Your privacy is very important to me and you can be confident that your personal information will be kept safe and secure and will only be used for the purpose it was given to me. I adhere to current data protection legislation, including the General Data Protection Regulation (EU/2016/679) (the GDPR), the Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
This privacy notice tells you what I will do with your personal information from initial point of contact through to after your therapy has ended, including:
- Why I am able to process your information and what purpose I am processing it for
- Whether you have to provide it to me
- How long I store it for
- Whether there are other recipients of your personal information
- Whether I intend to transfer it to another country,
- Whether I do automated decision-making or profiling, and
- Your data protection rights.
I am happy to chat through any questions you might have about my data protection policy and you can contact me via email at [email protected]
‘Data controller’ is the term used to describe the person/organisation that collects and stores and has responsibility for people’s personal data.
In this instance, the data controller is me. I am registered with the Information Commissioner’s Office (ZA509637). My phone number is: 07866226248. My email address is: [email protected]
My lawful basis for holding and using your personal information
The GDPR states that I must have a lawful basis for processing your personal data. There are different lawful bases depending on the stage at which I am processing your data. I have explained these below:
If you have had therapy with me and it has now ended, I will use legitimate interest as my lawful basis for holding and using your personal information.
If you are currently having therapy or if you are in contact with me to consider therapy, I will process your personal data where it is necessary for the performance of our contract.
The GDPR also makes sure that I look after any sensitive personal information that you may disclose to me appropriately. This type of information is called ‘special category personal information’. The lawful basis for me processing any special categories of personal information is that it is for provision of health treatment (in this case counselling) and necessary for a contract with a health professional (in this case, a contract between me and you).
How I use your information
When you contact me with an enquiry about my counselling services, I will collect information to help me satisfy your enquiry. This will include name, telephone number, email address, and a brief description of the issues you wish to bring to counselling and any disclosures made during the phone call or email. Alternatively, your GP or other health professional may send me your details when making a referral or a parent or trusted individual may give me your details when making an enquiry on your behalf.
Before our initial assessment session, you will fill in a Client Information Form online.
If you decide not to proceed, I will ensure all your personal data is deleted within 30 calendar days. If you would like me to delete this information sooner, just let me know.
While you are accessing counselling
Rest assured that everything you discuss with me is confidential. That confidentiality will only be broken in the case of disclosures involving terrorism; drug trafficking; money laundering; prevention of a serious crime; prevention of serious harm to yourself or others (adult and child safeguarding would be considered, as appropriate). I will always try to speak to you about this first, unless there are safeguarding issues that prevent this. I will keep a record of your personal details to help the counselling services run smoothly. These details are kept securely on Dropbox Inc. that is only accessed on secured devices (explained further below) and are not shared with any third party.
I will keep written notes of each session, these are kept on Dropbox Inc. in pseudo-anonymised folders using a unique code, with your identifying information (name, date of birth, address, telephone number, emergency contact, GP details, social worker’s details if applicable, any current medications, medical conditions) kept in a separate folder. Any notes that are taken by hand are digitised, and the paper copy is securely destroyed. Your telephone number is stored in my password-protected and biometrically-secured mobile phone under your first name and the first letter of your surname only.
For security reasons I do not retain text messages for more than 30 calendar days. If there is relevant information contained in a text message, I will record this within your weekly session notes. Likewise, any email correspondence will be deleted after 30 calendar days if it is not important. If necessary, I will record any disclosures that are relevant to our work together within your weekly session notes.
After counselling has ended
Once counselling has ended your records will be kept for 3 years from the end of our contact with each other – in line with BACP’s complaints policy – and are then securely destroyed. Your telephone number will be deleted from my mobile phone when counselling ends. If you want me to delete your information sooner, please tell me.
Third party recipients of personal data
I sometimes share personal data with third parties, for example, where I have contracted with a supplier to carry out specific tasks. In such cases I have carefully selected which partners I work with. I take great care to ensure that I have a contract with the third party that states what they are allowed to do with the data I share with them. I ensure that they do not use your information in any way other than the task for which they have been contracted. I use Dropbox Inc. to store digitised versions of contact information, identifying information, weekly session notes, screening forms and questionnaires, and any signed documentation. Dropbox Inc. is a cloud-based file-hosting service and is GDPR-compliant.
I try to be as open as I can be in terms of giving people access to their personal information. You have a right to ask me to delete your personal information, to limit how I use your personal information, or to stop processing your personal information. You also have a right to ask for a copy of any information that I hold about you and to object to the use of your personal data in some circumstances. You can read more about your rights at ico.org.uk/your-data-matters.
If I do hold information about you I will:
• give you a description of it and where it came from;
• tell you why I am holding its, tell you how long I will store your data and how I made this decision;
• tell you who it could be disclosed to;
• let you have a copy of the information in an intelligible form.
You can also ask me at any time to correct any mistakes there may be in the personal information I hold about you.
To make a request for any personal information I may hold about you, please put the request in writing addressing it to [email protected]
If you have any complaint about how I handle your personal data, please do not hesitate to get in touch with me by writing or emailing to the contact details given above. I would welcome any suggestions for improving my data protection procedures.
If you want to make a formal complaint about the way I have processed your personal information you can contact the ICO which is the statutory body that oversees data protection law in the UK. For more information go to ico.org.uk/make-a-complaint.
I take the security of the data I hold about you very seriously and as such I take every effort to make sure it is kept secure. Access top Dropbox Inc. is only though password-protected or biometrically-secured personal devices (Macbook, iPad, iPhone).
Visitors to my website
When someone visits my website, I use third-party services – WordPress.com Jetpack plugin, and Google Analytics – to collect standard internet log information and details of visitor behaviour patterns. I do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way that does not identify anyone. I do not make, and do not allow WordPress.com Jetpack plugin or Google Analytics to make, any attempt to find out the identities of those visiting my website.
I use legitimate interests as my lawful basis for holding and using your personal information in this way when you visit my website.
No user-specific data is collected by me or any third party. If you fill in a form on my website (such as ‘Get in Touch’ or ‘Client Information Form’), that data will not be logged by the web host but be sent to me via email (which will be stored or deleted as explained above).