Privacy Policy, Terms & Conditions 

Effective date: 18th August 2023

 

Privacy Policy

WEBSITE
1. INTRODUCTION
This privacy notice provides you with details of how we collect and process your personal data through your use of our site.
By providing us with your data, you warrant to us that you are aged 18 years and over.

KEYPHASE LTD is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

Contact Details
Our full details are:
Full name of legal entity: KEYPHASE LTD
Email address: [email protected]

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at [email protected].

2. WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUNDS DO WE PROCESS IT? 

Personal data means any information capable of identifying an individual. It does not include anonymised data.
We may process the following categories of personal data about you:
Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, sending you any free reports you may have requested or delivering an eletter you may have requested, for record keeping and for the establishment, pursuance, or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.

Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.

User Data that includes data about how you use our website, open emails and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.

Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.

Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, to deliver relevant website content and email promotions and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.

We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).

Sensitive Data
We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.

Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.
We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at [email protected]. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

We do not carry out automated decision making or any type of automated profiling.

3. HOW WE COLLECT YOUR PERSONAL DATA
We may collect data about you by you providing the data directly to us (for example by filling in forms on our site or by sending us emails). We may automatically collect certain data from you as you use our website by using cookies and similar technologies. Please see our cookie policy for more details about this.

We may receive data from third parties such as analytics providers such as Google based outside the EU, advertising networks such as Facebook based outside the EU, such as search information providers such as Google based outside the EU, providers of technical, payment and delivery services, such as data brokers or aggregators.

4. MARKETING COMMUNICATIONS
Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).

Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However, you can still opt out of receiving marketing emails from us at any time.

Before we share your personal data with any third party for their own marketing purposes, we will get your express consent.

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you OR by emailing us at [email protected] at any time.

If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc.

5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below:

Service providers who provide IT and system administration services.
Third parties / editors who have created products in partnership with KEYPHASE LTD.

Professional advisers including lawyers, bankers, auditors, and insurers
Government bodies that require us to report processing activities.
Third parties to whom we sell, transfer, or merge parts of our business or our assets.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is in place:

We will only transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or

Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or

If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

7. DATA SECURITY
We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.

8. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

When deciding what the correct time is to keep the data for, we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.

In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS
Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.

You can see more about these rights at:
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
If you wish to exercise any of the rights set out above, please email us at [email protected].
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

10. THIRD-PARTY LINKS
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

11. COOKIES
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookies policy.

 

Terms & Conditions

THE THERAPEUTIC CONNECTION
Terms and Conditions of Agreement for counselling and psychotherapy

1.Parties
“You” and KEYPHASE LTD is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

2. Introduction

2.1. These are the standard terms and conditions for the services that we provide. We have done our best to use friendly terms while ticking all the necessary legal boxes and not taking away any unnecessary rights of service users. The following terms apply as the standard terms for all of our services.

2.2. The following is intended to form the terms and conditions of the agreement relating to the professional relationship between You and counsellors/psychotherapists with KEYPHASE LTD. If at any point either party believes that the other party might be in breach of this agreement, it is important that concerns are raised as soon as possible so that we can work together towards a resolution. We will take any complaints seriously. We recommend that You raise any complaint in the first instance directly with the counsellor/psychotherapist with KEYPHASE LTD.

3. Commencement Date

3.1. The Agreement shall commence on the day that the first session is agreed. The agreement may be terminated by either party at any time by giving to the other party at least one week’s notice.

4. The Services

4.1. The services that will be provided under this agreement include individual therapy or relationship counselling including in-person, video, telephone and online therapy (“the Services”).

5. Ethical Standards

5.1. We shall carry out our obligations towards You under this agreement in keeping with the ethical standards for therapeutic practice of the British Association for Counselling and Psychotherapy (BACP) and the Association of Christians in Counselling and Linked Professions (ACC). The relevant standards for therapeutic practice are available on the BACP and ACC websites.

6. Confidentiality

6.1. The confidentiality of information relating to You is of paramount concern to us. We fully comply with data protection legislation and therapeutic confidentiality guidelines. We share information on a need to know basis and strict guidelines are in place to ensure the information remains secure. Your therapy and personal information are kept securely. Information but not names will be shared with counselling supervisors who is also registered with a regulatory professional body and who regularly reviews our practice.

6.2. Confidentiality will be broken if we have concerns that You or anyone else is at risk. We have a statutory duty to break confidentiality in accordance with the Children Act, the Terrorism Act and the Drug Trafficking Act. This disclosure would have to be in the public interest where we reasonably believe that this would assist the detection and / or prevention of serious harm to the public, an individual, the security of the state, public order, crimes that involve substantial financial gain, or be in the interests of protecting a child or vulnerable adult from abuse. We will always take careful consideration of the seriousness and immediacy of the risk, the ethics of the situation, consent issues, and appropriate action. We will also take advice where relevant to inform any decisions to break confidentiality. We will include you in discussions and let you know wherever possible of decisions to break confidentiality. We may break confidentiality for an actively suicidal client with a clear plan and imminent intent to take his / her own life. This does not necessarily mean that we would break confidence with every disclosure of suicidal thoughts, ideation or intent.

7. Data Protection Act 2018

7.1. We are committed to meeting the provision of the Data Protection Act 2018. We have a legal duty to keep information about You confidential. In summary, this means that we will ask for information about You so that You can receive proper care and treatment. Contact information, registration details, emergency contacts, and very brief notes on individual, couples’ and group sessions relating to You will be kept. Upon starting therapy, basic personal information will be collected for contact and identification reasons. During our therapy meetings, an assessment of Your psychological health will be completed, and notes will be drafted after Your sessions. These will include personal and sensitive details about Your life. The assessment and notes are used solely for the delivery of a therapy service to You.

7.2. We keep this information securely with details of Your care because it may be needed when You are seen again.

7.3. We will normally only provide information about Your therapy to Your GP if You provide me with consent. There may be situations in which we are required by our legal, regulatory or professional obligations to inform Your GP and/or other public bodies about certain matters, for example where there is a risk to life or physical harm to You or to a third party.

7.4. We support audit projects intended to evaluate the health of the nation and the quality of related care. We support ethically approved research projects which measure the long-term effectiveness of treatment. There will be a specific consent form for contribution to any research projects.

7.5. You may be receiving care from other people as well as us. So that we can all work together for Your benefit, we may need to share some information about You with those people.

7.6. You have rights relating to the information we hold to verify the accuracy or to ask for them to be supplemented, deleted, updated or corrected.

7.7. You have a right of access to Your therapy records under the Access to Health Records Act as Ill as under the Data Protection Act 2018. If You would like a copy of some or all of Your personal information, please email or write to us via the contact details stated in this agreement. Information will be provided to You within 30 days. For more information, You may like to consult the Information Commissioner’s website: www.ico.gov.uk

8. Access to Non-Therapeutic Information

8.1. Access to non-therapeutic information may be granted to others on a strictly confidential basis in the course of and for the purpose of efficient administration, for example audit, financial management and credit control and managing or improving my services. This access may be given to any person or organisation involved in billing, processing, payment or collection of accounts or the provision of credit referencing. In some instances, we are obliged by law to disclose information for example where it will assist in investigations into fraud or other criminal offences, or if there is an issue relation to public health, Your own safety or another individual’s safety.

9. CCTV, Recordings and Supervision

9.1. The buildings where we operate in-person sessions from uses CCTV in some areas for security purposes only.

9.2. Supervision is conducted in accordance with the BACP and ACC guidelines for supervised client-work. This means that Your case may need to be discussed with counselling supervisor and/or senior psychotherapist in the interest of Your treatment. Your identifying details will remain anonymous.

9.3. As part of supervision, on-going professional training requirements, service evaluation or research, You may at the outset of the work be asked to consent to sessions being video and / or audio-recorded. You have the right to decline this request. Any recordings will be erased as soon as reasonably practicable after the purpose of the recording has been discharged in line with the requirements under the Data Protection Act 1998.

10. Retention, Storage and Destruction of Information

10.1. Information about You is stored in a confidential and secure manner whether it is in manual or computerised form. Your information will be kept for the specific retention periods outlined by the relevant professional bodies. Your information is kept for the time necessary to provide the therapy service requested, however outside of this we will hold Your details and session notes for a specified period following the end of treatment to comply with obligations that are placed upon us by our insurers. After this retention date, all data will be securely deleted. Destruction of data, either manual or digital is undertaken using documented procedures with an audit trail of activity and destruction.

11. Influence of alcohol or substances

11.1. If it is reasonably suspected that You are under the influence of alcohol or any illegal substances, You will be asked to leave and forfeit Your session that day without a refund of the fee. If this behaviour continues, it may lead to therapy being terminated.

12. Contact between sessions

12.1. In instances where You need to contact us between sessions, You can send text message or send an e-mail. All messages will be responded to as soon as reasonably practicable as time permits between sessions within normal opening hours. We do not operate a crisis or emergency service. If You need to speak to someone immediately please contact Your GP, the NHS Non-Emergency Number by dialling 111 or in the event of an emergency You may also call an ambulance on 999.

13.Use of our website online content (e.g. Blogs, Instagram, Facebook, LinkedIn)

13.1. The materials contained on our website and on our other online content are for general information only and should not be relied upon as legal, medical, therapeutic or other professional advice. We make no warranty as to whether the information is accurate or up to date. We do not accept any responsibility for any loss which may arise from accessing information that we put either on our website or on any other online forum. We hereby exclude all liability for losses or damages that are direct or indirect arising from use of any online material relating to us including but not limited to our website.

13.2. Changes may be made to our online content, the content may be deleted and our online content may be removed at any time without notice.

14. Access of service online

14.1. We aim to make our website and online material and communication (e.g. e-mail, social media, and video calls such as Zoom) as accessible to all service users. However, we cannot guarantee that the website or online services will always operate correctly, will necessarily be compatible with all clients’ hardware and software, or will be secure over Your internet connection. We will not be held responsible for any loss of data, damage to data, unlawful interception of data, viruses or interruption of access.

15. Dual Relationships

15.1. The therapeutic relationship is professional in nature and cannot extend into other spheres. In order to protect professional boundaries and ethics, it is not appropriate to engage in any other capacity outside of the therapeutic relationship. This helps ensure objectivity, clinical judgment and therapeutic effectiveness. For example, we will not accept any invitations via social networking sites nor accept invitations to client events. We will not be able to accept you as a participant on any training that we provide or engage in any business transaction with you. We will also not act as a witness by providing reports or letters on our work together for any purpose other than for Your psychological treatment. We cannot provide reports or letters for matters such employment or educational disputes, divorce and custody disputes, personal injury, educational mitigating circumstances etc.

16. Litigation and Legal Proceedings

16.1. Due to the matter of dual relationships, the nature of the therapeutic process and the fact that therapy often involves making a full disclosure with regard to many matters which may be of a confidential nature, it is agreed that should there be formal or legal proceedings (such as, but not limited to employment or educational disputes, divorce and custody disputes, personal injury, educational mitigating circumstances etc.), neither You nor Your lawyer, nor anyone else acting on Your behalf will call on us to provide a report, letter or to testify in court or at any other proceedings.

16.2. If You at any stage become aware that there is a possibility that You will be involved in litigation or legal proceedings, You agree to let us know at the earliest possibility so that the risks of any dual relationships or conflict of interests can be discussed and resolved.

17. Fees and payment

17.1. The rate for therapy is stated in contract agreement (sessions usually last 50 minutes). Payment is required before each session, You may pay online via credit or debit  card. If You prefer you may make payment by bank transfer, and you will be provided the bank account details. Fees are revised annually in April of each year and You will be provided with written notice of any changes in the fees charged.

18. Initial sessions and ongoing treatment

18.1. The initial three sessions form part of Your psychological assessment to explore the presenting issue and discuss how therapy might address it. No further obligation is assumed by either party as a result of attending these initial three sessions. After the three initial sessions, You may decide that You do not want to continue any further or I may decide that the material You want to work on falls outside of my areas of expertise and experience, in which case You will be referred to another professional (where reasonably practicable).
18.2.The usual frequency of sessions is weekly and booked at the same time and day each week. Session availability cannot be guaranteed if booked on an ad hoc basis and / or infrequently.

19. Sessions and cancellations

19.1. Sessions are 50 minutes in duration and the same day and time will be reserved for You each week, unless we agree otherwise. Since ongoing therapy involves the reservation of a time specifically for each client, a minimum of 48 hours’ notice is required for re-scheduling or cancelling an appointment. Unless a different agreement is reached and confirmed in writing, the full fee will be charged for sessions that You do not attend or arrive at later than the start time without providing at least 48 hours’ of notification of cancellation or rescheduling. If payment has already been made for a session and cancelled with sufficient notice, a refund will be made less the bank / payment gateway charge for the transaction which is non-refundable.

19.2. It is expected that the session will begin at the agreed time. Any session that begins after this time due to Your late arrival for whatever reason cannot be extended beyond the agreed finish time. If You do not arrive or call me within 15 minutes of the agreed appointment, this will be considered a cancellation without the required 48 hours’ notice being provided and we may not be available for the remainder of the session. For a couples’ therapy session, both individuals need to be present in order for the session to start.

19.3. If for any reason we have to cancel a session, we will aim to provide You with 48 hours’ notice where this is possible and You will not be charged for the session. we will also give 4 weeks’ notice of any planned holiday dates when we will be unavailable. You are required to provide at least 2 weeks’ notice in relation to any holiday dates.

20. Regular reviews

20.1. Working towards the goals of therapy requires effort, active involvement and honesty on Your part. During the first session and throughout the work, we will discuss with You Your understanding of the problem, treatment plan, therapeutic objectives and Your view of the possible outcomes of treatment. Therapy requires You to recall and talk about events, feelings or thoughts which could give rise to unpleasant feelings and in extreme cases, physical symptoms such as insomnia. We will regularly ask for Your feedback and views on Your therapy and its progress. It is important that You are as honest as You can be so that we can monitor and respond to any concerns You may have.

21. Ending therapy

21.1. Regular reviews of Your progress will help determine the duration of the therapy. During the initial assessment and the first two sessions following that, we will discuss with You whether we both believe that therapy with us will be of benefit to You. If You have requested video call (e.g. Zoom) or telephone therapy, the assessment will include Your suitability for this medium of therapy. We prefer to arrange face to face therapy sessions where this is reasonably practicable as these may be more effective. If at any point during the therapy sessions, we assess that we are not effective in helping You reach Your therapeutic goals, we are obliged to discuss this with You, up to and including termination of treatment.

21.2. Therapy may need to be terminated if less than half of the weekly (or mutually agreed frequency) sessions are attended in any two-month period. Therapy requires an ongoing commitment to be effective and for ethical reasons, we cannot provide psychological services when we do not deem that they will be beneficial to You.

21.3. We reserve the right to terminate this agreement at any time in the event that in our opinion You are not likely to benefit from ongoing therapy sessions with us. We may also terminate this Agreement by giving You one week’s notice of termination.

21.4. You have the right to terminate therapy at any time and whatever the reason, we will always respect Your decision. You are required to give at least one week’s notice before terminating Your therapy sessions in order to allow time in the final session to discuss Your reasons, progress made and possible referrals for ongoing support.

22. Issues specific to Video-call (e.g. Zoom) and telephone therapy

22.1. Should either You or we experience difficulties ‘attending’ a session because of technical reasons, we should both endeavour to let the other person know straight away and allow time to try to connect again or to have therapy via another means. In the event that You have paid for a session but are unable to attend the session at the agreed time, the full fee charged for the session will be retained and will not be refundable.

22.2. It is important for You to ensure that the environment You work and live in allows You the physical and emotional safety and privacy to express Yourself freely in order for a remote therapy session to take place. It is Your responsibility to ensure that the technology that You use is secure and that precautions are put in place in Your surroundings to safeguard confidentiality of information relating to You.


23. Acceptance
23.1. You agree that Your continued use of the services of KEYPHASE LTD, constitutes Your approval and acceptance of the terms within this agreement.

24. These terms and conditions are an important tool in the event that You need any clarity about our contractual relationship. If You have any questions or if any of these terms are not clear, please contact us.

Contact Us

If you have any questions, concerns or complaints about this Privacy Policy, Terms and Conditions, please contact us: