1. Who we are.

Feniks was set up in 2007 as a charity supporting integration and aiming at improving the wellbeing of the Central Eastern European Community in Edinburgh. Feniks is a company limited by guarantee without a share capital, registered in Scotland, Company No. 329038, with the charitable status registered in Scotland, no. SC039041.

2. Who is the data administrator (data controller) at Feniks and who to contact about processing your personal data.

FENIKS Counselling, Personal Development and Support Services Ltd. is your data administrator and controller.
Please contact us at info@feniks.org.uk if you would like to get further information or advice about this privacy notice and how we handle your personal information.

3. What information about you do we collect when you visit our website?

a) Google Analytics

When you visit our website, some information about you will be automatically collected by Google Analytics. Google Analytics is a service which allows Feniks to understand the behaviour of our website users and the general traffic on the website, for example, what you, as a user click on or how you move between subpages. The data which we collect is not considered personal data, ie. it is not data which would allow us to identify you.

b) Cookies

Our website uses cookies – when you visit our website for the first time, a pop-up notification will show up asking you if you agree to the use of cookies
Some cookies (session cookies) are removed after your session on the website expires (for example, when you close your browser). Other cookies (persistent cookies) are kept on your device and allow us to recognize your browser every time you visit our website. You can manage the use of cookies in the settings of your browser. Please note that disabling or restricting the use of cookies can limit some functions available on our and other websites.

c) Social media plugins

You can find on our website social media plugins, connecting our website to social media platforms such as Facebook, X, YouTube or Instagram.
Such plugins gather some information about you such as your user ID, visited pages, time when you visited a page or information about your browser.
If you are logged into a social media platform when visiting our website, the platform will recognize your profile and connect it to the visit on our website.
If you wish the information gathered by the social media platforms not to be connected with your profile when you visit our website, you need to log out of the platform before visiting our website. You can also choose to visit our website in the incognito mode. Additionally, there are extensions available for your browser which you can install to block such plugins from loading.
You can find more information about social media plugins in privacy policies of the individual platforms.

4. What information about you do we have when you contact us for the first time?

When you contact us for the first time, you will automatically share with us some personal data.

  • Contact via email or the website contact forms

If you contact us via email, we will have at least your email address. Additionally, we will have all the information which you decide to include in your message.
If you contact us via any contact form, apart from your email address, we will ask for your name and (optionally) your telephone number. Similarly to when you contact us via email, we will also have the information which you share with us in the body of your message.

  • Telephone contact

If you decide to phone us, we will have at least your phone number.

5. What types of your personal information will we have if you decide to use our services?

There are different types of services which we run at Feniks and it will depend on the service or a project, in which you might participate, what personal information we will process. Remember that in most cases we will ask you directly for your personal details, and if it happens that we receive them from another organisation or institution, we must be sure that you know about your information being shared and that you gave consent for this to happen. If you do not understand why we are asking about a specific detail, please, ask us – we have a duty and an obligation to explain to you why we gather and process different pieces of personal information.

  • Clients (therapy, Link Worker, community groups, SMART Recovery, etc.)

Due to the nature of our services Feniks might process the following information about you:

  • Your name.
  • Home address.
  • Email address.
  • Telephone number.
  • Your date of birth.
  • Your gender.
  • Your highly sensitive personal information (depending on the service): medical history, your ethnicity and country of origin, your sexual orientation and sex life.
  • Additionally, the information which you share with us when you communicate with us (via phone or email) and when you participate in our services.

 

  • Volunteers

If you contact us about becoming a volunteer, at the beginning we will ask for your name, email address and your phone number. Depending on the type of volunteering which we can offer you, we can also ask for the following information:

  • Details of two people who you choose for your references.
  • Your home address.
  • Details of your emergency contact.
  • Copy of your proof of identity.
  • Disclosure Scotland or Protecting Vulnerable Groups documents.
  • Depending on the type of the project, we can have your image (for example, when we take pictures during an event). Remember that if you do not want us to use photos or recordings with your image, please, just tell us.

 

  • Participants of various projects

Feniks runs different types of projects and activities and we sometimes can ask for your details if you want to participate in them. In most cases we will ask for your name and some contact details so we can be in contact with you about the project or inform you about any changes or updates about the meetings. Sometimes you might need to register on a third party platform (such as Eventbrite) to participate in the events – remember that the privacy policy of those platforms and websites is not controlled by Feniks. Sometimes we might have your image (for example, when we take pictures during an event) – please tell us if you do not want us to use your image (we will try to ask for your consent before taking pictures or recording).

6. Our lawful basis for using your information.

We will process your data only when there is a lawful basis to do so. We can do it based on:

  • Your consent, for example when you consent to be placed on our waiting list or when you are being referred to a different organisation.
  • Contract, for example when you access our mental health services.
  • Vital interests, when processing is necessary to protect someone’s life.
  • Legal obligation, when processing your data is required by law (for example when hiring a new employee).
  • Legitimate interest, when data processing is necessary to run the organisation’s services, for example to provide high-quality services, keep records of individual support or to defend any potential legal claims.

7. Is your data safe?

We make sure that your personal data is safe. Only authorised members of staff have the access to your personal data. We have analysed the risks carried by processing personal data and have implemented necessary security measures to protect all personal data controlled by Feniks. If you have any questions about the security of your personal data, contact us on info@feniks.org.uk

If a breach of data is detected and assessed as high risk, we are obliged by law to inform the Information Commissioner’s Office within 72 hours after becoming aware of it. We are also obliged to inform the persons whose data were breached.

8. How do we process your personal data?

We are legally obliged to process and store your personal data in a secure, accurate and properly organized way. If your data is processed electronically, it will be processed only on authorised accounts and using authorised software. If your data is processed electronically, Feniks will share the data with third parties due to the fact that we use the services of Google Workspace which belongs to Google – your data will be processed by third parties then (Google) because it will be stored on servers belonging to Google.
Due to the nature of our services it can sometimes happen that we might share your data with other institutions (for example, other organizations, to which we refer you as a part of our service). If such a situation happens, we will not share your data without talking to you first and gaining your consent. We will explain who we will share your data with and why we are doing it. We will not share any of your personal data to private third parties.
Please note that in situations when your life or the lives of others are in danger, we are legally allowed to share your details to the designated authorities without your consent. On rare occasions we might also need to share your data with relevant institutions or authorities (for example Social Care), if there is a safety concern for a child or a vulnerable adult.

9. What is the purpose of processing your personal data at Feniks?

Depending on the reason why you participate in services run by Feniks, the purpose of processing your personal data can differ. The most basic one is to provide you with information when you contact us. The purpose of processing personal data of our clients is to be able to run the designated services – we need your personal details to carry professional counselling services and to provide you with the appropriate support in other Feniks services. Some of your details can also help us understand if we run our services properly and to build relevant statistics. We also process your personal data as a part of legal obligations as a counselling service.

10. How long will we store the information about you?

Depending on the type of the service, we might store your personal data for a different length of time. The basic rule for storing your data is to store the data for no longer that it is required by the purposes of the individual service. If you would like to learn more about the details of storing your data, please contact us at info@feniks.org.uk.

11. Your rights.

Feniks processes your data following the legal framework regulated by the following documents:

  • Data Protection Act 2018
  • UK General Data Protection Regulation

We will not process your data for purposes other than those for which it was acquired or for which you gave consent. Processing your highly sensitive data by Feniks is legal under Article 9(2) UK GDPR and is based mainly on your explicit consent when you start using our services, but also due to fact that Feniks, as a charity which runs counselling services, will store information as a legal basis for potential court cases. In very rare situation, when your life and safety or the lives and safety of others might be at risk, we can process your data without your consent (for example, we have the obligation of safeguarding vulnerable people or groups.

At any point of using our services you have the right to:

  • Gain access to your personal data processed at Feniks (please note that if our records contain the information about other people among your personal data we might redact your copy to protect the data of those third parties).
  • Restrict the processing of your personal information.
  • Rectify or correct your personal details.
  • Withdraw your consent to be contacted.
  • Object to the processing of your personal information.
  • Ask to have your personal information removed. Please note that if you ask to remove your personal data from Feniks’ records, it might mean that you can no longer use the specific Feniks service (for example, we would need to stop your counselling sessions). On rare occasions we might need to refuse your request, if we judged to have legal reason to do it. We would always assess every such case individually and we would try to act with the utmost understanding and transparency about the situation.

12. Complaints.

If you are not satisfied with Feniks’ data processing procedures, you can:

  • Make a formal complaint to us by contacting us by:

Phone: 0131 629 1881
Email: info@feniks.org.uk

Our detailed complaints procedure is available on our website: https://feniks.org.uk/services/complaints/

  • Inform the Information Commissioner’s Office:

https://ico.org.uk/make-a-complaint/data-protection-complaints/