Your privacy is very important to me and you can be confident that your personal information will be kept safe and secure. It will only be used for the purpose for which it was given to me. I adhere to current data protection legislation, including the General Data Protection Regulation (EU/2016/679) (the GDPR) and the Data Protection Act 2018.
This privacy notice tells you what I will do with your personal information from initial point of contact 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
- Your data protection rights
I am happy to chat through any questions you might have about my data protection policy. You can contact me via [email protected].
‘Data controller’ is the term used to describe the person/organisation that collects, stores and has responsibility for people’s personal data. In this instance, I am the data controller.
I am registered with the Information Commissioner’s Office (ICO) and my registration number is ZB277268.
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
Initial contact
When you contact me with an enquiry about my counselling services I will collect information to help me satisfy your enquiry. This will include your name, phone number, address and email address. 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.
If you decide not to proceed, I will ensure all your personal data is deleted within one month. If you would like me to delete this information sooner, just let me know.
While you are accessing counselling
Everything you discuss with me is confidential. That confidentiality will only be breached if I think you, or another person, are at risk of serious harm. In this instance, I may share your personal information with an appropriate authority such as your GP or the emergency services. I will always try and speak to you about this first, unless there are safeguarding issues that prevent this.
However, I have a legal obligation to report matters relating to terrorism, money laundering and drug trafficking, without first informing you.
I will keep a record of your personal details to help the counselling service run smoothly. These details are kept securely in a locked cabinet and are not shared with any third party.
I will keep brief written records of each session; these are kept in a separate locked cabinet and do not contain identifying information but are linked to your name by a client ID number which is recorded on your personal details form.
For security reasons, I do not retain text messages for more than one month. If there is relevant information contained in a text message I will record it on your personal information form or session notes, as appropriate. Likewise, any email correspondence will be deleted after one month if it is not important. If necessary, I will record important information on your personal information form or session notes, as appropriate.
After counselling has ended
Once counselling has ended, your records will be kept for six years from the end of our contact with each other and then securely destroyed. If you want me to delete your information sooner than this, please tell me. I will securely destroy any record of your personal information, other than your name, when counselling has ended.
You do not have to provide this personal information but if you do not consent to me using your data in this way, it is unlikely that I am able to work with you.
Your rights
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 me processing your personal information. You also have the right to ask for a copy of any information that I hold about you, via a subject access request, and to object to the use of your personal data in some circumstances. You can withdraw your consent for the processing of your personal data at any time by emailing me at [email protected]
You can read more about your rights at www.ico-org.uk/your-data-matters
If I do hold information about you I will, if asked:
- give you a description of it and where it came from
- tell you why I am holding it, 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 may 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 complaints about how I handle your personal data, please do not hesitate to get in touch with me by emailing [email protected]
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 www.ico.org.uk/make-a-complaint.
Data security
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.
I use an encrypted email, web form and e-signature service called Hushmail. Any hard copy paper documents are kept in locked filing cabinets.
Third parties
During clinical supervision, I discuss my work with a qualified supervisor to maintain an ethical practice. All client information is pseudonymised during these supervision sessions.
In the event of my incapacitation, an appointed colleague will contact you to advise of this and they will delete your personal data according to GDPR.