Privacy Policy

At Listening Tree CIC we care deeply about the children, young people, families, school staff and other professionals we offer support and training to. As such we take your privacy very seriously, treating any information you give us with great care. We will ensure any personal information you provide to us is protected using secure systems and processes.

At all time we strive to ensure these comply with the EU general Data Protection Regulation (GDPR), the Privacy and Electronic Communications Regulations (PECR) and other relevant legislation.

This policy explains how we collect and use the personal information you provide to us. By using our website, any of our services, or providing us with any personal information we will assume you are agreeing to your information being used and disclosed in the ways described in this policy.

About us

Listening Tree is a Community Interest Company. We look to provide support both directly and indirectly to children, young people, school staff and other professionals through training, supervision and consultancy.

Any questions in relation to this policy or how we use this information you can get in touch via the details in the contact us section of this Privacy Policy.

How and when we collect data

There are several ways we may collect and store personal data, examples of this include when you:

Get in touch with us via phone, website, email or other method of communication
Tell us your story
Submit an enquiry
Register for or use our services
Participate in our training
Give us feedback
Make a complaint
Apply for a job
Register for a counselling placement
Enter into a contract with us

Please note this is not an exhaustive list but aims to offer an overview on this topic.

What information we might collect

When you engage with us via any of the means as listed above we may collect information about you (referred to in this policy as ‘personal information’). This may include:

Name
Address
Email address
Telephone number
Date of birth
Job title and details of your education and career
Why you are interested in Listening Tree CIC
Other information relating to you personally which you may choose to provide us with such as diversity information.
Social, family or health issues connected to your referral

Please note this is not an exhaustive list but that all personal information collected will be processed in accordance with the approach outlined in the Privacy Policy.

Data protection law also recognise that certain types of personal information are more sensitive than others- these are known as ‘sensitive’ or ‘special category’ personal information. These include information such as racial or ethnic origin, religion, philosophical beliefs and political opinions, trade union, sexual orientation or information concerning your physical and mental health. This would only be collected with your explicit consent, when necessary and only accessible to relevant staff.

Children’s Data

Due to our service working with children and young people we are required to hold personal information of those using our services. These details are only held with the explicit consent of the child’s parents/guardian or a young person themselves if they are Fraser competent. Their details are kept securely with restricted access and handled with the greatest respect for privacy.

How and why we use your information

We use the personal information you give us, where relevant, for:

Responding to a request
Marketing: if you specifically consent we may use your email, SMS, or phone to provide you with marketing information about our services which you can opt out of at any point.
Monitoring and evaluation: Your information may be used by us to improve current and future delivery of our services. If diversity information is collected on an individual, all reporting will be anonymised
Processing an application to work with us: We may process your information if you send or fill in an application form or send us your CV or details in respect of an opportunity to work with us in order to evaluate your suitability, respond to you and take steps to possible enter into a contract with you.
Transactional purposes: We will need to use your personal information in order to carry out our obligations arising from any contracts entered into between you and us for goods or services, for example, processing your order.
Using our website: We may use your personal information to help provide you with access to our website, personalise your experience, and improve and develop it further.
Counsellor Placements: Should you become a counsellor with us, we will need your personal information in order to process your placement with us.
Administration: We may use your personal information to record and deal with a complaint, record a request not to receive further marketing information, record what our counsellors on placement have done for us, and for other necessary internal record keeping purposes.
Protecting your vital interests: We may process your personal information where we reasonably think that there is a risk of serious harm or abuse to you or someone else.
Legal, regulatory and tax compliance: Where we are subject to a legal obligation, we may process your personal information to fulfil that obligation.

Who do we share your information with?

We will only use your information for the purposes it was obtained for and not share this with third parties for their own purposes. Information may be shared with counsellors within our services all of whom are required to have professional clinical supervision and may, when necessary, discuss client personal information in confidence with their professional supervisor. With your agreement and for the promotion of your welfare we may also share certain information you provide to us with other healthcare professionals, social or welfare organisations, government agencies, family members or others representing you. We will not break confidentiality without your agreement except in limited circumstances, and we will always tell you about this first if the law allows us to. These limited circumstances include:

If you disclose an intention to commit suicide or cause harm to yourself or another person
If we are concerned about your health or behaviour, and we believe you are not able to perceive this, we may need to seek further help
If we are required by a Court of Law, or you disclose issues where a legal duty may stop us from keep confidentiality (examples include matters relating to Terrorism, Money Laundering or Child Protection)

How do we protect your information?

Listening Tree CIC is committed to the protection and security of your personal information. We take all appropriate technical and organisational security measures to safeguard personal information. Access to information is strictly limited on a need-to-know basis and that we take appropriate measures to ensure those using it comply with this Privacy Policy. We also regularly review who has access to such information to ensure only those appropriate can view it.

Should you have any concerns around misuse or loss of or unauthorised access to your personal information please let us know immediately via the details given in the ‘contact us’ section of this Privacy Policy so we can investigate and rectify this in a timely and efficient manner.

How long will we hold your information?

Information will be held as long as it appropriate when using our services as dictated by law, such as for tax purposes, or by our organisational, professional and indemnity bodies require us to do so. This may be for up to six years after leaving our services, or for under 18’s accessing our services this will be six years after their eighteenth birthday. Please note in some circumstances we may hold this information longer if for example we believe in good faith that the law or relevant regulators require us to preserve your data.

Your rights

As outlined under data protection legislation you have a number of rights regarding your personal information:

Right to be informed
Right to access
Right to rectification
Right to erasure
Right to restrict processing
Right to data portability
Right to lodge a complaint with a supervisory authority

Right to be informed

You have the right to know how your personal information will be used and why it is needed, this has been the aim of this Privacy Policy but should you have further questions you can direct them to the details given in the ‘Contact us’ section.

Right to access

You may ask us to confirm what personal information of yours we hold about you at any time, and request us to modify, update or delete such information. We may ask you for more information about your request. If we provide you with access to the information we hold about you, we will not charge you for this unless your request is "manifestly unfounded or excessive". If you request further copies of this information from us, we may charge you a reasonable administrative cost. Where we are legally permitted to do so, we may refuse your request. If we refuse your request we will always tell you the reasons for doing so.

Right to rectification

You also have the right to request that we rectify any inaccurate or incomplete personal information that we hold about you, including by means of providing a supplementary statement. If we have shared this personal information with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. You may also request details of the third parties that we have disclosed the inaccurate or incomplete personal information to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.

Right to erasure

You have the right to request that we "erase" your personal information in certain circumstances. Normally, the information must meet one of the following criteria:

The data are no longer necessary for the purpose for which we originally collected and/or processed them;
Where previously given, you have withdrawn your consent to us processing your data, and there is no other valid reason for us to continue processing;
The data has been processed unlawfully (i.e. in a manner which does not comply with the GDPR);
It is necessary for the data to be erased in order for us to comply with our obligations as a data controller under EU or Member State law; or
If we process the data because we believe it necessary to do so for our legitimate interests, you object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing.

We would only be entitled to refuse to comply with your request for one of the following reasons:

To exercise the right of freedom of expression and information;
To comply with legal obligations or for the performance of a public interest task or exercise of official authority;
For public health reasons in the public interest;
For archival, research or statistical purposes; or
To exercise or defend a legal claim.

When complying with a valid request for the erasure of data we will take all reasonably practicable steps to delete the relevant data.

Right to restrict processing

You have the right to request that we restrict our processing of your personal information in certain circumstances. This means that we can only continue to store your data and will not be able to carry out any further processing activities with it until either: (i) one of the circumstances listed below is resolved; (ii) you consent; or (iii) further processing is necessary for either the establishment, exercise or defence of legal claims, the protection of the rights of another individual, or reasons of important EU or Member State public interest.
The circumstances in which you are entitled to request that we restrict the processing of your personal information are:

Where you dispute the accuracy of the personal information that we are processing about you. In this case, our processing of your personal information will be restricted for the period during which the accuracy of the data is verified;
Where you object to our processing of your personal information for our legitimate interests. Here, you can request that the data be restricted while we verify our grounds for processing your personal information;
Where our processing of your data is unlawful, but you would prefer us to restrict our processing of it rather than erasing it; and
Where we have no further need to process your personal information but you require the data to establish, exercise, or defend legal claims.

If we have shared your personal information with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal information.

Right of data portability

If you wish, you have the right to transfer your personal information between data controllers. In effect, this means that you are able to transfer the details we hold on you to a third party. To allow you to do so, we will provide you with your data in a commonly used machine-readable format so that you can transfer the data to a third party. Alternatively, we may directly transfer the data for you. This right of data portability applies to: (i) personal information that we process automatically (i.e. without any human intervention); (ii) personal information provided by you; and (iii) personal information that we process based on your consent or in order to fulfil a contract.

Right to lodge a complaint with a supervisory authority

You also have the right to lodge a complaint with your local supervisory authority which is the Information Commissioner's Office in the UK. You can contact them in the following ways:

Phone: 0303 123 1113
Email: casework@ico.org.uk
ICO.org.uk via Live chat
Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

If you wish for any further information regarding our Privacy Policy, like any further information or wish to raise a concern or make a formal complaint please contact us via:

Data Privacy Manager: info@listeningtree.org.uk

We will always aim to deal with these in a timely, professional and effective manner. If you are not happy with our response you may raise your concern with our independent statutory body via the information in the section above.

(last updated: 13th March 2019)