PRIVACY POLICY

17th May 2018

STATEMENT OF INTENT

This privacy policy tells customers, members and users of services provided by Changes Welcome, its Websites, and its Practitioners Services what to expect when Changes Welcome collects, uses, retains, and discloses your personal information. Personal information is information that (on its own or together with other information) identifies you and is about you. This includes what you tell us about yourself and what we learn by having you as client, website user, or customer.

Changes Welcome is an entity owned by Liane Ulbricht-Kazan, who’s intention it is to ensure that any data you provide is managed respectfully, kept secure and only used for the lawful purposes for which it has been provided.

Within this policy, we describe instances where Changes Welcome is the ‘data controller’ (the organisation who decides what personal information is collected and how it is used), and where we direct or commission the processing of personal information by third parties on our behalf to provide services or improve our offering. This policy will be updated from time to time in line with prevailing legislation.

 

OUR COMMITMENT TO YOUR PRIVACY

Changes Welcome recognises the importance of protecting personal and confidential information in all that we do, and takes care to meet our legal and professional duties. Changes Welcome puts in place all reasonable technical, security and procedural controls required to protect your personal information for the whole of its like, in whatever format we hold that information in.

 

HOW THE LAW PROTECTES YOU

Your privacy is protected by law, which says that we can use your personal information only if we have a proper reason to do so. This includes sharing it outside of Changes Welcome. The reasons why Changes Welcome may process your personal information are:

  • To fulfill an explicit or implied contract we have with you (provision of services);
  • When it is our legal duty;
  • When it is in our legitimate interest; or
  • When you consent to it.

A legitimate interest is when we have a business or commercial reason to use your information, but this must not unfairly go against your rights of freedoms. If we rely on legitimate interest, we will tell you what this is within our privacy policy.

Below is a list of the ways that we may use your personal information, and which of the reasons we rely on to do so. This is also where we tell you what our legitimate interests are.

 

What we use your personal information for Our Reason(s) for processing Our Legitimate Interest (where applicable)
 

  • To manage our relationship with you
  • To communicate with you about services or products you have purchased
  • To facilitate services and products you have purchased (arranging appointments, checking in on progress)
  • To communicate with you about matters you first apporach us about (e.g. enquiries)
 

  • Fulfilling contracts (implied or explicit)
  • Our legal duty
  • Your Consent
  • Our legitimate interest

 

 

  • Keeping records up to date
  • Seeking your consent when we need it to contact you after you first make contact with us
  • Responding to appointment requests by booking you in to the booking system
  • Being efficient about how we fulfill our legal and contractual duties
 

  • To administer payments
  • To maintain proper accountancy records for HMRC and audit purposes
 

  • Fulfilling contracts (implied or explicit)
  • Our legal duty

 

 

  • To develop and carry out marketing activities
  • To conduct analysis and research activities to improve and develop or products and services
  • To analyse the reaction to our advertising activity
  • To create anonymised look-alike audiences for marketing purposes
  • To provide you with updaes about additional products or services
 

  • Your Consent
  • Our legitimate interest
 

  • Working out which of our products and services may interest you and telling you about them
  • Defining audiences to market our products to
  • Seeking your consent when we need it to contact you about additional products or services.

 

 

  • To detect, investigate, report and seek to prevent crime
  • To comply with regulations that apply to us
  • To respond to complaints and seek to resolve them
  • To respond to support requests via our help desk and resolve issues and enquiries as they arise
  • Fulfilling contracts (implied or explicit)
  • Our legal duty
  • Our legitimate interest

 

  • Complying with regulations and best practice standards that apply to us and our profession
  • Being efficient about how we fulfill our legal and contractual duties
 

  • To run our business in an efficient and proper way.  This includes managing our financial position, business capability, planning, communications, governance and audit.
 

  • Our legal duty
  • Our legitimate interest

 

 

  • Complying with regulations and best practice standards that apply to us and our profession
  • Being efficient about how we fulfill our legal and contractual duties
 

  • To fulfill our rights as set out in agreements or contracts
 

  • Fulfilling contracts

 

WHAT TYPES OF PERSONAL INFORMATION DO WE HANDLE?

We process personal information to enable us to run Changes Welcome, and to support the provision of services provided by itself and it practitioners (Coaches, Therapists, Hypnotherapists), as well as to maintain our accounts and promote our products and services.

The types of personal information we (Changes Welcome) use include:

  • Personal details such as names, addresses, telephone numbers;
  • Your relationship to other customers (where they make referrals);
  • Details of how you use our website(s), and where you accessed them from;
  • Details of how you interact with us on social media;
  • Details of when you contact us and when we contact you (including voicemail recordings, copies of written communications such as emails or letters);
  • Details of products and services you have purchased;
  • Any consents you have given us in relation to the processing of information;
  • Some details of use of the services offered by Changes Welcome, and it’s practitioners;

Types of information our Consultants, Coaches and Practitioners handle, which may be different, include:

  • Personal details such as names, addresses, telephone numbers;
  • Physical or mental health details in relation to requests by clients for access to our products and services, as well as personal details that form the content of sessions, including personal and private disclosures, employment and other social information, financial position, personal background and health information, and anything that is discussed in the context of sessions, either within the session, or outside of the session via telephone or other written means (such information requires special protection by law);
  • Your relationship to other customers (where they make referrals);
  • Details of how you use the practitioner’s own website(s), and where you accessed them from;
  • Details of how you interact with them on social media;
  • Details of when you contact them and when they contact you (including voicemail recordings, copies of written communications such as emails or letters);
  • Details of products and services you have purchased;
  • Any consents you have given them in relation to the processing of information;
  • Some details of use of the services offered by Changes Welcome, and it’s practitioners;

 

WHERE & HOW WE COLLECT PERSONAL INFORMATION

We may collect your personal information from the following sources.

Personal information you give to us:

  • When you contact Changes Welcome by any means or send us an enquiry;
  • When you contact the practitioner directly;
  • When you contact us or the practitioner via one of our practice locations;
  • During consultations, intake sessions & in the course of providing our services;
  • In customer surveys or any other research activity we may conduct with you;
  • When you use our services, arrange or attend consultations, breakthrough sessions, both fact-to-face and online;
  • When you update the information held with us;
  • When you request deletion of your personal information, in which case only the deletion request will be kept;

 

Personal information gathered from our website:

  • Please note that the practitioner may have his/her own website and you are advised to also refer to the privacy policy on that website. Changes Welcome cannot be held accountable for the content of the practitioner’s own personal or other websites;
  • We collect personal information when you use or access our website(s) including via cookies. Cookies are small files, which ask permission to be placed on your computer’s hard drive so that we can analyse web traffic to our site. Through this we can see which of our website’s pages are being viewed and are of interest. Most web browsers automatically accept cookies but you can modify your setting to decline them if you prefer. If you choose to do this you may find you cannot make full use of our website.

We collect personal information when you contact us via our website, phone or email we may collect your:

  • Name;
  • Email Address;
  • Telephone Number;
  • Any information you choose to supply regarding the purpose of your enquiry.

If you wish to make a booking, you will be directed to the booking system, where you will be able to book your initial consultation. Alternatively, we you may provide this to us or the practitioner via email, text, telephone or verbally face-to-face or at one of our centres, and they will enter your information into the booking system. A confirmation email will be sent to you, as well as reminder emails. These contain links to payment processers should you wish to effect your payment via such means.

We collect personal information when we receive incoming telephone calls:

Calls to our landline numbers are operated through VOIP Telephone services, which include functions such as caller ID, missed call logs, and voicemail. Records of all calls are stored. If you choose to leave a message, this is emailed to our general enquiries email address as a sound file along with your telephone number, as well as being stored at the voipfone company. This will be accessible by practitioners only.

Calls to mobile phones go directly to the handset owner (practitioner) who will receive any voicemails or caller information personally.

We collect personal information when we receive electronic mail and messaging communications including contact via the website(s):

Emails sent and received are done so in a number of ways. All incoming emails sent to ‘[email protected]’ are treated as general enquiries and may be checked by any consultant, coach or practitioner. This email address is also used on the website contact form(s).

Other emails sent directly to practitioners are received by the practitioner, as well as being stored on the email server until such time as this is deleted. These email accounts may be accessed also by persons responsible for the running of Changes Welcome where we have a legitimate interest to do so.

For online communications personal information may be collected via chat/ messenger services such as Skype, Zoom, or FB Messenger. This information may be noted inline with our policy on session notes (below).

We collect personal information via session recordings:

Webcam meetings & sessions: Where meetings and sessions are conducted by Webcam, eg. Zoom, Skype, Facetime, the sessions may be recorded by the consultant, coach or practitioner:

  • Temporarily, and only for as long as it takes to write up the notes not taken contemporaneously.   In such cases, once notes have been documented, the recording will be deleted.

Or

  • Where the recording is part of the service and is provided to you after the appointment.

Your consent will be required on each occasion at the start of the session, unless the recording is kept as part of the service, in which case this will be made clear upon enrollment.

Face-to-Face meetings & session: Some products and services include a recording of the session as part of the product or service. Your consent will be taken upon enrolment.

We collect personal information verbally:

Information may be taken verbally either face-to-face or online, for example at one of our centres, or within a group setting. This includes during consultations, meetings and sessions.

Verbal information may be noted for the purposes of executing our legitimate interest. For example, during consultations, meetings and sessions practitioners will make notes, which they deem appropriate to provide the service and for their own legitimate interest.

Verbal information will be provided to your consultant, coach or practitioners at each appointment.   With the exception of general booking information, payment and accountancy information (where appropriate), and other general information such as your contact details, this information is not processed by Changes Welcome, rather by the consultant, coach, or practitioner with whom the appointment is held. See also ‘Your right to confidentiality’.

You may be asked to sign a clause that you have understood your rights within GDPR at your initial consultation. In such cases, this form will be kept for lawful purposes.

We collect personal information from third parties:

  • Details of your payments from payment service providers such as paypal, our bank, stripe, worldpay or other such services;
  • Details obtained from social media;
  • Details obtained from cookies on third party websites;
  • Details obtained from legal guardians of clients and parents of clients who are minors;
  • Details obtained from one of our practice or business centres where they have received a contact request, or taken a booking;
  • Personal information purchased from providers of third party marketing lists (only if you have given your consent for this).

 

IF YOU CHOOSE NOT TO GIVE PERSONAL INFORMATION

We may need to collect personal information by law, or under the terms of a contract, we have with you, either implied or explicitly stated.

If you choose not to give us this personal information, it may delay or prevent us from meeting our obligations. It may also mean that we cannot provide you with services or products you have opted in for or purchased, and may result in annulment of any contracts without a refund (See also Terms and Conditions). We will notify you if your choice not to give personal information to us would result in a delay or prevent us from meeting our obligations.

Any personal information that is optional will be clearly marked at the point of collection. This does not apply to the content of consultations and sessions.

 

WHO WE SHARE YOUR PERSONAL INFORMATION WITH

Your personal information will only be shared with third party organisations when required (for example for legal organisations or regulatory requirements, in respect of the products and/ or services you request), as well as to fulfil a contract we have with you. Information is shared minimally on a need to know basis.

These types of organisations include:

  • Changes Welcome member Coaches, Consultants & Practitioners who are responsible for fulfilment of a contract with you.
  • The Practice or Business Centre providing a place for face-to-face interactions (such as first name and time of appointment, contact telephone number and email address).
  • HM Revenue & Customs, our regulators and other authorities, including fraud and crime prevention agencies (where required by permitted law).

We may share your personal information for these reasons:

  • Recording you booking for the purposes of receiving you at reception;
  • Contacting you to amend appointments and bookings;
  • Contacting you to collect payments;
  • Legal and regulatory compliance;
  • Preventing or detecting financial crime;
  • Maintaining accountancy records;
  • Complaints handling;
  • Improving customer service;
  • Referring you to other service or product providers with your explicit written consent.

Certain services are provided by third party organisations who collect and use personal information in order to provide those services to you. They are known as ‘joint data controllers’ under data protection law. This means that they have a separate responsibility to protect your personal information and will keep you informed about how your personal information will be used.

In the course of usual business, we may use other third party organisations known as ‘data processors’ under the data protection law to support the essential delivery of services. These organisations process your personal information on our behalf.

These types of organisations are used in order to enable us to run Changes Welcome efficiently, and they include:

  • Accountants;
  • Consultants;
  • Marketing agencies;
  • CRM systems providers;
  • Online accountancy programmes;
  • Payment processors;
  • Sale carts;
  • Webinar platforms;
  • Survey systems;
  • Facebook applications;
  • Content management systems;
  • Viral sharing applications;
  • Autoresponder and email signup services;
  • SMTP services;
  • Membership site services;
  • Community forums;
  • Communications services;
  • Third party white label software access;
  • FTP services;
  • Web hosting services;
  • Calendar, Booking & Scheduling Systems.

 

We only use data processors who are themselves fully compliant with GDPR regulations and seek to receive written assurances from such service providers that they are fully GDPR compliant.

Business or practice premises may operate CCTV surveillance for the purposes of security, and we will seek to confirm that they will handle this information in a compliant and lawful way.

Changes Welcome will never share or sell your personal information to external companies for their own marketing purposes.

 

SENDING PERSONAL INFORMATION OUTSIDE THE EEA

Data protection law holds all countries in the European Economic Area (‘EEA’) to the same high standards. If we transfer information outside the EEA, we will make sure that it is protected to these standards. We will only send your personal information to countries outside the EEA to:

  • Follow your instructions;
  • Comply with a legal duty; or
  • Work with other third-party organisations (as detailed above) who we use to help provide services to you.

We will always require confirmation from the organisation that how they handle personal information complies with European GDPR.

 

MARKETING

We may use your personal information to tell you about relevant products or services offered by Changes Welcome, our coaches, consultants, practitioners, or partners (including providers of services via an affiliate arrangement), as well as to make non-affiliated recommendations that we believe are relevant to you. Coaches, consultants and practitioners may do the same. This is what we mean by ‘marketing’.

We can only use our personal information to send you marketing messages if we either have your consent or a ‘legitimate interest’. Legitimate interest is when we have a business reason to use your information for marketing purposes (which will not unfairly go against your rights and freedoms). In other words, we will not market to you based on legitimate interest if you have told us that you do not want to receive such marketing.

We have a legitimate interest to:

  • Send you marketing messages by post, email or social media about products and services that are similar to those which you have already purchased from us (if you have provided us with relevant contact detail(s);
  • Contact you via telephone to welcome you as a new client, and offer you other additional relevant services;
  • Contact you if you decide to leave or cease to be a customer of ours, or if you have reached the end of the agreed contract;
  • Send you our newsletter;
  • Invite you to take part in additional or complementary services;
  • Invite you to make referrals;
  • Invite you to leave us feedback, reviews or testimonials;

We will ask for your explicit consent to send any other marketing emails.  You can withdraw your consent or ask us to stop sending you any marketing messages at any time. If you want to do so, please contact us by:

  • Following the unsubscribe link on the relevant email;
  • Writing to us at: Changes Welcome, Suite 253, 179 Whiteladies Road, Clifton, Bristol BS8 2AG;
  • Emailing [email protected]

Please note that if you tell us that you no longer wish to receive marketing from us, you will still receive essential service information from us, such as details of changes to the product or services you have form us and updates to this privacy notice.

 

YOUR RIGHTS UNDER GDPR FOR INDIVIDUALS

You have the ‘right to be informed’ about how your personal information is used. This is the reason for this privacy policy. Further rights are itemised below.

In order to exercise your rights under data protection law, where there is any doubt, we will need to verify your identity for your security, in order to communicate with you about your personal information.

You can contact us by emailing [email protected], writing to:

Data Protection Officer,

Changes Welcome,

Suite 253, 179 Whiteladies Road,

Bristol BS8 2AG.

 

How to get a copy of your personal information

You can request a copy of your personal information, as well as why we have that personal information, who has access to that personal information and where we got that personal information from at any time. Such requests must be made in writing to the above email or postal address. Once we have received your request we will respond within 30 days.

Letting us know if your personal information needs updating

You have the ‘right to rectification’ and to question any information we hold on you that you think is wrong, out of date or incomplete. If you do, we will take reasonable steps to check its accuracy and correct it. If you need to update your contact details (and/or the details of others, for example, if you pay for other people, or on behalf of the company you represent, you can also do so by contacting the above email or postal address.

If you want us to stop using your personal information

You have the ‘right to object‘ to the use of your personal information, or to ask us to delete, remove or stop using your information if there is no need for us to keep it. This is known as the ‘right to object’ and the ‘right to erasure’ (or ‘right to be forgotten’).

You also have the ‘right to restrict processing’. We may be able to restrict processing of your personal information so that it can only be used for certain things, such as legal claims or to exercise legal rights. In this situation, we would not use or share your information in other ways while it is restricted.

You can ask us to restrict the use of your personal information if:

  • It is not accurate;
  • It has been used unlawfully but you don’t want us to delete it;
  • It is not relevant any more, but you want us to keep it for use in legal claims; or
  • You have already asked us to stop using your personal information but you are waiting for us to access your request and conform whether we are permitted to continue using the personal information under data protection law.

If you want to object to how we use your personal information, or ask us to restrict how we use it, please contact us using the details above.  If you want us to erase your personal information, for example, if you feel that we should no longer be using your personal information, or that we are illegally using your data, you can request that we erase the personal information we hold on you.  You can also do this by contacting us using the details above.

When we receive your request, we will confirm whether the personal information has been deleted or tell you the reason why it cannot be deleted. This may include requesting further proof of your identity.  There may be legal reasons why we need to keep your personal information or part thereof. Given the nature of aspects of our work, we are required to hold certain details for an extended period due to the fact that the processing of the special category of personal data is
necessary for the provision of healthcare. For example, section B8 of the CNHC (Complementary and Natural Healthcare Council) Code requires registrants to keep client records safely and in good condition for eight years from the date of the client’s last visit or, if the client is a child, until his or her 25th birthday, or 26th birthday if the client was 17 when the treatment ended. This means that registrants have a ‘legitimate interest’ in retaining records for this period.

Your right to portability (obtaining your information in a portable format):

You have the ‘right of access‘ and to get copies of your personal information from us in a format that can be easily re-used (the ‘right to data portability’). You can also ask us to pass on your personal information to other organisations. To request this, please contact us using the details above.

Your right to complain:

If you are not satisfied with our response or believe that we are not processing your personal information in accordance with the law, you can complain to the Information Commissioner’s Office (ICO) by emailing [email protected] or telephoning 0303 123 1113. Additional contact methods are available on their website: https://ico.org.uk/global/contact-us

Your right to confidentiality

Most standards of confidentiality applied in professional contexts are based upon the Common Law concept of confidentiality where the duty to keep confidence is measured against the concept of “greater good”.  Therefore we may disclose your personal information without your consent in certain situations on a lawful basis:

  • If in the coach, consultant or practitioner’s opinion there is good cause to believe that not to disclose your personal information would cause danger or serious harm to self, the coach, consultant, practitioner or others, appropriate agencies may be contacted, including where appropriate healthcare providers and police. Only information required to ensure safety of relevant parties would be disclosed;
  • Information may have to be disclosed without consent for the prevention, detection or prosecution of a crime, including fraud;
  • The sharing of anonymous case histories with supervisors and peer support groups is not a breach of professional confidentiality;

Your right not to be subject to automated decision-making including profiling

We will not use your personal information for automated decision-making or profiling purposes.

 

CHANGES TO THIS POLICY

We regularly review our privacy notice. We will publish any updates on our website, and update customers and subscribers in regular communications. You can request a copy of our privacy policy by using the details above.

 

IF YOU CONTACT US

When you contact us or your consultant, coach or practitioner, we/he/she will need to verify your identity for security reasons. Verifying identity is an important way of safeguarding against criminal activities including the prevention or illicit access to your information.

If we/they are unable to validate your identity, we may ask you to provide further evidence so that your information can be accessed.

 

FREEDOM OF INFORMATION

Changes Welcome and its Consultants, Coaches and Practitioners are not governed by the Freedom of Information Act.

 

LINKS TO OTHER WEBSITES & DIRECT COMMUNICATIONS WITH CONSULTANTS, COACHES & PRACTITIONERS

Our website may contain links to other websites of interest. However, once you use these links please be aware that you have left our website and we do not have any control over other websites. This includes consultants, coaches & practitioners who are not employed by Changes Welcome.

We cannot therefore be held responsible for the protection and privacy of any information which you provide when visiting such sites and these sites are not governed by our privacy policy. We advise therefore that you exercise caution and look at the privacy statement applicable to the website in question.

Consultants, Coaches & Practitioners featured on the Changes Welcome website and other marketing materials form Changes Welcome.

We ensure that any person or entity offering services under the Changes Welcome umbrella are fully GDPR compliant, and have the proper professional qualifications, memberships, and insurances in place that are required and appropriate for the specific services they offer.

 

ICO Registration No:

 

 

 

 

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