CONNECT PSYCHOLOGICAL SERVICES LIMITED
Connect Psychological Services Limited (Company) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
This privacy notice aims to give you information on how the Company collects and processes your personal data through your use of this website.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
The sites under the domain name and associated sub-domains of https://www.connect-ps.co.uk are operated by the Company.
Connect Psychological Services Limited is the controller and responsible for your personal data (collectively referred to as the Company, “we”, “us” or “our” in this privacy notice).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact please contact us in writing, by email or telephone using the details shown in paragraph 16 below.
3. THIRD-PARTY LINKS
This 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.
4. About the information we collect and hold
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together in the table set out in the Schedule.
We seek to ensure that our information collection and processing is always proportionate. We will notify you of any changes to information we collect or to the purposes for which we collect and process it.
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
5. How is your personal data collected?
We use different methods to collect data from and about you including through:
5.1 Direct interactions. You may give us your identity, contact and financial data by filling in forms or by corresponding with us by post, phone, email or otherwise.
5.3 Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
5.3.1 Technical data from the following parties:
(a) analytics providers such as Google;
(b) advertising networks; and
(c) search information providers.
5.3.2 Contact, financial and transaction data from providers of technical, payment and delivery services.
5.3.3 Identity and contact data from data brokers or aggregators.
5.3.4 Identity and contact data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
6. How we use your personal data
The main purposes/activities for which we process your personal data are summarised in the table in the Schedule and include the following:
6.1 To register you as a new client.
6.2 To provide you with our products and services.
6.3 To manage payments, fees and charges and collect and recover money owed to us.
6.4 To communicate with you and manage our relationship, which will include:
6.4.1 Providing you with updates you have requested;
6.4.3 Asking you to leave a review or take a survey.
6.5 To enable you to partake in a prize draw, competition or complete a survey.
6.6 To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
6.7 To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
6.8 To use data analytics to improve our website, products or services, marketing, client relationships and experiences.
6.9 To make suggestions and recommendations to you about products or services that may be of interest to you.
We may need to share some of the categories of personal information with other parties as set out in the Schedule. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
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 we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us in writing, by email or telephone using the details shown in paragraph 16 below.
7. Marketing & Promotional Offers
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your identity, contact, technical, usage and profile data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing
Opting out: We will get your express opt-in consent before we share your personal data with any third party or company outside the Company for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by email@example.com at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product or service purchase, warranty registration, product or service experience or other transactions.
9. Disclosures of your personal data
As outlined in the table in the Schedule, we may need to share your personal data with third parties, examples of which are listed below:
9.1 Internal third parties, being other group companies acting as joint controllers or processors.
9.2 External third parties as follows:
9.2.1 Service providers who provide IT and system administration services.
9.2.2 Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
9.2.3 HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
10. International transfers of Information
We do not ordinarily transfer your personal data outside the European Economic Area (EEA).
However, if we do need to transfer your personal data out of the EEA, we will ensure that any such transfer is made securely and that there is adequate protection in place in order to protect your personal data, as required by the Data Protection Act 2018 and the provisions of Regulation (EU) 2016/679, including requiring the transferee to enter into model contractual clauses or (if US based) being a member of the Privacy Shield.
If we ever transfer your personal data outside the EEA you can ask us for a copy of relevant safeguards.
11. How long we keep your information
We keep your information during and after your custom with us for no longer than is necessary for the purposes for which the personal information is processed, 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.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
12. Your rights to correct and access your information and to ask for it to be erased
Your rights in connection with personal information
12.1 Under certain circumstances, by law you have the right to:
Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
Object to 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.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact in writing, by email or telephone using the details shown in paragraph 16 below.
No fee usually required
12.2 You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you
12.3 We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure we take to ensure that personal information is not disclosed to any person who has no right to receive it.
13. Keeping your personal information secure
The information you supply to us will be held on our servers located in datacentres hosted by one or more approved providers.
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
14. CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This version was last updated on 13 March 2020.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
15. Contacts & complaints
If you have any questions about how we treat and protect your personal data and your privacy, if you have any comments, wish to seek to exercise any of your rights as outlined above or to complain, please contact Connect Psychological Services Limited, Merlin House, Halesfield 19, Telford, TF7 4QT or by email at firstname.lastname@example.org or by telephone on 01952 445390 for the attention of Gemma Clarke.
We hope that we can resolve any query or concern you raise about our use of your information. If not, you may contact the Information Commissioner at ico.org.uk/concerns/ or telephone: 0303 123 1113 for further information about your rights and how to make a formal complaint.
|The information we collect||How we collect the information||Why we collect the information||How we use and may share the information|
|Identity data including first name, maiden name, last name or similar identifier, marital status, title, date of birth, gender and employment information.||From you||To enter into/perform our contract with you Legitimate interest: to ensure that you are properly identified as a client and that we are able to perform our obligations under our contract with you on an on-going basis Where we need to comply with a legal or regulatory obligation||To enter into/perform our contract with you|
|Contact data, including addresses, email addresses and telephone numbers.||From you From selected third parties such as data brokers or aggregators From publicly available sources such as Companies House and the Electoral Register||To enter into/perform our contract with you Legitimate interest: to ensure that you are properly identified as a client and that we are able to perform our obligations under our contract with you on an on-going basis||To enter into/perform our contract with you|
|Financial data including bank account details, billing information, payment card details and credit history, information to enable us to undertake credit or other financial checks on you||From you From selected third parties including credit reference agencies||To enter into/perform our contract with you Legitimate interest: to establish your ability to make payments to us under our contract with you, and to obtain such payments||To enter into/perform our contract with you To establish your ability to make payments to us and to obtain such payments|
|Contract and transaction data including details about payments to and from you and other details of products and services you have purchased from us, contact history, purchase history, saved items||From you Automatically from our information technology systems and our client relationship management software From providers of technical payment and delivery services||To enter into/perform our contract with you Legitimate interest: to keep our records up to date Legitimate interest: to monitor how clients use our products and services for the purposes of business management and planning and to identify whether any other products or services may be of interest to you||To enter into/perform our contract with you To keep our records up to date For business management and planning To identify future customer demand|
|Your family, friends and other contacts’ identity data including first name, maiden name, last name or similar identifier, marital status, title, date of birth and gender, and contact data, including addresses, email addresses||From you||To enter into/perform our contract with you Legitimate interest: To ensure we are able to comply with our obligations under our contract with you if we are unable to communicate with you directly provided that this does not affect your/their interests, rights and freedom||To enter into/perform our contract with you|
|Information involving feedback, questions and complaints received by us from you in relation to our products and services and your responses to surveys, competitions and promotions||From you||To enter into/perform our contract with you Legitimate interest: to maintain accurate records and to comply with legal, regulatory and corporate governance obligations and good practice||To perform our contract with you To maintain accurate records and to comply with legal, regulatory and corporate governance obligations and good practice|
|Technical data, including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our websites||Automatically as you interact with our websites by using cookies, server logs and other similar technologies. We may also receive this data about you if you visit other websites employing our cookies. Please see our Cookie Policies on our websites for further details||Legitimate interest: to ensure that our websites are user friendly and work for you and other clients Legitimate interest: to define types of clients for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy||To ensure that our websites are user friendly and work for you and other clients To define types of clients for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy We may share this information with selected third parties including our information technology and marketing advisers|
|Profile data, including your username and password, location, purchases or orders made by you, your interests, preferences, feedback and survey responses, personal or professional interests, information from accounts you link to us e.g. Facebook||From you Automatically as you interact with our websites by using cookies, server logs and other similar technologies. We may also receive this data about you if you visit other websites employing our cookies||Legitimate interest: to define types of clients for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy||To define types of clients for our products and services, to keep our website/records updated and relevant, to develop our business and to inform our marketing strategy To study how clients use our products/services We may share this information with selected third parties, including our information technology and marketing advisers|
|Usage data, including information about how you use our websites, products and services||From you Automatically as you interact with our websites by using cookies, server logs and other similar technologies. We may also receive this data about you if you visit other websites employing our cookies||Legitimate interest: to ensure that our websites are user friendly and work for you and other clients Legitimate interest: to define types of clients for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy||To ensure that our websites are user friendly and work for you and other clients To define types of clients for our products and services, to keep our website/records updated and relevant, to develop our business and to inform our marketing strategy We may share this information with selected third parties, including our marketing advisers|
|Marketing and communications data, including your preferences in receiving marketing from us and our third parties and your communication preferences||From you||Legitimate interest: to keep our records up to date and to understand how you wish for us to communicate with you||To enter into/perform our contract with you To keep our records up to date and to understand how you wish for us to communicate with you|