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In association with JoNaxtonPsychotherapies: 

PHOENIX COUNSELLING AND THERAPY SERVICES CIC Policy on General Data Protection Regulations


Phoenix Counselling and Therapy Services CIC, holds, collects and processes information about its staff (prospective, current and former). The information (which includes personal and special categories data) may include images and personal, academic, employment, financial, health, ethnicity and disability information. This information is used for various administrative, management, health and safety and statutory and regulatory reasons. The information provided by, and relating to, applicants and staff is processed in accordance with relevant current Data Protection Legislation.

PHOENIX COUNSELLING AND THERAPY SERVICES CIC will ensure that data is collected within the boundaries defined in this policy. This applies to data that is collected in person, or by completing a form or electronic.

When collecting data, PHOENIX COUNSELLING AND THERAPY SERVICES CIC will ensure that the Individual/Service User:

  • Signs the data protection consent to hold/store information.

  • Clearly understands why the information is held

  • Understands what it will be used for and what could happen should the Individual/Service user decide not to give consent to processing

  • As far as reasonably possible, grants consent, either written or verbal for data to be processed.

  • Is, as far as reasonably practicable, competent enough to give consent and has given so freely without any duress.

  • Has received sufficient information on why their data is needed and how it will be used so the individual can make an informed decision when giving consent.

Data Storage

Information and records relating to service users will be stored securely and will only be accessible to authorised staff.

Information will be stored only if it is a needed or required statute and will be disposed of appropriately.

It is PHOENIX COUNSELLING AND THERAPY SERVICES CIC responsibility to ensure all personal and company data is non-recoverable from any computer system previously used within the company, which has been passed on/sold to a third party.

Data access and accuracy

All service users have the right to access the information PHOENIX COUNSELLING AND THERAPY SERVICES CIC holds about them. PHOENIX COUNSELLING AND THERAPY SERVICES CIC will also take reasonable steps ensure that this information is kept up to date by asking data subjects whether there have been any changes. Any third-party information will be redacted when instructed by a court of law.


  • It has a Data Protection Officer with specific responsibility for ensuring compliance with Data Protection (Peter Haggerston)

  • Everyone processing personal information understands that they are contractually responsible for following good data protection practice and to familiarise themselves with the GDPR legislation as Data processers/ handlers. This will include the 6 principles on which the GDPR legislation is set.

  • Everyone processing personal information is appropriately trained to do so and has been given clear guidance on how the procedure is set up within the office environment.

  • Everyone processing personal information is appropriately supervised.

  • Anybody wanting to make enquiries about handling personal information knows what to do. Inform the DPO and respond within 30 days at no charge as per GDPR legislation.

  • It deals promptly and courteously with any enquiries about handling personal information.

  • It describes clearly how it handles personal information.

  • It will regularly review and audit the ways it holds, manages and uses personal information.

  • It regularly assesses and evaluates its methods and performance in relation to handling personal information.

  • All staff are aware that a breach of the rules and procedures identified in this policy may lead to disciplinary action being taken against them.

This policy will be updated as necessary to reflect best practice in data management, security and control and to ensure compliance with any changes or amendments made to the Data Protection Act 1998.

In case of any queries or questions in relation to this policy please contact the Data Protection Officer:  PHOENIX COUNSELLING AND THERAPY SERVICES CIC Director:  Peter Haggerston.

ICO: ZB581418

Jo Naxton Psychotherapies Data Protection Officer: Joanna Naxton.

ICO: CNS6633749

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