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Institute of Counselling
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Privacy Policy

Protecting Your Privacy
Institute of Counselling www.instituteofcounselling.ac.uk.

Privacy Notice

Contents of Privacy Notice

1. Introduction.
2. About the Institute of Counselling.
3. The legal bases for collecting and processing your personal data that we rely on.
4. When do we collect your personal data?
5. How and why do we use your personal data?
6. How we store and protect your personal data?
7. Who do we share your personal data with?
8. What are your rights over your personal data?
9. How you can stop us using your personal data to communicate with you through email marketing?
10. Any Questions?


May 2018.

1 Introduction
This Privacy Notice explains, precisely, the types of personal data that we may collect about you when you interact with us. It will also explain how we’ll store and handle that data, and keep it safe.
We want you to be fully informed about how the Institute of Counselling uses your data; we will explain how we store and handle your data in order to build a picture of you.

We hope the following sections of our Privacy Notice will answer any queries or questions you might have, however if it does not, then please don’t hesitate to get in contact our Data Protection Officers at email:  admin@instituteofcounselling.ac.uk    

It is possible that we’ll need to update this Privacy Notice on various occasions in the future, we will notify of any significant changes to our Privacy Notice, but you are welcome to check this whenever you choose.
When you are using the Institute of Counselling website, the Institute of Counselling is the data controller. 

2 About the Institute of Counselling

2.1 The Institute of Counselling provides a wide range of counselling and therapy related courses to students who have enrolled with them.

2.2 The website and other online products and services through which you engage any services are owned by the Institute of Counselling (“we”, “us”, “our”) a company and charity registered in Scotland. The Institute of Counselling is a registered charity in Scotland (number 034878) whose registered office is at 40 St. Enoch Square, Glasgow G1 4DH. We are the data controller for the Site.

3 The legal bases for collecting and processing your personal data that we rely on
The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:

3.1 Consent
In certain situations, we can gather and process your data with your consent.
For example, when you tick a box to receive emails or marketing information.
When collecting your personal data, we’ll always clearly communicate to you which data is necessary in connection to carrying out a particular service.

3.2 Contractual obligations
In some circumstances, we will require your personal data in order to comply with our contractual obligations. 
For example, when you enrol on a course with us, we’ll collect your email address in order to send your purchase to you and your home address in order to send out your award/qualification to you.

3.3 Legal compliance
If the law requires us to, we may need to collect and process your data.  
For example, we can pass on the details of people involved in criminal activity, such as fraud.

3.4 Legitimate interest
In certain situations, we will require your data to pursue our legitimate interests in a manner that might reasonably be expected as part of operating our business and which does not materially impact your rights, interests or freedom.
For example, we will use your purchase history to communicate to you or make personalised available offers. 
We also combine the enrolment history of many customers to identify trends in order to keep up with demand, or develop new relevant products/services. 

4 When do we collect your personal data?

4.1 When you make an online purchase such as an enrolment on a course or acquiring a membership. (we would store this transaction-based data).

4.2 When you comment on, or review one of our products or services.

4.3 When you visit our website, and use your account to purchase products and services.

4.4 When you create an account with us.

4.5 When you contact our organisation with questions or complaints, etc.

4.6 When you decide to complete a survey or questionnaire that we send you.

4.7 When you have signed up to one of our membership offers.

5 How and why do we use your personal data?

We aim to give our customers (students, members, enquirers, purchasers)  the best possible experience. One method of achieving this aim is to combine the data we have about you.
We will then use this data to offer you products, services and promotions that are relevant to you and that are likely to interest you.
The data privacy law allows this as part of our legitimate interest in achieving an understanding of our customers and providing our customers with high level service.
If you would like to change how we use your data, you’ll find details in the ‘What are my rights?’ section below.
Remember, if you choose not to share your personal data with us, or refuse specific contact permissions, we might not be able to provide some services to you.
For example, new course information. We can’t provide you with this information if you’ve withdrawn your general consent to hearing about this from us.

Here’s how we’ll use your personal data and why:

•To respond to your questions, complaints and refund requests. Handling the information you sent us will enable us to respond. We may also keep a record of these interactions to inform any future communication you have with us and how we communicated with you throughout these interactions. We do this on the basis of our contractual, legal obligations and our legitimate interests in providing you with a high quality service and an informed understanding of how we can improve our service based on your experience.
•To protect our organisation and your account from illegal activities such as fraud. This includes using your personal data to update, maintain and safeguard your account. We’ll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We’ll do all of this as part of our legitimate interest.
•To process payments and to prevent fraudulent transactions on the basis of our legitimate business interests and to protect our customers from fraud.
•With your consent, we will use your personal data, preferences and details of your transactions to inform you by email about relevant products and services including, discounts, tailored special offers, new course information and membership information.

Of course, you are free to opt out of hearing from us through these communication channels at any time.

•To send you communications required by law or to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice and legally required information relating to your orders. These service messages do not require prior consent when sent by email and do not contain any promotional content. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
•To comply with our legal or contractual obligations to share data with law enforcement.

For example, when a court order is submitted to share data with a court of law or law enforcement.
•To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email. We have a legitimate interest to do so as this helps make our products or services more relevant to you.

To send you surveys and questionnaires requesting feedback to help improve our services. These surveys and questionnaires do not require prior consent when sent to customers by email. We have a legitimate interest in carrying this out as it will be used to improve our service and products through enhancing their quality and relevance.

6 How we store and protect your personal data?

All information you provide to us is held on secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the site. We recommend that you do not share it with anyone else.
We know the importance of data security matters to all our customers. We therefore take all available steps to protect your personal data treat it with extreme care.
Access to your personal data is password-protected and where printed locked in a filing cabinet. 
We take measures to monitor our systems for possible attacks and threats to their security.

7 Who do we share your personal data with?

•We may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.
•We may also be required to disclose your personal data to law enforcement regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. We will make decisions regarding these requests on a case-by-case basis and will always consider the privacy of customers.
•IT companies who support our website and other business systems.

If you require further information then please contact our Data Protection Officers at admin@instituteofcounselling.ac.uk 

8. What are your rights over your personal data?

Your rights regarding your personal data:
You have the right to request:
•Access to the personal data that we hold about you, free of charge.
•That we stop any consent-based processing of your personal data after you withdraw that consent.
•A correction, when your personal data is incorrect, is not complete or has become out of date.
You have the right to request a copy of any information that we hold about you and to have that information corrected if it is inaccurate. To ask for your information, please contact the Data Protection Officers. 
To ask to have your information amended, contact our Student Services Administration Team by email at admin@instituteofcounselling.ac.uk

If we choose not to action your request we will explain to you the reasons for our refusal.

Your right to withdraw consent
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
 
Where we rely on our legitimate interest
In cases, where on the basis of our legitimate interest, we are processing your data, you can ask us to stop. We must then comply with this unless we believe we have a legitimate overriding reason to carry on with processing your personal data.

Checking your identity
We will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. This is to protect the confidentiality of your information.

9. How you can stop us using your personal data to communicate with you through email marketing?

You can stop email marketing communications from us:
•Click the ‘unsubscribe’ link located in any emails that we send you. We will then stop these email marketing communications being sent to you.

10 Any Questions?

We hope you have found this Privacy Notice helpful in explaining the way we handle your personal data and your rights to control it.
If you have any questions then please contact our Data Protection Officers who will be happy to help you:

Email us at: admin@instituteofcounselling.ac.uk 

Telephone us at: 0141, 204, 2230