The Sherwood Psychotherapy Training Institute
Privacy Notice
© SPTI 2019 SPTI Privacy Notice 2019
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Welcome to The Sherwood Psychotherapy Training Institute Limited’s (“we”, “us” and “our”) privacy
notice. We trade as “The Sherwood Psychotherapy Training Institute” and are also referred to as
SPTI
We respect your privacy and are committed to protecting your personal data. This privacy notice
will inform you how we look after your personal data when you ask us to send you information, you
apply to join us, you use our website, while you are a student and after you leave us and become
one of our graduate members. This privacy notice also tells you about your privacy rights and how
the law protects you.
This privacy notice is provided in a layered format so you can click through to the specific areas set
out below. Please also use the Glossary at the end to understand the meaning of some of the
terms used in this privacy notice.

  1. Important information and who we are
  2. The data we collect about you
  3. How is your personal data collected
  4. How we use your personal data
  5. Sharing your personal data
  6. International transfers
  7. Data security
  8. Data retention
  9. Your legal rights
  10. Glossary
  11. Important information and who we are
    This privacy notice tells you what personal data we collect about you, how we use the data and
    who might see it.
    It is important that you read this privacy notice together with any other privacy notice or fair
    processing notice we may provide on specific occasions when we are collecting or processing
    personal data about you so that you are fully aware of how and why we are using your data. This
    privacy notice supplements the other notices and is not intended to override them.
    Controller
    The Sherwood Psychotherapy Training Institute Limited is the controller and responsible for your
    personal data.
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    We are registered as a controller on the Data Protection Register. Our registration number is
    Z5182304.
    We have appointed a data privacy manager who is responsible for overseeing questions in relation
    to this privacy notice. If you have any questions about this privacy notice, including any requests to
    exercise your legal rights, please contact the Data Privacy Manager using the details set out
    below.
    Contact details
    Our full details are:
    Full name of legal entity: The Sherwood Psychotherapy Training Institute Limited
    Name or title of Business Manager: Amanda Ackroyd
    Email address: DataPrivacyManager@spti.net
    Postal address: Sherwood Psychotherapy Training Institute, Thiskney House, 2 St James
    Terrace, Nottingham, NG1 6FW
    You have the right to make a complaint at any time to the Information Commissioner’s Office
    (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would,
    however, appreciate the chance to deal with your concerns before you approach the ICO so please
    contact us in the first instance.
    Changes to the privacy notice and your duty to inform us of changes
    This version was last updated in May 2019.
    It is important that the personal data we hold about you is accurate and current. Please keep us
    informed if your personal data changes during your relationship with us
    Third party rights
    Our website may include links to third-party websites, plug-ins and applications. Clicking on those
    links or enabling those connections may allow third parties to collect or share data about you. We
    do not control these third-party websites and are not responsible for their privacy statements.
    When you leave our website, we encourage you to read the privacy notice of every website you
    visit.
  12. The data we collect 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). There are also “special categories” of more sensitive personal data which
    require a higher level of protection.
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    We may collect, use, store and transfer different kinds of personal data about you which we have
    grouped together as follows:
    • Identity Data includes full legal name, informal name, previous names, marital status, title,
    date of birth, gender, and a photograph.
    • Contact Data includes billing address, home address, email address and telephone
    numbers.
    • Financial Data includes bank account and transaction details, sponsorship details.
    • Enrolment Data includes details about payments to and from you and other details of
    courses, products and services you have purchased from us.
    • Academic Data includes qualifications and other academic records; information about your
    professional experience; and information about disciplinary action taken against you.
    • 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 our website
    and IT systems (such as our virtual learning environments (Moodle) and access our library.
    • Marketing and Communications Data: includes your preferences in receiving marketing
    from us and our third parties and your communication preferences.
    • Special Categories Data: includes information about your race or ethnicity, religious
    beliefs, sexual orientation and political opinions; information about your health, including
    any medical condition (such as information about disability status or learning difficulty),
    health and sickness records; information about criminal convictions and offences.
    The information we hold includes the details provided by you on application and enrolment,
    together with data which is collected during and after your studies.
    This can include “special categories” of more sensitive personal data.
    We also collect, use and share Aggregated Data such as statistical data, demographic data and
    data about the race or national or ethnic origin, religious, philosophical or moral beliefs, or sexual
    life or sexual orientation of our students for any purpose. Aggregated Data may be derived from
    your personal data but is not considered personal data in law as this data does not directly or
    indirectly reveal your identity. For example, we may aggregate your parts of your Identity,
    Enrolment and Special Categories Data to calculate the percentage of applications from different
    areas of the country or the percentage of applications from a particular racial group. However, if we
    combine or connect Aggregated Data with your personal data so that it can directly or indirectly
    identify you, we treat the combined data as personal data which will be used in accordance with
    this privacy notice.
    Where we need to collect personal data by law, or under the terms of a contract we have with you
    and you fail to provide that data when requested, we may not be able to perform the contract we
    have or are trying to enter into with you (for example, to enrol you on one of our courses). In this
    case, we may have to cancel your enrolment and we will notify you if this is the case at the time.
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  13. How is your personal data collected?
    We use different methods to collect data from and about you including through:
    • Direct interactions. You may give us your Identity, Contact, Financial, Enrolment,
    Academic and Special Categories Data by filling in forms or by corresponding with us by
    post, phone, email or otherwise. This includes personal data you provide when you:
    o apply for our courses;
    o enrol on to one of our courses;
    o request information or marketing material to be sent to you;
    o give us some feedback;
    • Automated technologies or interactions. As you interact with our website and IT
    systems, we may automatically collect Technical Data about your equipment, browsing
    actions and patterns and the facilities or resources you have accessed. We collect this
    personal data by using cookies, server logs and other similar technologies. We may also
    receive Technical Data about you if you visit other websites employing our cookies. Please
    see our cookie policy for further details.
    o Third parties or publicly available sources. We may receive personal data about
    you from various third parties [and public sources] as set out below Technical Data
    from the following parties:
    ▪ analytics providers [such as Google based outside the EU];
  14. How we use your personal data
    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:
    • Where we need to perform the contract we are about to enter into or have entered into with
    you;
    • 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;
    • Where we need to comply with a legal or regulatory obligation; or
    • Where we have your consent.
    Sometimes we may rely on consent as a legal basis for processing your personal data. Were we
    do so, you have the right to withdraw consent at any time by contacting us.
    Purposes for which we will use your personal data
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    We have set out below, in a table format, a description of all the ways we plan to use your personal
    data, and which of the legal bases we rely on to do so. We have also identified what our legitimate
    interests are where appropriate.
    Special Categories Data is particularly sensitive personal information and requires higher levels of
    protection. We need to have further justification for collecting, storing and using this type of
    personal information. We may process Special Categories Data of personal information in the
    following circumstances:
    • In limited circumstances, with your explicit written consent.
    • Where it is needed in the substantial public interest, such as for equal opportunities
    monitoring.
    • Where it is required to protect your (or someone else’s) vital interest and you are not
    capable of giving consent, such as for getting medical assistance for you.
    Note that we may process your personal data for more than one lawful ground depending on the
    specific purpose for which we are using your data. Please contact us if you need details about the
    specific legal ground we are relying on to process your personal data where more than one ground
    has been set out in the table below.
    Purpose/Activity Type of data Lawful basis for processing
    including basis of legitimate
    interest
    (a) To enrol you as a new
    student
    (a) Identity
    (b) Contact
    (c) Financial
    (d) Academic
    (e) Special Categories
    Performance of a contract with you
    (a) To introduce you to sources
    of student finance
    (b) To process and assess
    bursary applications
    (a) Identify
    (b) Contact
    (c) Academic
    (a) Consent
    (b) Necessary for our legitimate
    interests (to help you fund your
    programme of study with us)
    To deliver your course to you
    including:
    (a) Manage payments, fees
    and charges
    (b) Collect and recover money
    (a) Identity
    (b) Contact
    (c) Financial
    (d) Enrolment
    (a) Performance of a contract with
    you
    (b) Necessary for our legitimate
    interests (to recover debts due to us)
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    owed to us
    (c) Arranging and delivering
    assessments
    (e)Marketing and
    Communications
    (f) Special Categories
    (a) To arrange, and maintain,
    the certification or accreditation
    of our courses
    (b) To arrange your
    accreditation if you are a SPTI
    graduate member with the
    United Kingdom Council for
    Psychotherapy
    (a) Identify
    (b) Contact
    (c) Academic
    (d) Financial
    (a) Performance of a contract with
    you
    (b) Necessary for our legitimate
    interests (to have our SPTI graduate
    members and our courses certified or
    accredited by recognised bodies)
    To have our records and
    accounts independently audited
    (a) Identify
    (b) Contact
    (c) Academic
    (d) Financial
    (a) Performance of a contract with
    you
    (b) Necessary for our legitimate
    interests to meet the auditing
    requirements of Student Finance
    England and the course designation
    process (which enables students to
    apply for student loans).
    To conduct a Disclosure and
    Barring Service (DBS) search
    where you apply to do
    counselling work with
    vulnerable adults as part of
    your course
    (a) Identity
    (b) Contact
    (c) Special Category
    Data (information
    relating to your criminal
    convictions)
    (a) Consent for Identity and Contact
    Data, and explicit consent for Special
    Categories Data.
    To manage our relationship
    with you which will include:
    (a) Notifying you about
    changes to our terms or privacy
    notice
    (b) Asking you to leave a
    review or take a survey
    (a) Identity
    (b) Contact
    (c) Enrolment
    (d) Marketing and
    Communications
    (a) Performance of a contract with
    you
    (b) Necessary for our legitimate
    interests (to keep our records
    updated and to study how students
    use our services and facilities)
    To enable you to partake in a
    prize draw, competition or
    complete a survey
    (a) Identity
    (b) Contact
    (c) Technical
    (d) Marketing and
    Communications
    (a) Performance of a contract with
    you
    (b) Necessary for our legitimate
    interests (to study how students use
    our services and facilities to allow us
    to develop them and grow our
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    business)
    To provide:
    (a) Appropriate reasonable
    adjustments to
    accommodate any disability
    you may have
    (b) Pastoral care.
    (a) Identity
    (b) Contact
    (c) Special Categories
    Data (information about
    your physical or mental
    health, or disability
    status)
    (a) Consent for Identity and Contact
    Data, and explicit consent for Special
    Categories Data.
    To monitor equal opportunities
    and diversity
    (a) Special Categories
    Data (race or national or
    ethnic origin, religious,
    philosophical or moral
    beliefs, or your sexual
    life or sexual orientation)
    – however, this
    information will only be
    disclosed to third parties
    as Aggregated Data that
    does not identify you.
    (a) Explicit consent
    To administer and protect our
    business and this website
    (including troubleshooting, data
    analysis, testing, system
    maintenance, support,
    reporting and hosting of data)
    (a) Identity
    (b) Contact
    (c) Technical
    (a) Necessary for our legitimate
    interests (for running our business,
    provision of administration and IT
    services, network security, to prevent
    fraud and in the context of a business
    reorganisation or group restructuring
    exercise)
    (b) Necessary to comply with a legal
    obligation
    To deliver relevant website
    content and advertisements to
    you and measure or
    understand the effectiveness of
    the advertising we serve to you
    (a) Identity
    (b) Contact
    (c) Marketing and
    Communications
    (d) Technical
    Necessary for our legitimate interests
    (to study how students use our
    services, to develop them, to grow
    our business and to inform our
    marketing strategy)
    To use data analytics to
    improve our website,
    products/services, marketing,
    customer relationships and
    (a) Technical Necessary for our legitimate interests
    (to define types of potential students
    and students for our services, to keep
    our website updated and relevant, to
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    experiences develop our business and to inform
    our marketing strategy)
    To make suggestions and
    recommendations to you about
    training opportunities and
    workshops that may be of
    interest to you
    (a) Identity
    (b) Contact
    (c) Academic
    (d) Technical
    (e) Marketing and
    Communications
    (a) Consent
    (b) Necessary for our legitimate
    interests (to develop our services and
    grow our business)
    Marketing
    We strive to provide you with choices regarding certain personal data uses, particularly around
    marketing and advertising.
    Marketing from us
    We may use your Identity, Contact and Marketing and Communications Data to form a view on
    what we think you may want or need, or what may be of interest to you. This is how we decide
    which courses or services may be relevant for you (we call this marketing).
    You will receive marketing communications from us: (a) if you have requested information from us;
    or (b) are enrolled, or have previously enrolled, on a course with us (in which case such marketing
    communications will only be by email and text and be about similar courses to those you have
    already, or previously, enrolled with us); or (c) you have consented; and, in each case, you have
    not opted out of receiving that marketing.
    Third-party marketing
    We will not share your personal data with any third party for marketing purposes.
    Opting-out
    You can ask us or third parties to stop sending you marketing messages at any time by following
    the opt-out links on any marketing message sent to you or by contacting us at any time.
    Cookies
    Where you use our website you can set your browser to refuse all or some browser cookies, or to
    alert you when cookies are set or accessed. If you disable or refuse cookies, please note that
    some parts of this website may become inaccessible or not function properly. For more information
    about the cookies we use, please see Cookie Policy.
    Change of purpose
    We will only use your personal data for the purposes for which we collected it, unless we
    reasonably consider that we need to use it for another reason and that reason is compatible with
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    the original purpose. If you wish to get an explanation as to how the processing for the new
    purpose is compatible with the original purpose, please contact us.
    If we need to use your personal data for an unrelated purpose, we will notify you and we will
    explain the legal basis which allows us to do so.
    Please note that we may process your personal data without your knowledge or consent, in
    compliance with the above rules, where this is required or permitted by law.
  15. Sharing your personal data
    We do not normally share your personal data with any third party, except that we will share your
    personal data with parties set out below for the purposes set out in the table above:
    • ABC Awards – but only if you are studying the Level 2 Award in Counselling Concepts
    course and then only for the purpose of award registration, assessment and certification;
    • Staffordshire University (our degree validation partner) – but only if you are on one of our
    degree programmes and only for the purpose of registration, assessment and award
    certification;
    • The British Association for Counselling and Psychotherapy – but only if you are enrolled on
    our BSc course, and only then for course accreditation purposes;
    • The United Kingdom Council for Psychotherapy – but only if you are enrolled on our postgraduate MSc courses, and only then for course accreditation purposes or if you are a
    graduate member and only then for membership purposes;
    • The Higher Education Statistics Agency and the Office for Students, but only for the
    purpose of meeting our regulatory obligations and ensuring that those enrolled on our
    courses remain eligible to apply for student loans. HESA’s Collection Notices provide
    information for students, staff and graduates on behalf of HESA, HESA Services Ltd and
    the other organisations who are data controllers in common on HESA datasets. The
    Collection Notices are published at www.hesa.ac.uk/about/regulation/data-protection/notices ;
    • The Student Loans Company – but only if you have a student loan from them or a claiming
    a disabled students allowance, and only then for the purpose of managing and supporting
    your student loans process by confirming your attendance on the funded programme and
    meeting other reporting requirements;
    • Local authorities; the police and other bodies with enforcement powers where disclosure is
    necessary for the prevention or detection of crime or by law;
    • The East Midland Shared Services (DBS umbrella organisation) – but only if we need to
    conduct a DBS search where you apply to do counselling work with vulnerable adults and
    only on the basis of your consent;
    • To anybody providing you with a sponsorship or scholarship or other type of funding, but
    only if you have consented to such disclosure; and
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    • To third parties to whom we may choose to sell, transfer, or merge parts of our business or
    our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a
    change happens to our business, then the new owners may use your personal data in the
    same way as set out in this privacy notice.
  16. International transfers
    We do not transfer your personal data outside the European Economic Area.
  17. Data security
    We have put in place appropriate security measures to prevent your personal data from being
    accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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.
  18. Data retention
    We will only retain your personal data for as long as necessary to fulfil the purposes we collected it
    for, including for the purposes of satisfying 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 personal data, the purposes for which we process your personal data and whether we can
    achieve those purposes through other means, and the applicable legal requirements.
    Details of retention periods for different aspects of your personal data are available in our
    Information Management Policy which you can request from us by contacting us.
  19. Your legal rights
    Under certain circumstances, you have rights under data protection laws in relation to your
    personal data.
    • Request access to your personal data
    • Request correction of your personal data
    • Request erasure of your personal data
    • Object to processing of your personal data Request restriction of processing your personal
    data
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    • Request transfer of your personal data
    • Right to withdraw consent
    If you wish to exercise any of the rights set out above, please contact us.
    No fee usually required
    You will not have to pay a fee to access your personal data (or to exercise any of the other rights).
    However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or
    excessive. Alternatively, we may refuse to comply with your request in these circumstances.
    What we may need from you
    We may need to request specific information from you to help us confirm your identity and ensure
    your right to access your personal data (or to exercise any of your other rights). This is a security
    measure to ensure that personal data is not disclosed to any person who has no right to receive it.
    We may also contact you to ask you for further information in relation to your request to speed up
    our response.
    Time limit to respond
    We try to respond to all legitimate requests within one month. Occasionally it may take us longer
    than a month if your request is particularly complex or you have made a number of requests. In this
    case, we will notify you and keep you updated.
  20. Glossary
    Legitimate Interest means the interest of our business in conducting and managing our business
    to enable us to give you the best service and the best and most secure experience. We make sure
    we consider and balance any potential impact on you (both positive and negative) and your rights
    before we process your personal data for our legitimate interests. We do not use your personal
    data for activities where our interests are overridden by the impact on you (unless we have your
    consent or are otherwise required or permitted to by law). You can obtain further information about
    how we assess our legitimate interests against any potential impact on you in respect of specific
    activities by contacting us
    Performance of contract means processing your data where it is necessary for the performance
    of a contract to which you are a party or to take steps at your request before entering into such a
    contract – for example, our contract with you to deliver to you the course you have enrolled on.
    Comply with a legal or regulatory obligation means processing your personal data where it is
    necessary for compliance with a legal or regulatory obligation that we are subject to.
    Consent means processing your personal data where you have given your unambiguous consent
    to our processing of your personal data.
    Your legal rights
    You have the right to:
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    Request access to your personal data (commonly known as a “data subject access request”).
    This enables you to receive a copy of the personal data we hold about you and to check that we
    are lawfully processing it.
    Request correction of the personal data that we hold about you. This enables you to have any
    incomplete or inaccurate data we hold about you corrected, though we may need to verify the
    accuracy of the new data you provide to us.
    Request erasure of your personal data. This enables you to ask us to delete or remove personal
    data where there is no good reason for us continuing to process it. You also have the right to ask
    us to delete or remove your personal data where you have successfully exercised your right to
    object to processing (see below), where we may have processed your information unlawfully or
    where we are required to erase your personal data to comply with local law. Note, however, that
    we may not always be able to comply with your request of erasure for specific legal reasons which
    will be notified to you, if applicable, at the time of your request.
    Object to processing of your personal data where we are relying on a legitimate interest (or those
    of a third party) and there is something about your particular situation which makes you want to
    object to processing on this ground as you feel it impacts on your fundamental rights and
    freedoms. You also have the right to object where we are processing your personal data for direct
    marketing purposes. In some cases, we may demonstrate that we have compelling legitimate
    grounds to process your information which override your rights and freedoms.
    Request restriction of processing of your personal data. This enables you to ask us to suspend
    the processing of your personal data in the following scenarios: (a) if you want us to establish the
    data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c)
    where you need us to hold the data even if we no longer require it as you need it to establish,
    exercise or defend legal claims; or (d) you have objected to our use of your data but we need to
    verify whether we have overriding legitimate grounds to use it.
    Request the transfer of your personal data to you or to a third party. We will provide to you, or a
    third party you have chosen, your personal data in a structured, commonly used, machinereadable format. Note that this right only applies to automated information which you initially
    provided consent for us to use or where we used the information to perform a contract with you.
    Withdraw consent at any time where we are relying on consent to process your personal data.
    However, this will not affect the lawfulness of any processing carried out before you withdraw your
    consent. If you withdraw your consent, we may not be able to provide certain products or services
    to you. We will advise you if this is the case at the time you withdraw your consent.