Introduction      
                                
The Thrive Collective (TTC) is committed to protecting your personal data. Your information will be kept secure and only used for the purpose it was given.
​
This notice sets out how TTC use and protect information you provide, and the lawful basis under the Data Protection Act 2018, the General Data Protection Regulations (GDPR) and the data protection principles (contained in the NCPS Code of Ethical Practice that permits TTC to do so.
​
‘Data controller’ means the person/organisation that collects, stores and has responsibility for people’s personal data. In this instance, the data controller is Rebecca Skinner at TTC.
​
TTC is registered with the Information Commissioner’s Office [ZB046363].
​
Lawful Basis
​
TTC uses different elements of the GDPR depending on the stage at which we process your data, including storage of the data. These are contract, explicit consent, legal claims, vital interest, legal obligation.
​
For a full breakdown of what information is collated, how it is processed, retention periods and lawful basis for processing, please contact TTC.
​
The type of information collected
​
Whether or not you become a client, TTC will collect and hold personal data, this may include special category data as set out below.

Personal Data

• name
• date of birth
• relationships (parents, siblings, children)
• occupation
• contact details
• employment
• education
• social life details
• nominated emergency contact details
• GP contact details

Special Category Data​

• physical and mental health details;
• counselling / therapy history
• medical conditions
• prescribed medication
• emotional & psychological issues
• any disability or communication difficulty
• Counselling notes
• sexual history and/or orientation
• racial or ethnic origin
• religious beliefs

How TTC gets the information and why we have it
​
Most of data collated is during initial contact, assessment and contracting stages and provided by you. Alternatively, another professional or a parent / carer may send your details when making a referral or enquiry on your behalf. Further information provided will be during consultation(s). Information collated may be via telephone, email, post, face to face or via a third party. TTC collects and holds data for the purpose of assessment, counselling and to receive clinical supervision. Your records assist in providing you with a better service.
​
Storage of Information
​
TTC will take all steps reasonably necessary to ensure your data is treated securely and in accordance with this privacy notice. Your data is kept securely in an electronic format.
​
Data collated are the property of TTC and not the client. This data is not shared with anyone unless an exception in the ‘Confidentiality & Contract’ form applies. Where TTC is required to share information, TTC will always try to speak to you first, unless there are safeguarding issues that prevent this.
​
Any payment transactions via your bank will only be identified by an pseudonymised client reference number and no other information will be required or shared.
​
TTC retains your data only for as long as such information is needed and useful for the purpose for which it was collected. TTC stores the information for varying durations, depending on the type of information, but only if, TTC continues to have a valid reason. This includes allowing TTC to have enough information to respond to future issues, to uphold agreements between you and TTC and to be compliant with applicable law. If you would like a copy of my data retention map, please email TTC.
 
Unfortunately, the transmission of information via the internet cannot be completely secure. Security measures are in place to protect your personal data, but TTC cannot guarantee the security of your data transmitted, particularly by email; any transmission is at your own risk. Once TTC receives your information, TTC will use their own policies and procedures as far as is reasonably possible to prevent unauthorised access.
​
If you decide not to proceed, TTC will ensure all your data is deleted after 6 calendar months.
​
For security reasons TTC does not retain text messages or emails for more than 6 months. If there is relevant information contained in a text message, TTC will record this in their notes.
​
Once counselling has ended your records will be kept for 6 years from the end of the contract with each other and are then securely destroyed.
​
Website
​
The website may contain links to other websites that may be of interest. However, TTC has no control over other websites. Therefore, TTC cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at their privacy statements.
​
TTC does not use its website to collate any personal information and does not store your information from this source.
​
When you use a website, cookies are downloaded onto your PC and the next time you visit the site, your PC will check the cookie and send information back to the site, therefore tailoring what pops up. You can refuse these cookies using your own device settings.
​
TTC use a third-party service, ‘IONOS’ to collect standard internet log information and details of visitor behaviour patterns. TTC does this to find out things such as the number of visitors to the various parts of the site and to improve the service This information is only processed in a way that does not identify anyone. TTC does not make, and does not allow ‘IONOS’ to make, any attempt to find out the identities of those visiting the website. You can read IONOS privacy notice here: here.
​
Changes to this Privacy Notice
​
Any changes to this privacy notice in the future will be published on this website.
​
Your data protection rights
​
Under data protection law, you have rights including:
​

• Right of access - You have the right to ask for copies of your personal information.
• Right to rectification - You have the right to ask to rectify personal information you think is inaccurate or to ask TTC to complete information you think is incomplete.
• Right to erasure - You have the right to ask to erase your personal information in certain circumstances.
• Right to restriction of processing - You have the right to ask to restrict the processing of your personal information in certain circumstances.
• Right to object to processing - You have the the right to object to the processing of your personal information in certain circumstances.
• Your right to data portability - You have the right to ask that TTC transfers the personal information you gave to another organisation, or to you, in certain circumstances.

​
You are not required to pay any charge for exercising your rights. If you make a request, TTC has one month to respond to you. Please contact TTC in writing if you wish to make a request. You can read more about your rights at here.
​
Complaints
​
When people make complaints against the service, TTC holds data relating to the complainant, details of the complaint and witnesses or interested parties. TTC may share information with any external bodies who have a legal interest. All data relating to this process is kept electronically.
​
If you have any questions or concerns, you can contact:
​
The Thrive Collective:
Data Controller: Rebecca Skinner
Service Manager: Rebecca Skinner
E-mail: RebeccaSkinnerUK@pm.me
Website: http://www.Thrive-Collective.co.uk
 
You can also complain to the ICO if you are unhappy with how TTC has used your data.
​
The ICO:           
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk