TRC Privacy Notice
Privacy Policy
The Recovery Centre Limited (“TRC Group”) understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, www.trcgroup.org.uk (“Our Site”) and access our Services, and only collect and use your personal data as described in this Privacy Policy. Any personal data we collect will only be used as permitted by law.
Our Website and Services may contain links to third party websites that are not covered by this Privacy Policy. We therefore ask you to review the privacy statements of other websites and applications to understand their information practices.
We have drafted this Privacy Policy to be as clear and concise as possible. Please read it carefully to understand our policies regarding your information and how we will treat it. By using or accessing our Website or the Services, you agree to the collection, use and disclosure of information in accordance with this Privacy Policy. This Privacy Policy may change from time to time and your continued use of the Website or the Services.
1. Information About Us
Our company name is The Recovery Centre Limited, a Private Treatment Centre [registered in England under company number 05905491]. The Recovery Centre Limited is trading as TRC Group.
Registered address: Timsons Business Centre, Bath Road, Kettering, Northants, NN16 8NQ.
Main trading address: 75 Kinnerton Street, London, SW1X 8ED
Data Protection Officer: Laura Batt
Email address: laura@trcgroup.org.uk.
Telephone number: 02072350080.
Postal address: 75 Kinnerton Street, London, SW1X 8ED
We are a member of British Association for Counselling and Psychotherapy
We respect your right to privacy and will only process personal information about you or provided by you in accordance with the Data Protection Legislation which for the purposes of this Privacy Policy shall mean: (i) the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) (UK GDPR), (ii) the Data Protection Act 2018 and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK and then (ii) any successor legislation to the UK GDPR or the Data Protection Act 2018 and other applicable privacy laws.
2. What we may collect
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).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Identity Data includes first name, last name, username or similar identifier. When you email, phone, live chat or otherwise, we may collect information such as your first name, last name, email address and phone number.
• Contact Data includes billing address, invoicing address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments and other details of our Services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Website.
• Usage Data includes information about how you use our Website and Services.
• Cookies Data like many websites, we use “cookies” to enhance your experience and gather information about visitors and visits to our websites. Please refer to section below for information about cookies and how we use them and what kind.
• Third Parties and Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or through the Services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on our Website. We are also working closely with third parties (including, for example, business partners, suppliers, sub-contractors, advertising networks, analytics providers, and search information providers) and may receive information about you from them.
• Analytics includes third-party analytics services (such as Google Analytics) to evaluate your use of the Website, compile reports on activity, collect demographic data, analyse performance metrics, and collect and evaluate other information relating to our Website and internet usage. These third parties use cookies and other technologies to help analyse and provide us the data. By accessing and using the Website, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy.
Under UK GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
a) processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
b) processing is necessary for compliance with a legal obligation to which we are subject;
c) processing is necessary to protect the vital interests of you or of another natural person; and/or
d) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party such as our financial payments, except where such interests are overridden by the fundamental rights and freedoms of the data subject, in particular where the data subject is a child.
If you provide personal information to us about another data subject, you are responsible for ensuring that you have their consent to provide that data for the uses set out in this Privacy Policy and for bringing this Privacy Policy to their attention.
3. How we may collect and use your data
We (or third party data processors, agents and sub-contractors acting on our behalf) may collect, store and use your personal information by way of different methods to collect data from and about you including through:
Direct interactions. You may give us your information by filling in forms via our Website or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
a) use any of our Services;
b) subscribe to our Services or publications; or
c) give us some feedback.
In addition to the above, we may use the information in the following ways:
a) Carry out our contracts with you.
b) Provide the relevant Services to you
c) Tell you our charges.
In some cases, the collection of personal data may be a statutory or contractual requirement, and we will be limited in the services we can provide you if you don’t provide your personal data in these cases.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
a) Where we need to perform the contract we are about to enter into or have entered into with you.
b) Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
c) Where we need to comply with a legal or regulatory obligation, for example compliance with health and safety, tax or other statutory obligations.
We agree that we will not do anything that we have not agreed to under this Privacy Policy, and we will not send you any unsolicited marketing or spam. We will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the UK GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended.
4. Cookies
All Cookies used by and on our website are used in accordance with current UK Cookie Law.
We use cookies to distinguish users and improve our Website.
We use Necessary cookies that help make our website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.
We use Statistic cookies to help website owners to understand how visitors interact with websites by collecting and reporting information anonymously.
We also use Marketing cookies that are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third party advertisers.
5. Where we store your data and security
We may transfer your collected data to storage outside the UK. If we do store or transfer data outside the UK, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the UK GDPR. Such steps may include, but not be limited to, the use of legally binding contractual terms between us and any third parties we engage with and the use of approved Model Contractual Arrangements.
Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through our Website. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
By giving us your personal data, you agree to this arrangement. We will do what we reasonably can to keep your data secure.
Any payments made by you, will be encrypted.
We have implemented security measures to protect any data and maintain a high level of security.
Notwithstanding the security measures that we take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to us data via the internet and you take the risk that any sending of that data turns out to be not secure despite our efforts.
We will keep personal data for as long as is necessary which is usually the life of our relationship and up to a period of seven years after our relationship have ended. We may, however, in certain circumstances, be required to retain personal data for a longer period of time to ensure we comply with our legislative and regulatory requirements. We review our data retention obligations to ensure we are not retaining data for longer than we are legally obliged to.
6. Disclosing or sharing your information
We are allowed to disclose your information in the following cases:
• We can disclose it to medical experts that are treating you
• We can disclose it if we have a legal obligation to do so, or in order to protect you or your or other people’s property, safety or rights.
• We can exchange information with others to protect against fraud or credit risks.
We may contract with third parties to supply services to you on our behalf. These may include payment processing or search engine facilities. In some cases, the third parties may require access to some or all of your data.
Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under UK GDPR and the law. Any third party that we share data with will not be permitted to use it for any other purpose than fulfilling their contract with us.
7. What Are My Rights?
Under the Data Protection Legislation, you have the following rights:
a) The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions by contacting our data protection officer.
b) The right to access to the personal data we hold about you.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time. We do not rely on consent as a lawful basis.
h) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
i) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
It is important to note that these rights are not absolute.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, so please contact our data protection officer.
We will not process your personal data any longer than is necessary.
We will not share any of your personal data with any third parties for any purposes other than the purposes described in part 6 of storage on an email and/or web hosting server.
8. Contact us
To contact us about anything to do with your personal data, please use the following details (for the attention of Laura Batt):
Email address: laura@trcgroup.org.uk.
Telephone number: 02072350080.
Postal Address: 75 Kinnerton Street, London, SW1X 8ED.
9. Changes to this Privacy Policy
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
This Privacy Policy was last updated on 3 November 2022.