Privacy Policy

Connecting Minds Limited referred to as ‘Connecting Minds, ‘we’ or ‘our’ is committed to protecting the privacy and security of your personal information. This Privacy Notice describes how we collect and use personal information about you during and after your relationship with us pursuant to the Data Protection (Jersey) Law 2018 (“DPJL”). Connecting Minds Limited is a “Data Controller”, which means we are responsible for deciding how we hold and use personal information. We are also registered with the Jersey Office of the Information Commissioner (“JOIC”) – Registration No. 101090. We will comply with data protection law, the principles of which says that the personal information 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 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 your data only as long as necessary for the purposes we collected it.
Kept securely.

Connecting Minds Limited is accountable to you and the Authorities to show compliance with Data protection (Jersey) Law 2018 (“DPJL”) and demonstrate how we are compliant.

The Data Protection Manager ("DPM")

We have appointed a DPM to oversee compliance with this Privacy Notice.

If you have any questions about this Privacy Notice or how we handle your personal information, contact the DPM at dataprotection@connectingminds.je

You have the right to make a complaint at any time to the JOIC.

Contact details for these are outlined at the bottom of this Privacy Notice.

The Kind of Information We Hold About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). To explain this to you, we will list our different services when we collect or use additional information about you.

How Is Your Personal Information Collected?

We collect personal information about you when you contact us, get referred to our services, book a session, take part in therapy, coaching, workshops, consultation, and clinical supervision, or provide us with your data for another specific purpose.

What information do we collect about you?

Records of email correspondence
Name
Telephone number
Email address

Book a Session (via website application form or by phone)

Name
Telephone number
Email Address
Billing address (home address)
Card details for payment
Therapy Message (will contain sensitive data on your health and well-being when communicated via website application)

Therapy and Wellbeing Interventions

Name
Email address
Telephone number
Therapy Session notes/summary (will contain sensitive data on your health and well-being when communicated at a session)
GP Practice

Workshops, consultation, clinical supervision

Name
Telephone number
Email Address
Billing address (home address)
Card details for payment

Marketing communication

Name
Email address

What Special Category Data do we collect about you?

We collect what is called Special Category data, and we will always have either a clear legal basis to process this or your explicit consent. Special Category data is any information relating to your racial or ethnic origin, political opinion, religion or philosophical belief or trade union membership, health, race, sexual orientation, sex life, genetic or biometric data, data relating to a criminal record or alleged criminal activity, etc.

An example of this processing would be when you complete our application form or make a booking we will collect sensitive information on your health. We have a legal obligation to collect this information and store it.

Where necessary, we will also collect the following information:

Nationality
Ethnicity
Gender
Marital Status
Country of Birth
Family History
Health Information
Medication Information
Referral Source
Previous service details
Emergency Contact Info
Additional Needs Info
Client risk assessment

If we rely on your Explicit Consent, you can withdraw this at any time by contacting our DPM at dataprotection@connectingminds.je

How We Will Use Information About You?

We will only use your personal information when the law allows us to.

Most commonly, we will use your personal information in the following circumstances:

You have entered into a Contract with us to provide you with a service; an example would be when you have engaged Connecting Minds to provide assistance and one-on-one therapy sessions.
Processing your data for the provision of Counselling; for example, we process your data when we provide our counselling services to you to provide advice and support.
We need to comply with a Legal Obligation; an example of this would be when we have to comply with the legal requirements regarding safeguarding concerns for your welfare or that of those around you.
Where you have given us, your Consent to contact you for a specific purpose, an example of this would be when we get your consent to share your data with health care professionals for referrals to their services which you may require.

We may also use your personal information in the following situations:

In an emergency, it is in your Vital Interest to share your information when we have it recorded; an example would be, if there was an incident on our premises and we had to provide emergency services with the personal data of people on the site.

Change of purpose

We will only use your personal information for the purposes we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal information for an unrelated purpose, we will notify you and explain the legal basis that allows us to do so.

Data Sharing

We do not pass on information gained from your engagement with us without a clear legal basis for doing so. However, we may disclose your Personal Information to meet legal obligations, regulations, or valid governmental requests.

We use certain third parties, also known as Processors, to provide or support our services. We have appropriate agreements in place with those processors to ensure the safety of your information. For information on these processors, please see the table below. We do not share your information with any processors for direct marketing purposes.

Data may be shared with referral sources such as Insurance Companies and Health Care Agencies. At times it may be necessary to provide brief reports within contractual agreements or to secure additional sessions.

The current data processors used by Connecting Minds Limited are:

Processor	Description of processing	Link to Privacy Notice
Office 365	The data collected from clients during their consultation sessions is stored using various secure servers such as internal documents, Outlook, Calendar, and OneDrive, please refer to the Microsoft Privacy Statement.	Microsoft - Privacy Statement
Propelfwd	Data Protection Compliance Consultants. They provide advice and assistance with our data protection requirements and have no access to your data. For more information about how they use information, please visit the PropelFwd Privacy Notice.	PropelFwd - Privacy Policy
AI Studio	We use AI studio as our website developers. AI Studio do not store your personal information on behalf of Connecting Minds. For more information about how they use information, please visit the AI Studio Privacy Notice.	AI Studio - Privacy Policy
WhatsApp	Direct communication with clients regarding appointments.	Privacy Policy (whatsapp.com)

Processors are other organisations/services carefully chosen by Connecting Minds Limited to process your information correctly and securely. In the case of organisations outside of Jersey, the United Kingdom and the European Economic Area (EEA);

(a) we have prior written instructions for the transfer or (b) we have entered into specific contractual terms with them to ensure that they treat your personal data in way equivalent to that in which they would be required if they were established in Jersey.

We ensure that your privacy rights are respected in line with this Notice and the same protection is given to your personal data as laid down by the DPJL.

Data Security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, altered or disclosed, or accessed in an unauthorised way. In addition, we limit access to your personal information to those Staff, Agents, Contractors and other third parties on a need-to-know basis. They will only process your personal information according to our strict instructions and are subject to a duty of confidentiality. Details of these measures may be obtained from our DPM. We have put in place procedures to deal with any suspected data security breach and notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Data Retention

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including to satisfy any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your data. The purposes for which we process your data and whether we can achieve those purposes through other means and the applicable legal requirements.

You can request our Data Retention Schedule from our DPM if required.

In some circumstances, we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

Rights of Access, Correction, Erasure, and Restriction

The personal information we hold about you must be accurate and current. Please keep us informed if your information changes during your relationship with us. Under certain circumstances, by law, you have the right to:

Request access to your personal information (commonly known as a “data subject access request”). This right enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This right enables you to have any incomplete or inaccurate data we hold about you corrected.
Request erasure of your personal information. This right enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
Object to processing your personal information where we rely on a legitimate interest (or those of a third party). There is something about your situation that makes you want to object to processing on this ground. You also have the right to object to processing your personal information for direct marketing purposes.
Request the restriction of processing of your personal information. This right 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.
Request the transfer of your personal information to another party.

If you want to review, verify, correct or request the erasure of your personal information, object to the processing or request that we transfer a copy of your personal information to another party, contact our DPM at dataprotection@connectingminds.je

You will not have to pay a fee to access your personal information (or exercise any other rights). However, we may charge a reasonable fee if your access request is unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

How to request your information and what we may need from you

You can use the Data Subject Access Request form, available on our Cookie Banner. You can also email in your request, make your request over the telephone verbally to one of our team, whatever way you feel more comfortable with.

If you have any questions about this process or any of your rights, contact our DPM dataprotection@connectingminds.je

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or exercise any of your other rights).

We will respond to your request without undue delay, but certainly within Four Weeks after satisfactory identity verification. In some circumstances, we can apply an eight-week extension to this time frame when the request is complex in nature and cannot be answered in the four-week time frame. If this is to happen, we will inform you as soon as possible.

Right to Withdraw Consent

In the limited circumstances where you may have provided your consent to the collection, processing, and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.

To withdraw your consent, contact our DPM at dataprotection@connectingminds.je

Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to unless we have another legitimate basis for doing so in law.

Changes to this Privacy Notice

We reserve the right to update this privacy notice at any time and will provide you with a new one when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information or requesting you confirm the accuracy of the information we hold on you.

Confidentiality Statement

Maintaining your confidentiality is our top priority at Connecting Minds Ltd. All information pertaining to you or our collaborative work will be held in strict confidence within our organisation. However, there are certain exceptions that we want you to be aware of:

1. Legal Obligations and Duty of Care:

In certain circumstances, we may be obligated by law or our ethical codes of conduct to share your data. This includes situations where there is a Legal Requirement, concerns about the welfare of a child or vulnerable adult, or if there is an immediate risk to yourself or others.

2. Data Sharing:

With your Explicit Consent, we may share relevant data with our associate practitioners for the purpose of onward referral. Your privacy and preferences will always be respected.

3. Referrer Communication:

If you were referred to our service by a third party, and with your Agreement, we may find it beneficial to communicate with your referrer or other involved agencies to enhance the effectiveness of your treatment.

4. Clinical Supervision:

Clinical supervision is a professional practice that allows us to reflect on our collaborative work with a clinical supervisor. This ensures we maintain effective clinical practices and provide you with the best possible outcomes. To protect your privacy, we will not use your real name or directly identifiable data during these sessions.

5. Third-Party Invoicing:

If you claim session costs through your insurance or a third party, we may need to share session dates for invoicing purposes. Additionally, details about your treatment and progress may be required to secure further funding. In such cases, we will share the minimum necessary data after discussing and obtaining your agreement.

Rest assured, your privacy is of utmost importance to us, and we will always take measures to ensure the confidentiality of your information.

Complaints

We want the chance to resolve any complaints you have about how we process your information. You have the right to complain to the JOIC about how we have used your data. The details for each of these contacts are:

Connecting Minds Limited
1st Floor, 13 Royal Square, St Helier, Jersey JE2 4WA
Telephone +44 07829 883271 or email dataprotection@connectingminds.je

Jersey Office of the Information Commissioner
2nd Floor, 5 Castle Street, St Helier, Jersey JE2 3BT
Telephone +44 (0) 1534 716530 or email enquiries@jerseyoic.org