Privacy Policy
How we collect, hold and use the personal information you give us through this website, our CPD courses and the practitioner screening tool.
1. Who we are and what this notice covers
ReNurture Ltd is committed to protecting the privacy and security of your personal information. ReNurture Ltd is a company registered in England and Wales (company number 17057216) and located in Devon, United Kingdom. Clear from Control is the CPD brand of ReNurture Ltd. Clear from Control and ReNurture are trade marks of ReNurture Ltd (trade mark pending).
ReNurture Ltd is the "data controller" for the personal information described in this notice. This means that we are responsible for deciding how we hold and use it, in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. Our registration with the Information Commissioner's Office is ZC134099 (registered as ReNurture Ltd).
This notice applies to people who visit the Clear from Control website (clearfromcontrol.com), who send us an enquiry, reserve a seat or register interest through its forms, who attend one of our CPD courses, and who use the practitioner screening tool. It does not form part of any contract to provide services. We may update it at any time; the date at the top shows when it was last changed.
It is important that you read this notice, together with any other privacy notice we may provide on specific occasions, so that you are aware of how and why we are using your information.
2. Data protection principles
We will comply with data protection law. This says that the personal information we hold about you must be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely.
3. The information we collect and why
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data which has been anonymised to the extent that the individual can no longer be identified.
3.1 Enquiry, seat-reservation and register-interest forms
When you use a form on this website, whether to send an enquiry, to hold a seat on a course, to register your interest in a course, or to ask about an organisation or team booking, we collect the details you type in. Depending on the form these are your email address, your professional role, and, where asked, your name, your organisation, the course or booking type you are interested in, your stabilisation-training status, and any message you write.
We use this information to reply to you, to hold your seat, to tell you when course dates and early-bird pricing open, and to arrange organisation bookings. The lawful basis is that the processing is necessary to take steps at your request before entering into a contract with you, and, for enquiries and register-interest requests, our legitimate interest in responding to people who have asked to hear from us about our courses. Where you have registered interest, you can ask us to stop emailing you at any time, using the link in any email or by writing to us.
Form submissions are not stored on the website server. Each submission is sent as an email to support@renurture.org through our email delivery provider, Resend, and is then held in our mailbox. When you register your interest in a course, your email address and, if you give it, your first name are also added to our mailing list, held by our email marketing provider, Kit, and tagged with the course you asked about, so that we can tell you when dates and booking open. Each form also contains a hidden field that genuine visitors never see; if it is filled in, which only happens with automated spam, the submission is silently discarded and nothing is sent.
3.1A Booking and payment
When you book a seat, you pay through a secure checkout page run by our payment provider, Stripe. Stripe collects your name, email address and card details, and the professional body and registration number you enter at checkout. Your card details go directly to Stripe and never reach us or this website. Stripe sends us a confirmation of the booking with your name, email address, professional details and the amount paid, which we use to confirm your place, check that you meet the entry requirements, and send joining details. The lawful basis is the performance of our contract with you.
3.2 The practitioner screening tool and practitioner accounts
Practitioner screening tool (PSCC-27). When a practitioner uses the screening tool with a client and ticks the optional calibration box, the tool sends the multiple-choice responses and derived scores only to ReNurture's secure record store, held in ReNurture's secure systems (Cloudflare D1, under ReNurture's data protection impact assessment). It is passed through this website's Cloudflare Worker to ReNurture's secure systems; nothing is kept by the website itself. No names, contact details, free text or IP addresses are written to that record; a server timestamp and the tool version are added. We use this data solely to calibrate and improve the tool, and we do not attempt to identify anyone from it. Practitioners remain responsible for their own client records and for explaining this to their client. The anonymised record is sent only when the client agreed at onboarding; nothing is sent unless the box is ticked.
Practitioner accounts. Access to the PSCC-27 is given to practitioners who have completed our full-day workshop and whose application we have approved (see 3.2A). For each practitioner, ReNurture holds, in ReNurture's secure systems (Supabase, under ReNurture's data protection impact assessment), the email address, name and course details the practitioner gave us, the date access was granted, and the date of their most recent sign-in. These details are passed through this website's Cloudflare Worker to ReNurture's secure systems; nothing is kept by the website itself. Sign-in uses a one-time code emailed to that address; codes are held by ReNurture, stored only in hashed form, and expire after ten minutes. A session cookie, scoped to the /members area of this website, keeps the practitioner signed in on their device for up to 30 days. We do not store IP addresses with these records. Feedback a practitioner submits about the tool is stored linked to their account, so that we can follow up with them about it. Practitioners can ask us to remove their access record at any time.
The lawful basis for the practitioner account record is the performance of our contract with the practitioner (providing access to the PSCC-27). The lawful basis for the calibration data is our legitimate interest in checking and improving the reliability of the screening tool; because that data contains nothing that identifies the client, it is not personal data about the client in our hands.
3.2A Applications for practitioner access
When a practitioner applies for access to the PSCC-27 using the application form, we collect the details they type in: full name, email address, optional phone number, profession, professional body, registration or membership number, optional link to their public register entry, where they practise, the date they attended the full-day workshop, an optional note on how they would use the PSCC-27, and their three declarations. We use these details to check the applicant's attendance and their registration against the public register and to manage access to the PSCC-27. The application is sent to us as an email to support@renurture.org through Resend, in the same way as the other forms described above, and is not stored on the website server. If access is granted, the practitioner account record described above is created. The lawful basis is that the processing is necessary to take steps at the applicant's request before giving them access. If an application is not approved, we delete it within 12 months of our decision.
3.3 Course delivery
When you attend a course, we use the name and email address you gave us to send joining details, to confirm your attendance, to give you access to session recordings for the 6 months they are available, and to issue your CPD certificate on completion. Live sessions are delivered remotely over a video platform, which will process your name and connection details under its own privacy policy for the duration of the session. Session recordings capture what is said and shown in the session; if you would rather not appear on a recording, you can keep your camera off and use the chat sparingly. We keep a record of who attended and who received a certificate so that we can re-issue a certificate on request. The lawful basis is the performance of our contract with you. Where your organisation booked your seat, we may confirm your attendance and certificate to the person who made the booking, and nothing else.
3.4 Correspondence
If you email us, we keep the correspondence for as long as we need it to deal with your query and to keep a record of what was agreed. The lawful basis is our legitimate interest in running our business and responding to the people who contact us.
4. What we do not collect
- We do not use any analytics or tracking service on this website, and we do not set third-party or advertising cookies.
- We do not collect IP addresses with form submissions, practitioner records or screening-tool data.
- We do not collect anything for advertising, profiling, or sale to third parties, and we never sell your data. Nothing is shared beyond the providers listed in section 6.
- The screening tool does not collect names, contact details or free text about clients.
5. Cookies
This website sets two cookies, both only within the /members area: the practitioner session cookie described in section 3.2, and a short-lived security token that protects the sign-in and sign-out forms from forgery. The session cookie keeps a signed-in practitioner signed in on their device for up to 30 days; the security token lasts only until the browser is closed. Both are strictly necessary for the sign-in to work and are not set on any other page. Neither tracks you across other sites. No other cookies are set by this website. You can delete them at any time through your browser settings, which will sign you out. When you close the cookie notice, your browser remembers that in its local storage on your device so the notice does not appear again; this is not a cookie and is not sent to us.
6. Who we share your information with
We do not sell or rent your information, and we share it only with the providers we need in order to run the website and our courses:
- Resend, our email delivery provider, which carries form submissions and the practitioner one-time sign-in codes to and from us.
- Cloudflare, which hosts and delivers this website and stores anonymous screening records on ReNurture's behalf.
- Supabase, which stores practitioner accounts, sign-in codes and practitioner feedback on ReNurture's behalf.
- The video platform used to deliver live sessions and host recordings, for the duration of a course.
- Our email and office software providers, in which our mailbox and course records are held.
- Stripe, our payment provider, which takes course bookings and payments. Your card details go directly to Stripe and never reach our servers.
- Kit, our email marketing provider, which holds the mailing list for people who have registered interest in a course.
We may also disclose information where the law requires it, or where it is necessary to protect someone's safety. Beyond the providers listed above, we do not share personal information with any third party.
7. International transfers
We are based in the UK and aim to keep your information in the UK or the European Economic Area wherever we can. Our email delivery provider may process form submissions and sign-in codes outside the UK, and Cloudflare, Supabase, Stripe and Kit may also process information outside the UK. Where information leaves the UK we will rely on a safeguard recognised under UK data protection law so that your information receives an equivalent level of protection. [CONTENT NEEDED: confirm the processing location and transfer safeguard relied on for Resend, Cloudflare, Supabase, Stripe and Kit (IDTA / UK Addendum)]
8. How long we keep your information
- Enquiries and register-interest requests. We keep these until you ask us to stop contacting you, or for 24 months after our last contact with you, whichever is sooner.
- Bookings that do not go ahead. Where a booking is cancelled or refunded, we delete the booking details within 12 months of the cohort it related to, apart from the payment and refund records we must keep for tax purposes (see below).
- Booking and attendance records, including certificates issued. We keep these for six years after the course, so that we can re-issue a certificate and meet our record-keeping obligations. Invoices and payment records are kept for six years as required by UK tax law.
- Practitioner account records. We keep these until access is removed, and delete them when the practitioner asks or when ReNurture removes them.
- Screening-tool calibration data and practitioner feedback. Anonymous screening records contain nothing that identifies anyone. These records and practitioner feedback are kept for three years and then deleted.
- Sign-in codes. These expire after ten minutes and are deleted within 24 hours.
- Session recordings. Available to participants for 6 months after each session. We delete the master copy 12 months after the course ends.
9. Your rights
Under UK data protection law you have the right to:
- Access the personal information we hold about you, and receive a copy of it.
- Correct information that is inaccurate or incomplete.
- Erase your information where there is no good reason for us to continue holding it.
- Restrict how we use your information while a query about it is resolved.
- Object to processing that is based on our legitimate interests, including direct marketing, which we will stop on request.
- Data portability: receive information you gave us in a structured, commonly used format where we process it by automated means under a contract or consent.
- Withdraw consent at any time where we rely on consent.
To exercise any of these rights, email support@renurture.org. We will respond within one month and will not charge a fee unless a request is clearly unfounded or excessive. We may ask you to confirm your identity before acting on a request. We do not make decisions about you using automated decision-making or profiling.
10. Security
We have put in place appropriate measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way. Form submissions and sign-in codes travel over encrypted connections, one-time codes are stored only in hashed form, and access to our mailbox and records is limited to the people who need it. If we become aware of a breach that is likely to put your rights at risk, we will tell you and the regulator as the law requires.
11. Children
This website and our courses are for practitioners and the organisations that employ them. They are not directed at anyone under 18, and we do not knowingly collect information from children.
12. Complaints
If you have a concern about how we have handled your information, please contact us first at support@renurture.org so that we can try to put it right. You also have the right to complain to the Information Commissioner's Office, the UK supervisory authority for data protection, at ico.org.uk or on 0303 123 1113.
13. Changes to this notice
We may update this notice from time to time, for example to reflect changes in the law or in how the website or our courses work. The latest version will always be on this page, with the date it was last updated shown at the top. If a change significantly affects how we use information we already hold about you, we will tell you by email.
14. Contact
Questions about this notice, or about your information, should be sent to ReNurture Ltd at support@renurture.org.