Privacy Policy

Philippi Guernsey LBG Privacy Policy (Edition – May 2018)

Philippi Guernsey LBG (‘Philippi’) is committed to protecting the privacy and security of your personal information.  This privacy policy describes how we collect and use personal information about you during and after your relationship with us.

Who Are We?

Philippi is a registered company and charity, providing counselling and training services in Guernsey.  We do not receive funding from any governmental or other source. Neither do we collect fees from clients. Philippi relies wholly on donations from clients and organisations. We make a charge to students to cover the cost of the training courses.  Our training is supplied by both Philippi and a UK based training provider.  We also issue regular newsletters.

Our contact details are as follows:

Registered Office:St Andrew’s Church Barn, Rue des Morts, St Andrew GY6 8UT

Tel: 07781 130523 Email: philippi.g@cwgsy.net   Website: www.philippi.org.gg

Company number: 41514 Association of Guernsey Charities Number: 270

Data Protection Principles – The Data Protection (Bailiwick of Guernsey) Law, 2017

We will comply with data protection law. This requires that personal information that we hold about you must be:

  • used lawfully, fairly and in a transparent way;
  • collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
  • relevant to the purposes we have told you about and limited only to those purposes;
  • accurate and kept up to date;
  • kept only as long as necessary for the purposes we have told you about;
  • kept securely.

What type of information do we hold?

Personal data, (or personal information), is any information relating to an identifiable individual. It does not include data where a person cannot be identified.

We hold information about two categories of person. The first category are clients. The second category are all persons other than clients. The way we deal with personal data depends on whether you are a client or not.

This section of the Policy relates exclusively to Clients

 Confidentiality

Client sessions are conducted in strictest confidence and this confidence will be maintained and applied to all records, except in the following circumstances:

  • Where the client gives consent for the confidence to be broken.
  • Where the counsellor is compelled to do so by an Order of a Court.
  • Where the counsellor reasonably considers that the information is of such gravity that confidentiality should not be maintained.
  • Where the counsellor reasonably considers that there is a risk of serious harm to the client or others.

Handling of your personal information

All clients undergo an initial consultation meeting with the Philippi Manager (or other authorised person) and is asked to fill in an initial consultation form during this initial meeting. At that meeting, the client will also be asked to sign the Philippi counselling agreement.

After this initial meeting, the initial consultation form is then given to the nominated counsellor together with a signed copy of the counselling agreement. Duplicate copies of the form and agreement are given to the client at the initial meeting for their own record. The Philippi Manager does not keep a record of client’s consultation form or agreement and the only personal information retained by the Manager is the client’s telephone number or email address for essential contact purposes.

The counsellor may make encrypted, computerised notes of counselling sessions. Alternatively, a brief paper record of sessions is kept. These notes are anonymised and do not contain any identifiable information other than a code. The counsellor keeps the code, which is always kept secure and separate from the notes.

In accordance with the Counselling Code of Ethics, each counsellor is required by their professional body to undertake supervision.  Although client issues are discussed within supervision, confidentiality is maintained, and the client’s identity will not be revealed during the supervision.

In order to provide a client with the highest level of care and ensure that the counsellor is working within the Association of Christian Counsellors’ Code of Ethics and Practice, there may be times when it is appropriate to audio record a counselling session for the supervisor. This will be considered if it is thought to be in the client’s best interests.  The client’s written permission will be obtained first.

The Philippi Manager (or deputy manager) may on occasions need to access a client’s information in connection with the management of the Philippi counselling services and/or Philippi’s professional responsibilities particularly but not exclusively relating to safeguarding issues.

The counselling agreement, to be signed by the client at the outset of the counselling, contains the following matters that will be explained and, if agreed by the client, signed in the following form:

I understand that by signing this section it has been explained to me that;
·     I am giving my consent to Philippi Guernsey LBG (‘Philippi’) processing my personal data for all purposes in connection with the provision by them of counselling services;

·       I give my consent freely, and I have been informed that I have the right to withdraw my consent at any time. I have been advised that I have the option of refusing my consent;

·       I understand that the processing of my personal data is necessary for the proper performance by Philippi of their responsibilities in providing counselling services to me;

·       I understand that a brief record of the initial consultation and the contents of each counselling session will be kept. The initial consultation does identify me but that the notes of the counselling session will not identify me.

·       I understand that my data records are kept secure and the counselling notes are kept separately to the Counselling Agreement and initial consultation form;

·       I am advised that Philippi take appropriate measures to protect the security of my data in their possession.

·       My personal data will, except as set out in this Agreement, be accessed only by my counsellor, their supervisor (in an anonymised form) and the manager (or deputy manager) of the service;

·       I understand and consent to my personal data being disclosed to appropriate third-party agencies in any one of the circumstances set out above in points 1-4 of paragraph 1 of these terms and conditions.

·       I have a right to know what personal data Philippi hold regarding myself. If I wish to receive a copy of the information you hold, I should contact the manager of the service.

If I have any concerns about your handling of my data which we cannot resolve between us, I have the right to complain to the Office of the Data Protection Commissioner.
By signing this section, I give my consent to Philippi Guernsey LBG processing my data and disclosing this to third party agencies in accordance with the provisions of this section.

This section applies to persons who are not Clients

We may collect and store your name, title, residential address, telephone, email, and where appropriate your church, your job title and employer.  We do not collect any sensitive information (Special Category Data).

We collect personal data from you when you give us your information to sign up for a newsletter, or for one of our training courses and workshops.  We also hold some information which is in the public domain, such as email addresses for you if you represent an organisation relevant to our work, including agencies and churches.  None of your data is used to develop a personal profile of you and the log files are regularly purged.

How we will use information about you

We may use your personal information in the following circumstances:

  • Where we need to comply with a legal obligation;
  • To inform you about the work of Philippi Guernsey LBG via an email or postal newsletter;
  • To inform you about future training courses and workshops;
  • To inform you about the activities of Friends of Philippi Guernsey.

Normally the purposes for which we use your personal information will be made clear at the point we collect that information. We will not use your personal information for other purposes.

Who do we share your information with?

Your data will not be passed on to third parties for advertising or marketing purposes.  It may be shared with a training organisation where you have asked for information or have signed up for a training course or workshop.

If we wish to put you in touch with others as part of our counselling or training activities (or to put someone in touch with you) we will only use a work email address and not your personal email unless we have first obtained your consent.

Opting In / Opting Out

We may wish to provide you with choices regarding the use of your personal data. This will normally be in relation to us wishing to notify you of future training courses or workshops for continuing professional development.  If you agree to receive this material, you are free to opt out at any time by sending us an email instruction or by telephone.

 How Do We Store Your Data?

We have adopted suitable security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We limit access to your personal information to the Philippi Manager and one other person who is responsible for mailing out newsletters.  They are subject to a duty of confidentiality.

How long will we use your information for?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for.

Your rights in connection with personal information

These are your rights which are relevant to the way Philippi Guernsey LBG holds your information: You have a:

  • right of access to your personal information (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;
  • right to object to the processing of your personal information;
  • right to rectification of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;
  • right to your personal information being deleted. This enables you to ask us to delete or remove personal information;
  • right to restrict the 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;
  • right to be notified of rectification, erasure and restrictions.

If you wish to exercise any of your rights listed above please write to us at the registered office or email us.

Changes to this Privacy Policy

This Privacy Policy may be updated at any time. Any new version will be published on our website.

This Privacy Policy was last updated on 24 May 2018.

If you have any questions about this Privacy Policy, please contact:

The Manager, Philippi Guernsey LBG, St Andrew’s Church Barn, Rue des Morts, St Andrew, Guernsey GY6 8UT or email philippi.g@cwgsy.net