Privacy and Legal

How and when do we collect information about you?

We collect your personal data in the following ways:

1. When you apply with us to be a Registrant or through our other membership types
2. When we confirm your details and trainings, or any details relevant to your BPC registration
3. When we receive such information through other regulators or membership bodies such as BACP and UKCP, or one of our Member Institutions
4. When you are raising concerns about a Registrant
5. When you make a complaint about our organisation

The information we collect includes the following: your name, email address, address, details about your circumstances (including health information, and other special categories of data), information about your previous trainings, educational background, any concerns about a Registrant’s Fitness to Practise, financial information.

How is the information used?

We use this information to:

1. Add you to our register of psychoanalytic clinicians or to administer your membership
2. Fulfil our role as a voluntary regulator to protect the public
3. Investigating any concerns about our Registrants
4. Facilitate your enquiries
5. Carry out internal evaluation and monitoring

What is our lawful basis for processing this information?

1. To fulfil your registration or membership with us, we rely on contractual obligation. If your registration is unsuccessful, we rely on legitimate interest to continue storing your information. We rely on additional lawful basis of Substantial Public Interest, read with Protecting the Public condition.
2. Any information about any third parties or member bodies that is shared with us when you are a Registrant is processed based on legitimate interest, based on both substantial public interest and Protecting the Public conditions.
3. To undertake any fitness to practise investigations, we rely on legitimate interest, and substantial public interest read with Protecting the Public condition.
4. For assessing any complaints against the organisation or staff, we rely on legitimate interest.

Who do we share your data with?

1. We may use legitimate interest to share your personal data with other member bodies in order to protect the public.
2. To comply with our duty of care and safeguarding, we apply vital interest and legitimate interest as our lawful basis.

How we store your information and for how long?

We retain the personal data of all service users in line with our retention periods. If you would like to know more about this, please contact us at the email address above.

How and when do we collect information about you?

You provide several pieces of data to us directly during the recruitment period and subsequently upon the start of your employment/engagement. In some cases, we will collect data about you from third parties, such as employment agencies or former employers when gathering references.

What types of information is collected about you and who provides it?

We keep several categories of personal data to carry out effective and efficient processes. Specifically, depending on your type of engagement with us, we may process the following types of data:

1. personal details such as name, address, phone numbers, marital status
2. name and contact details of your next of kin
3. information of any disability or other medical information you have disclosed
4. right to work documentation, National Insurance number, bank account details
5. information gathered via the recruitment process such as that included in a CV, cover letter or application form, references, details on your education and employment history etc
6. information relating to your employment with us (e.g. job title, job description, salary, terms and condition of the contract, annual leave records, appraisal and performance indication, formal and informal proceedings involving you such as letters of concern and disciplinary, disciplinary and grievance proceedings)

We may also process special category of data which include health information, sexual orientation, race, ethnic origin. We may also process criminal records information if the role involves DBS check. We also ask for disclosures around political opinions or affiliations with other organisations to assess any conflicts of interest.

How is the information used?

We are required to use your personal data for various legal and practical purposes for the administration of your contract of employment or your volunteer/ trustee agreement, without which we would be unable to employ you. Holding your personal data enables us to meet various administrative tasks, legal obligation or contractual/agreement obligation. We process information in relation to the DBS for our safe recruitment practices.

What is our lawful basis for processing this information?

We mainly use contractual obligation as a lawful basis for processing personal data for employees, job applicants and freelancers. We mainly use ‘legitimate interest’ for trustees.

Some special categories of personal data, such as information about health or medical conditions is processed in order to carry out employment law obligations and for health and social care obligations. We may also process information about ethnic origin, sexual orientation, health or religion or belief based on substantial public interest for the purposes of equal opportunities monitoring. For administering any grievance or disciplinary processes, we rely on legitimate interest.

When processing criminal records (for example, in order to perform DBS check), the organisation relies on the lawful basis of legitimate interest and additional conditions of the UK GDPR and DPA 2018.

Who do we share your data with?

Personal Data in relation to your salary is shared with HRMC as part of our legal obligation. When sharing information with third parties, we have data sharing agreements, data processing agreements or contracts in place to ensure data is not compromised. These third parties implement appropriate technical and organisational measures to ensure the security of your data.

How long do we keep your data?

We only keep your data for as long as we need it for, which will be at least for the duration of your employment/engagement with us though in some cases, we will keep your data for a period of 7 years after your employment/engagement has ended. If you’ve applied for a vacancy but your application hasn’t been successful, we will keep your data only for 12 months.  Some data retention periods are set by the law. Retention periods can vary depending on why we need your data. Please get in touch by contacting us using the details above if you want to know more about retention period.

Data is destroyed or deleted in a secure manner as soon as the retention date has passed.

What information will we collect about you?

Device and usage data including IP addresses and device identifiers

Device event information including crash logs, hardware settings, browser type and browser language

How will we collect information about you?

Automatically collected and stored in our server logs when you interact with our website

Why are we processing information about you?

To improve the user experience of our website, including to offer you tailored content, and to protect the security of our website.

What is our legal basis for processing information about you?

To pursue our legitimate interests, in particular to understand how our website is used, to improve the user experience of our website, and to maintain the security of our website.

What information will we collect about you?

Information derived from cookies and similar technologies

How will we collect information about you?

Google analytics

Why are we processing information about you?

To analyse the traffic to our website

What is our legal basis for processing information about you?

As applicable, your consent or to pursue our legitimate business interests as described above.

Events:

We host events throughout the year, and your personal information is collected when you register for an event with us. We may collect basic personal information, such as your name, email, phone number. We rely on legitimate interest to administer your registration for the event. When we collect other information such as dietary information, we rely on your explicit consent.

If you have attended an event with us previously, we may reach out to you to invite you for our future events. We rely on consent (to send you emails) and legitimate interest (to call you on your registered number with us)

Marketing:

We may also send you marketing communications if you have signed up for marketing emails. We use texts, email, and calls for marketing.

We rely your consent to send your email communications (except where this is a business email address, whereby we rely on legitimate interest).

If you would like to change your marketing preferences, please reach out to us on the email address provided in the first section of this privacy notice, or you can simply unsubscribe with the option on the bottom of the emails.

We may also use post as a mode of sending you marketing communications, relying on legitimate interest. If you would like us to not send such communications, please do reach out to us.

Your rights as a Data Subject

You have the following rights:

• ‘Right to be informed’, which means we will be completely clear and transparent about how we plan to use your personal information.
• ‘Right of access’, which means you can request details of the personal information we hold about you and how we use it. We will provide this within one month.
• ‘Right to rectification’, which means you can ask us to update or amend the personal information we hold about you, if it is incorrect.
• ‘Right to restrict processing’, which means you can ask us to change, restrict or stop the way we are using your personal information.
• ‘Right to erasure’ (or ‘right to be forgotten’), which means you can ask us to remove your personal information from our records.
• ‘Right to object’, which means you can object to us using your personal information for marketing purposes.
• ‘Right to data portability’, which means you can obtain the personal information we hold about you and reuse it for your own purposes.
• ‘Right not to be subject to automated decision making’, which means if we use systems to make a decision about you, you have the right to ask for a person to intervene, which may change the outcome.
• Right to lodge a complaint with a supervisory authority, such as the Fundraising Regulator or the Information Commissioner’s Office (ICO), if you are not satisfied with our response to a request you make to us, or you feel we are not using your information correctly.

International Data Transfers

Where personal data is stored outside of the UK and the EEA, safeguards to protect personal data may include but are not limited to the UK Addendum used in conjunction with the EU Standard Contractual Clauses (SCCs), or UK International Data Transfer Agreement (IDTAs). Such safeguards will be subject to Transfer Risk Assessments (TRAs).

Complaints procedure

If you are unhappy with how we handle your personal data, you have the right to raise a complaint with us.

You can contact us by:

• Email:[email protected]
• Telephone: +44 (0) 20 7561 9240

Please provide:

• Your name and contact details
• A clear description of your concern
• Any relevant dates or reference numbers

What happens next?

1. We will acknowledge your complaint within 30 days of receiving it.
2. We will investigate your concerns.
3. We may contact you if we need further information.
4. We will respond as soon as possible and without undue delay.

Our response will explain:

• What we have found
• Whether any action has been taken
• What happens next

If you are not satisfied

If you remain unhappy with our response, you have the right to complain to the Information Commissioner’s Office (ICO):

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephone: 0303 123 1113
Website: https://ico.org.uk

Accessibility

If you require this information in an alternative format, please contact us and we will be happy to assist.