Privacy and Cookies Policy

The Counselling Pastoral Trust Privacy Policy may change so please remember to check back from time to time, this is version 0.1. It was last updated on the 23rd May 2018. Where we have made any changes to this Privacy Policy, we will make this clear on our website or contact you about any changes.

1. Who we are

The Counselling Pastoral Trust is a Company Limited by Guarantee, founded on 27th August 1993, registered in England and Wales, number: 2848495.

CPT is also a Registered Charity number: 1027526. CPT’s Registered Office address is First Floor, 116 Long Acre, Covent Garden, London WC2E 9PA

The Schema Therapy Institute, London, and its training programmes were established by the Counselling Pastoral Trust (CPT) in 2009.

The Counselling Pastoral Trust is committed to protecting your personal information and making every effort to ensure that your personal information is processed in a fair, open and transparent manner.

We are a “data controller” for the purposes of the Data Protection Act 1998 and (from 25 May 2018) the EU General Data Protection Regulation 2016/679 (“Data Protection Law”).  This means that we are responsible for, and control the processing of, your personal information.

For further information about our privacy practices, please contact our Data Protection Officer by:

• Writing to CPT, Langley House, First floor, 116 Long Acre, Covent Garden. London. WC2E 9PA.
• Calling us on 020 7384 9212
• Emailing to info@counsellingpastoraltrust.org

2. How we collect information about you

 You may be asked to provide your personal information anytime you are in contact with CPT and its affiliates (Schema Therapy Institute, London) and may share this personal information with each other to provide and improve our services, but will always be used in accordance with this Privacy Policy.

Everything we do, we do to ensure that we can help people experiencing a mental health problem get both support and respect. We want to make sure you receive the communications that are most relevant to you, be it through visiting our website or receiving emails, post or phone calls. We want to make sure you receive the best attention when you book on an event, receive our services or make a donation.

We collect information from you in the following ways:

When you interact with us directly: This could be if you ask us about our activities, register with us for training or an event, make a donation to us, ask a question about mental health, make a purchase, apply for a job or volunteering opportunity or otherwise provide us with your personal information. This includes when you phone or email us, visit our website, make a purchase from our shops, receiving our services or get in touch through the post, or in person.

When you interact with us through third parties: This could be if you provide a donation through a third party that we work with and provide your consent for your personal information to be shared with us.

Our website uses Google analytics, a service which transmits website traffic data to google servers in the US. Google analytics does not identify individual users or associate your IP address with any other data held by Google. We use reports provided by Google Analytics to help us understand website traffic and web page usage.

We may also use “cookies” to help our site run effectively. (See section 11 on ‘Cookies’ below for further information).

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.

3. Information we collect and why we use it

Personal Information

Personal information we collect includes details such as your name, date of birth, email address, postal address, telephone number, credit/debit card details (if you are making a purchase or donation), physical and mental health information, nationality, marital status, racial or ethnic origin, religion as well as information you provide in any communications between us. You will have given us this information whilst making a donation, registering for an event or any of the other ways to interact with us.

We will mainly use this information:

• To process your donations or other payments, to claim Gift Aid on your donations and verify any financial transactions.
• To provide the services or goods that you have requested.
• To update you with important administrative messages about your donation, an event, services or goods you have requested, or changes to our terms, conditions and policies.
• 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.

Because this information is important to your interaction with CPT, you may not opt out of receiving these communications.

We may also use your personal information:

• To contact you about our work and how you can support CPT (see section 8 on ‘Marketing’ below for further information).
• To invite you to participate in surveys or research.
• To develop, operate, deliver, and improve the quality of the care we provide or, more generally, the type of services that we offer.
• For internal purposes such as auditing, data analysis, and research to improve our services and our communication with you.
• To test our computer systems such as the software we use to store your health, social and care records to improve our services.

Sensitive Personal Information

If you provide us with any Sensitive Personal Information by telephone, email or by other means, we will treat that information with extra care and confidentiality and always in accordance with this Privacy Policy.

A special note about the Sensitive Personal Information we hold   

Data Protection Law 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.

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 express permission 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.

4. Profiling: making our work more unique to you

We want to improve how we talk to you and the information we provide through our website, services, products and information. To do this we sometimes use profiling and screening methods so that we can better understand our supporters, your preferences and needs to provide a better experience for you.

We may carry out targeted fundraising activities using profiling techniques based on the information that we hold about you. We may also work with third party organisations who provide additional insight, this may include providing wealth screening information or general information about you that is publicly available.

This information can be appended to the information that you have provided which allows us to use our resources more effectively by better understanding the background of our supporters and making appropriate requests based on what may interest them and their capacity to give.

You can opt out of this activity at any time by email at ‘info@counsellingpastoraltrust.org’ with the subject line ‘Please stop analysis of my data’ or by contacting our team at CPT on the address and telephone number listed in Section 1.

5. Legal basis for using 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.

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 CPT to do so to help us achieve our mission.

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, students and clients are, improving our services, for our legal purposes (for example, dealing with complaints and claims), or for complying with guidance from the Charity Commission.

6. Marketing

We will only contact you about our services, events, relevant information on mental health and how you can support CPT by email, phone or text message, if you have agreed for us to contact you in this manner.

However, if you have provided us with your postal address we may send you information about our work and how you can support CPT by mail unless you have told us that you would prefer not to hear from us in that way.

We use MailChimp as our marketing automation platform.  The contact information you provide will be transferred to MailChimp for processing in accordance with their Privacyand Terms.

You can update your communication preferences or opt out anytime by contacting ‘info@counsellingpastoraltrust.org’ or clicking the relevant links in the footer of any email you receive from us.

7. Sharing your Information

The personal information we collect about you will only be used by our staff (and volunteers) at CPT so that they can support you.

We will not sell, share or give information or web browsing activity to third parties for marketing purposes.

CPT may however share your information with our trusted partners and suppliers who work with us on or on our behalf to deliver our services, but processing of this information is always carried out under our instruction. We make sure that they store the data securely, delete it when they no longer need it and never use it for any other purposes. Some examples of where we may share your information are with our fulfilment partners who help to create and send information to you to reduce our costs, with our partners who help us to process donations and claim Gift Aid and our partners who help us to manage our social media accounts.

We enter into contracts with these service providers that require them to comply with Data Protection Laws and ensure that they have appropriate controls in place to secure your information.

Legal disclosure

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 sale and other agreements.

8. Keeping your information safe

We take looking after your information very seriously.  The personal information we collect is stored in a variety of paper and electronic forms. 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.

Access is limited only to those of our employees who need to access it to provide services to you.

All members of staff are required to undertake annual data protection and confidentiality training and our privacy and security guidelines are communicated to all CPT staff. These privacy safeguards are monitored and strictly enforced. We send any information that we need to share with any third parties either as a legal requirement or through an anonymised process securely.

All data is stored on servers within data centres in the UK, although at times they may be temporarily outside the UK but within the EU.

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 advertisers or 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.

9. How long we hold your information for

We only keep it as long as is reasonable and necessary for the relevant activity, which may be to fulfil statutory obligations (for example, the collection of Gift Aid).

10. Your rights

You have various rights in respect of the personal information we hold about you – these are set out in more detail below.  If you wish to exercise any of these rights or make a complaint, you can do so by contacting our team at CPT on the address and telephone number listed in Section 1.

You can also make a complaint to to the data protection supervisory authority, the Information Commissioner’s Office, https://ico.org.uk/

• Access to your personal information: You have the right to request access to a copy of the personal information that we hold about you, along with information on what personal information we use, why we use it, who we share it with, how long we keep it for and whether it has been used for any automated decision making. You can make a request for access free of charge.  Please make all requests for access in writing, and provide us with evidence of your identity.
• Right to object: You can object to our processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.  Please contact us as noted above, providing details of your objection.
• Consent: If you have given us your consent to use personal information (for example, for marketing), you can withdraw your consent at any time.
• Rectification: You can ask us to change or complete any inaccurate or incomplete personal information held about you.
• Erasure: You can ask us to delete your personal information where it is no longer necessary for us to use it, you have withdrawn consent, or where we have no lawful basis for keeping it.
• Portability: You can ask us to provide you or a third party with some of the personal information that we hold about you in a structured, commonly used, electronic form, so it can be easily transferred.
• Restriction: You can ask us to restrict the personal information we use about you where you have asked for it to be erased or where you have objected to our use of it.
• No automated-decision making:  Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention.  You have the right not to be subject to automated decisions that will create legal effects or have a similar significant impact on you, unless you have given us your consent, it is necessary for a contract between you and us or is otherwise permitted by law.  You also have certain rights to challenge decisions made about you.  We do not currently carry out any automated decision-making.

Please note, some of these rights only apply in certain circumstances and we may not be able to fulfil every request.

11. Cookies

‘Cookie‘ is a name for a small file, usually of letters and numbers, which is downloaded onto your device, like your computer, mobile phone or table when you visit a website.

They let websites recognise your device, so that the sites can work more effectively, and also gather information about how you use the site. A cookie, by itself, can’t be used to identify you.

How do we use cookies?

We use cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you come to our website and also allows us to improve the user experience.

The cookies we use

We use the categorisation set out by the International Chamber of Commerce in their UK Cookie Guide.

We use all four categories of cookies:

• Strictly necessary cookies are essential for you to move around our website and to use its features, like our shopping basket and your account.
• Performance cookies collect anonymous information about how you use our site, like which pages are visited most.
• Functionality cookies collect anonymous information that remember choices you make to improve your experience, like your text size or location. They may also be used to provide services you have asked for such as watching a video or commenting on a blog.
• Targeting or advertising cookies collect information about your browsing habits in order to make advertising relevant to you and your interests.

No cookies, please

You can opt out of all our cookies (except the strictly necessary ones). Find out how to control and delete cookies in your browser.

But, if you choose to refuse all cookies, our website may not function for you as we would like it to.

If you have any questions about how we use cookies, please contact our team at CPT on the address and telephone number listed in Section 1.

12. Monitoring

Your communications with our teams (including by telephone or email) may be monitored and/or recorded for training, quality control and compliance purposes to ensure that we continuously improve our customer service standards.

To find out more about this policy and how we look after your personal information, contact our team at CPT on the address and telephone number listed in Section 1