Privacy Notice
Green Ways Therapy & Green Ways Wellbeing CIC
Customer Privacy Notice
Registered name: Green Ways Therapy and Green Ways Wellbeing CIC
We are the controller of your personal data. For more information on controllers and their responsibilities please see our guidance on data protection principles, definitions, and key terms.
This privacy notice tells you what to expect us to do with your personal information.
Contact details
hello@greenwayswellbeing.co.uk
What information we collect, use, and why
We collect or use the following information to provide services and goods, including delivery:
Names and contact details
Addresses
Date of birth
Health information (including dietary requirements, allergies and health conditions)
Health and safety information
We also collect or use the following special category information to provide services and goods, including delivery. This information is subject to additional protection due to its sensitive nature:
Health information
We collect or use the following information for the operation of customer accounts and guarantees:
Names and contact details
Addresses
Information used for security purposes
Marketing preferences
We collect or use the following information for service updates or marketing purposes:
Names and contact details
Addresses
Marketing preferences
Records of consent, where appropriate
We collect or use the following information to comply with legal requirements:
Name
Contact information
Safeguarding information
We collect or use the following personal information for dealing with queries, complaints or claims:
Names and contact details
Address
Lawful bases and data protection rights
Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:
Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.
Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.
Your right to erasure - You have the right to ask us to delete your personal information. Read more about the right to erasure.
Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.
Your right to object to processing - You have the right to object to the processing of your personal data. Read more about the right to object to processing.
Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability.
Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.
If you make a request, we must respond to you without undue delay and in any event within one month.
To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.
Our lawful bases for the collection and use of your data
Our lawful bases for collecting or using personal information to provide services and goods are:
Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
We have a legitimate interest in collecting and using personal information in order to provide counselling and wellbeing services, respond to enquiries, manage bookings, communicate with participants, and ensure that our programmes and therapy are delivered safely and effectively. This includes using information to understand individual needs, provide appropriate support, maintain safeguarding responsibilities, improve our services, and maintain accurate records for the BACP requirements, the professional membership body. We only collect information that is necessary for these purposes and handle all personal information with care, confidentiality and respect.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Recognised legitimate interests - our pre-approved purpose for collecting or using personal information to provide and improve products and services for clients are:
We need to protect the physical, mental or emotional well-being of people who need extra support, or to protect them from harm or neglect (the ‘safeguarding condition’).
Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.
Our lawful bases for collecting or using personal information for the operation of customer accounts and guarantees are:
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
**Lawful basis for collecting and using personal information for customer accounts and service management** We collect and use personal information where it is necessary to provide and manage our services, including processing bookings, communicating with participants, managing payments, maintaining records and fulfilling our responsibilities as a wellbeing service provider. Our lawful bases for processing this information are: Where processing is necessary to provide the services a participant has requested, manage bookings, and fulfil agreed arrangements. Where processing is necessary to manage our relationship with participants, respond to enquiries, maintain accurate records, improve our services and ensure the safe and effective delivery of our programmes.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Our lawful bases for collecting or using personal information for service updates or marketing purposes are:
Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Our lawful bases for collecting or using personal information for legal requirements are:
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Recognised legitimate interests - our pre-approved purpose for collecting or using personal information for recruitment purposes are:
Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:
Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.
Where we get personal information from
Directly from you
How long we keep information
Data Retention Schedule
We only keep personal information for as long as it is necessary for the purpose it was collected, taking into account legal, professional, safeguarding and organisational requirements.
Our retention periods include:
Counselling client records
We retain counselling records in line with professional guidance, insurance requirements and legal obligations. Client records are securely stored and retained for 7 years after the end of therapeutic work, unless there is a specific reason to retain them for longer.
Wellbeing group and programme participant information
Information collected for nature connection groups, workshops and wellbeing programmes (such as registration details, emergency contacts and relevant support information) is retained for up to 12 months after the programme ends, unless required for safeguarding, legal or insurance purposes.
Safeguarding records
Where safeguarding concerns are recorded, information will be retained for as long as necessary and in accordance with safeguarding guidance, legal requirements and professional responsibilities.
Financial records
Information relating to payments, invoices and financial transactions is retained for 6 years in line with HMRC requirements.
Marketing and mailing lists
Contact details used for newsletters or updates are retained until a person withdraws their consent or asks to be removed from our mailing list.
Website enquiries and general correspondence
Enquiry information is retained only for as long as necessary to respond, manage our relationship with individuals and maintain appropriate records.
When information is no longer required, it is securely deleted or anonymised.
Who we share information with
Others we share personal information with
Organisations we need to share information with for safeguarding reasons
Organisations we’re legally obliged to share personal information with
Emergency services
How to complain
If you have any concerns about our use of your personal information, you can make a data protection complaint to us:
Email: hello@greenwayswellbeing.co.uk or esther@greenwaystherapy.com
If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.
The ICO’s address:
Information Commissioner’s OfficeWycliffe HouseWater LaneWilmslowCheshireSK9 5AF
Helpline number: 0303 123 1113 Website: https://www.ico.org.uk/make-a-complaint