please see the Mailchimp or Salesforce privacy notices as appropriate.

Feedback and enquiries

Catch22 processes the data submitted through any of our website contact forms for the purpose of receiving your message and responding to it under the lawful basis of consent, which you give when submitting the form.

We will only use the information supplied to us to deal with the enquiry and any subsequent issues, and to check on the level of service we provide.

These contact forms are processed using the WordPress plugin, Gravity Forms. When these forms are submitted to us, notification emails are automatically generated to send your enquiry to the appropriate team within Catch22 who will store your email for as long as is required to deal with your enquiry and any subsequent issues.

Form submissions are also stored within the Catch22 WordPress database for a period of 90 days. This allows us to identify if there are any issues with forms being received by our teams. After this time, forms and all accompanying personal data are automatically deleted from the system. Gravity Forms does not receive copies of any of forms, or any accompanying personal data, that are submitted via the Catch22 website.

If using our online chat service, Click4Assitance, data collected through the chat service may be shared internally within Catch22  to provide support and improve services. 

You have the right to withdraw consent for us to contact you at any time by contacting dpo@catch-22.org.uk. You also have the right to lodge a complaint with a supervisory authority, which in the United Kingdom is the Information Commissioner’s Office.

For more information, please see the Gravity Forms privacy notice.

Complaints

Complaints can be submitted using our online feedback form, by emailing feedback@catch-22.org.uk, or by post. Catch22 undertakes the processing of your complaints data as part of its legitimate interests.

When we receive a complaint from a person we make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint.

We will only use the personal information we collect to process the complaint and to check on the level of service we provide.

We usually have to disclose the complainant’s identity to whoever the complaint is about. This is inevitable where, for example, the accuracy of a person’s record is in dispute. If a complainant doesn’t want information identifying him or her to be disclosed, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis.

We will keep personal information contained in complaint files in line with our retention policy. This means that information relating to a complaint will be retained for six years from closure. It will be retained in a secure environment and access to it will be restricted according to the ‘data minimisation’ principle.

For more information, please see the Complaints, Compliments and Feedback policy.

Use of data processors

The Data Processor (the organisation that does data processing on behalf of Catch22) is Totally.Tech.

Catch22 also works with third-party data processors to provide our:

• content management system (WordPress),
• website analytics (Google Analytics),
• marketing platform (Mailchimp),
• client relationship management platform (Salesforce),
• social media advertising campaigns (Meta Pixel, Twitter Pixel, LinkedIn Insight Tag, TikTok Pixel),
• online chat service (Click4Assitance), and
• recruitment service (SmartRecruiters).

We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it and retain it for the period we instruct.

Individual Catch22 services may work with additional third-party data processors in line with their contractual requirements. For more information, please see the relevant Service Privacy Notice, which can be downloaded from their service page on this website, or found by searching for the service by name in our Policy Library.

Disclosures

Catch22 may disclose information about you to any of our employees, officers, agents, suppliers or data processors insofar as reasonably necessary for the purposes as set out in this privacy notice.

In addition, we may disclose information about you:

• to the extent that we are required to do so by law,
• in connection with any legal proceedings or prospective legal proceedings, or
• in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).

Except as provided in this privacy notice, Catch22 will not provide your information to third parties without your consent.

Security of your personal data

Catch22 will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.

We will store all the personal information you provide on our secure, encrypted password and firewall protected servers. As data transmission over the internet is inherently insecure, we cannot guarantee the security of data sent over the internet.

Where information is held on our behalf by data processors, we will ensure, to the best of our ability, that they hold your information securely and in line with data protection legislation. We hold contracts with all data processors to make sure that they cannot do anything with your data unless we have instructed them to do so.

Notice amendments

We may update this privacy notice from time-to-time. Check this page occasionally to ensure you are happy with any changes.

Your rights

Please contact the Data Protection Officer if you have any queries regarding this Privacy Notice or if you would like to exercise or query any of the following rights afforded to you under the General Data Protection Regulation (GDPR):

• right to access
• right to erasure
• right to object
• right to rectification
• right to be informed
• right to restrict processing
• right to data portability
• rights in relation to automated decision making and profiling
• right to lodge a complaint with the Information Commissioners Office (ICO) – via the Complaints page on the ICO website or by calling 0303 123 1113

For further information on your rights, please visit the Individual Rights page on the ICO website.

Contact

If you have any questions about this privacy notice or of our treatment of your personal data, please email dpo@catch-22.org.uk or write to:

Data Protection Officer

Catch22
27 Pear Tree Street
London
EC1V 3AG

Data controller

Catch22’s data protection registration number is Z1473239

Bespoke Services: Privacy notice

Catch22 is a national organisation that works across England and Wales delivering services in a variety of settings. These include schools, colleges, social care, victim services, family support, prisons, apprenticeships and employment support.

We have been around for over 200 years and our focus is about making a difference to people by delivering our 3 ‘P’s – having good people around, having a good place to live/study/work, and having good purpose in life. Different services will focus on different aspects, but we aim to address those three elements to support people to thrive.

What does this service do?

Catch22’s Bespoke Service has been developing and delivering a wide range of services for over 30 years. Services are commissioned by schools, academies, local authorities and partner organisations on a one-off or long-term basis and are co-designed with commissioning organisations.

What information do we collect and why do we need it?

We will only ask you for data that is needed to deliver, monitor and evaluate our services. Some of the information will be obvious but if you have any queries about any of the information we ask you for or why we need it, then please ask us. The person referring your case to us will pass on the following information about you:

• Full name
• Age
• Address
• Contact number
• The background to your situation and any issues that Catch22 needs to be aware of (accessibility issues, support workers, health and safety concerns etc.)

We may ask you to give us some more sensitive information (also known as ‘special data’) like your gender, age, ethnicity, sexual orientation, religion and/or any disabilities. We will explain to you why we need this information, and you are free to refuse to give it if you do not wish to do so.

If we work with you on a 1 to 1 or family support basis, when we talk to you in person, we will ask you for further details about your situation.

What law applies and which bits set out the legal basis for us to collect and hold your personal information?

The two main pieces of law that apply are:

1. The UK General Data Protection Regulation
2. The Data Protection Act 2018

We do have to have a legal basis for processing your information and this is:

• performance of a contract (UKGDPR Article 6.1b)
• vital Interests (UKGDPR Article 6.1d)
• individual consent (UKGDPR Article 6.1a)

The ‘special category data’ that we collect must meet even more of a legal test and our legal basis for collecting this is:

explicit consent (UKGDPR Article 9.2a).

The Information Commissioner’s Office has given further guidance that sets out when these conditions can be used as the legal basis for processing your information and this can be supplied to you if you wish to see it.

Where did we get your data from?

The data we collect comes from you, from the person referring you to us or other professionals you have consented for us to talk to. They are required to obtain your consent from you to pass on that information and for us to contact you.

Who will we share your information with?

We will provide the person who referred the case to us with updates on whether you do or do not attend sessions.

We will only share information about you to other organisations where we have a record that you have agreed for your details to be passed on to another service to provide you with further or additional support.

Bespoke Services provides monitoring reports to our partners and referrers, but no personal or sensitive information is provided that will identify you. We do like to provide anonymised case studies, as well as anonymous evaluation and feedback, so that we can improve the service that we deliver.

We may have to share information if we are legally obliged to do so, for example where we have serious concerns about your safety or that of someone else associated with you. In these cases, we would share the relevant information with safeguarding organisations (Social Service, the Police or any other Emergency Service) if you or anyone else is at risk of harm. We will only share information where the law allows.

Catch22 securely stores all the information and data mentioned above and is only available to those people with authorised access.

Information sent between agencies is via email, with documents being encrypted with agreed passwords, and any other information being anonymised to ensure the information is not identifiable to you other than with the people working with you and whom the information is intended for.

How long will we hold on to your information for?

Your information will be held as ‘live’ for the period of time that you are engaging with Bespoke Services and then it will be held as archived until you are 25 years old. Sometimes there may be legal reasons we have to retain the information for a longer specified period of time and there may also be circumstances where it is appropriate within legal and best practice requirements to retain the information for a longer period, but we will make every effort to inform you of this.

What happens if the information in the records is wrong?

You will need to be specific about what information you think may be wrong and why, along with what you think we should do to correct it. If we cannot amend your record in the way you would like, we will explain the reason for this. We will always mark disputed records to show that the record is disputed. You will be able to see a copy of your amended record.

What rights do you have over the information that we hold on your behalf?

You have a number of rights over your data that we are required by law to uphold. You have the following rights:

• the right to be informed – how we will use your information
• the right of access – how to access information we hold about you
• the right to rectification – request that information that is held about you and is inaccurate or incomplete be rectified
• the right to erasure – requests that under special circumstance information held on you may be removed or deleted if applicable
• the right to restrict processing –block or suppress processing of information about you
• the right to data portability – obtain and re-use information held about you for your own purposes across different services if applicable
• the right to object – in certain circumstance you can object to processing of information about you.
• the right to withdraw consent – at any time where your information is being processed based on that consent.
• the right to lodge a complaint with the Information Commissioners Office (ICO)

If you feel we have not processed your data correctly and in accordance with UKGDPR and the Data Protection Act 2018, you have the right to make a complaint to the Information Commissioners Office (body that regulates Data Protection).

Please visit https://ico.org.uk/ or call 0303 123 1113 in order to lodge a complaint with the regulator.

Contact

If you would like to discuss anything in this privacy notice, please contact: Data Protection Officer Catch22, on DPO@Catch-22.org.uk.

Last updated:

We may need to update this privacy notice periodically, so we recommend that you revisit this information from time to time. This version was last updated January 2022.