Privacy & Cookie Policy

Introduction and Purpose

HCC is committed to being transparent about how it collects and uses the personal data of all engaged with the organisation, and to meeting its data protection obligations. This policy sets out our commitment to data protection, and individual rights and obligations in relation to personal data.

This policy applies to the personal data of anybody engaged with or previously engaged with HCC, referred to as HR-related personal data.

HCC has appointed Natasha Harrison, as the Data Protection Controller, who is the person with responsibility for data protection compliance within HCC. Questions about this policy, or requests for further information, should be directed to her via admin@highgatecounselling.org.uk.

Definitions

“Personal data” is any information that relates to an individual who can be identified from that information. Processing is any use that is made of data, including collecting, storing, amending, disclosing or destroying it.

“Special categories of personal data” means information about an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation and biometric data.

“Criminal records data” means information about an individual’s criminal convictions and offences, and information relating to criminal allegations and proceedings.

Data protection principles

HCC processes personal data in accordance with the following data protection principles:

HCC processes personal data lawfully, fairly and in a transparent manner.

HCC collects personal data only for specified, explicit and legitimate purposes.

HCC processes personal data only where it is adequate, relevant and limited to what is necessary for the purposes of processing.

HCC keeps accurate personal data and takes all reasonable steps to ensure that inaccurate personal data is rectified or deleted without delay.

HCC keeps personal data only for the period necessary for processing.

HCC adopts appropriate measures to make sure that personal data is secure, and protected against unauthorised or unlawful processing, accidental loss, destruction or damage.

HCC tells individuals the reasons for processing their personal data, how it uses such data and the legal basis for processing in its privacy notices. It will not process personal data of individuals for other reasons.

HCC will update personal data promptly if an individual advises that his/her information has changed or is inaccurate.

Personal data gathered during HCC’s engagement is held in the individual’s personnel file (in hard copy or electronic format, or both), and on HR systems. The periods for which HCC holds personal data are contained in its privacy notices to individuals.

HCC keeps a record of its processing activities in respect of personal data in accordance with the requirements of the UK General Data Protection Regulation (UK GDPR).

Individual rights

As a data subject, individuals have a number of rights in relation to their personal data.

Subject access requests

Individuals have the right to make a subject access request. If an individual makes a subject access request, HCC will tell them:

whether or not their data is processed and if so why, the categories of personal data concerned and the source of the data if it is not collected from the individual;

to whom their data is or may be disclosed;

for how long their personal data is stored (or how that period is decided);

their rights to rectification or erasure of data, or to restrict or object to processing;

their right to complain to the Information Commissioner if they think HCC has failed to comply with their data protection rights; and

whether or not HCC carries out automated decision-making and the logic involved in any such decision-making.

HCC will also provide the individual with a copy of the personal data undergoing processing.

If the individual wants additional copies, HCC will charge a fee, which will be based on the administrative cost to HCC of providing the additional copies.

To make a subject access request, the individual should send the request to admin@highgatecounselling.org.uk. In some cases, HCC may need to ask for proof of identification before the request can be processed. HCC will inform the individual if it needs to verify their identity and the documents they require.

HCC will normally respond to a request within a period of one month from the date it is received. In some cases, such as where HCC processes large amounts of the individual’s data, it may respond within three months of the date the request is received. HCC will write to the individual within one month of receiving the original request to tell them if this is the case.

If a subject access request is manifestly unfounded or excessive, HCC is not obliged to comply with it. Alternatively, HCC can agree to respond but will charge a fee, which will be based on the administrative cost of responding to the request. A subject access request is likely to be manifestly unfounded or excessive where it repeats a request to which HCC has already responded. If an individual submits a request that is unfounded or excessive, HCC will notify them that this is the case and whether or not it will respond to it.

Other rights

Individuals have a number of other rights in relation to their personal data. They can require HCC to:

rectify inaccurate data;

stop processing or erase data that is no longer necessary for the purposes of processing;

stop processing or erase data if the individual’s interests override the HCC’s legitimate grounds for processing data (where HCC relies on its legitimate interests as a reason for processing data);

stop processing or erase data if processing is unlawful; and

stop processing data for a period if data is inaccurate or if there is a dispute about whether or not the individual’s interests override the HCC’s legitimate grounds for processing data.

To ask HCC to take any of these steps, the individual should send the request to admin@highgatecounselling.org.uk.

Data security

HCC takes the security of personal data seriously. HCC has internal policies and controls in place to protect personal data against loss, accidental destruction, misuse or disclosure, and to ensure that data is not accessed, except by employees in the proper performance of their duties.

Where the HCC engages third parties to process personal data on its behalf, such parties do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and procedural measures to ensure the security of data.

Impact assessments

Some of the processing that HCC carries out may result in risks to privacy. Where processing would result in a high risk to individual’s rights and freedoms, HCC will carry out a data protection impact assessment to determine the necessity and proportionality of processing. This will include considering the purposes for which the activity is carried out, the risks for individuals and the measures that can be put in place to mitigate those risks.

Data breaches

If HCC discovers that there has been a breach of personal data that poses a risk to the rights and freedoms of individuals, it will report it to the Information Commissioner within 72 hours of discovery. HCC will record all data breaches regardless of their effect.

If the breach is likely to result in a high risk to the rights and freedoms of individuals, it will tell affected individuals that there has been a breach and provide them with information about its likely consequences and the mitigation measures it has taken.

Individual responsibilities

Individuals are responsible for helping HCC keep their personal data up to date. Individuals should let HCC know if data provided to HCC changes, for example if an individual moves house or changes their bank details.

Individuals may have access to the personal data of other individuals engaged in HCC in the course of their engagement. Where this is the case, HCC relies on individuals to help meet its data protection obligations to all engaged in HCC.

Individuals who have access to personal data are required:

to access only data that they have authority to access and only for authorised purposes;

not to disclose data except to individuals (whether inside or outside HCC) who have appropriate authorisation;

to keep data secure (for example by complying with rules on access to premises, computer access, including password protection, and secure file storage and destruction);

not to remove personal data, or devices containing or that can be used to access personal data, from the HCC’s premises without adopting appropriate security measures (such as encryption or password protection) to secure the data and the device; and

not to store personal data on local drives or on personal devices that are used for work purposes.

Failing to observe these requirements may amount to a disciplinary offence, which will be dealt with under the HCC’s disciplinary procedure. Significant or deliberate breaches of this policy, such as accessing employee or customer data without authorisation or a legitimate reason to do so, may constitute gross misconduct and could lead to dismissal without notice.

Training

HCC will provide training to all individuals about their data protection responsibilities as part of the induction process.

Individuals whose roles require regular access to personal data, or who are responsible for implementing this policy or responding to subject access requests under this policy, will receive additional training to help them understand their duties and how to comply with them.

Use of cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to our customer’s needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies and save your preferences. If no choice is made, the system will not use cookies, except for functional cookies required to operate the site.

To find out more about cookies, including how to see what cookies have been set and how to block and delete cookies, please visit http://www.aboutcookies.org/.

Cookies we may use

We may use ga, gid and gat cookies to track website visitors using the provider Google Analytics.

Contact details

If you have any questions about this privacy and cookie policy, or the information we hold about you, please contact HCC directly and we will happily discuss this with you.

The best way to reach us is to contact us via email: admin@highgatecounselling.org.uk

If you wish to contact HCC’s Data Protection Controller direct, please email: natasha.harrison@highgatecounselling.org.uk

Effective as at: 3 February 2026