Your privacy is a priority
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),
- Data Protection Act 2018
- Privacy and Electronic Communications (EC Directive) Regulations 2003.
- I also adhere to the ethical guidelines regarding protecting client privacy and confidentiality set by the British Association for Counselling and Psychotherapy (BACP).
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.
If you have any questions about this privacy notice, you can contact me in the first instance via email: email@example.com
‘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: Registration Number: C1118745
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 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.
- 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.
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/address/telephone number/email address/brief case notes
If you decide not to proceed, I will ensure all your personal data is deleted within [1 month].
While you are accessing counselling.
The content of our sessions is confidential, however in exceptional circumstances such as a perceived high risk of self-harm or harm to others, disclosure concerning acts of terrorism under the terrorism act, or acts specific to the children’s act, confidentiality will be broken, and such disclosures will be passed onto the relevant authority without delay. Where possible I will discuss the reasons for breaking confidentiality with you and what actions will be taken.
I will keep a record of your personal details to help the counselling services run smoothly.
- Personal details are stored electronically and are password protected and are not shared with any third party.
- I will take written notes during each session, which are anonymised using a unique client code. Written notes are stored in a locked filing cabinet, for the duration of our work together.
- A summary of the counselling session content is held electronically and is password protected.
- All electronic communication (texts, emails etc) are held securely on devices that are password protected for the duration of our work together. If there is relevant and or important information contained in any electronic communications, I will add the relevant details to your client file.
Once counselling has ended.
- All handwritten notes are securely destroyed within 1 month of the final counselling session
- The electronic summary of our sessions will be kept for 6 years from the final counselling session and are then deleted.
- All electronic communications will be deleted within 1 month of the final counselling session
Please note that I need to keep a record of your name, date of birth and your client reference number for six years after your final counselling session to enable me to match you and your summary counselling notes should this be required.
Third party recipients of personal data
I share a limited amount of personal data with third parties in order to provide therapy services to you and to fulfil my professional obligations for example I share information confidentially with my clinical supervisor who also acts as my clinical executor should I become incapacitated and unable to work.
Where I have contracted with a supplier to carry out tasks, they will not use your information in any way other than the task for which they have been contracted. I will never pass on your contact details to any third-party organisations for the purposes of sales, marketing or research.
If your appointments are paid for or arranged via a third party, for example, your employer we will agree levels of information sharing, and this will be agreed by all parties in advance.
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 firstname.lastname@example.org.
If you have any complaint about how I handle your personal data, please do not hesitate to get in touch with me by emailing me on 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.
- Paper records are kept separate from your personal details and are anonymised using a unique client code. These are stored in a locked cabinet.
- Electronic records are password protected
- Electronic devices such as laptop and telephone are password protected
- Email accounts are password protected
- The transmission of information via the internet or email is not completely secure. Although I will do my best to protect your personal information, I cannot guarantee the security of your information transmitted through the site or over email; any transmission is at your own risk.
Visitors to my website
When someone visits my website, I use a third party service, 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 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. I use Google Analytics so that I can continually improve my service to you. You can read their privacy policies by clicking here.
No user-specific data is collected by me or any third party. If you fill in a form on my website, that data will be temporarily stored on the web host before being sent to me.
Got a question about this policy? Contact me