Data Protection Policy
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 discuss any questions you might have about my data protection policy and you can contact me via telephone, text, or email.
‘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, and I am registered with the Information Commissioner’s Office: [Insert Registration Number].
You can contact me using the details here: Contact Information.
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.
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).
Use of informationInitial 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, telephone number, email and the nature of your counselling requirements. 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 6 months. If you would like me to delete this information sooner, just let me know.
Whilst accessing counselling
Everything you share with me during our work together will be treated with confidentiality. However, there are some limits to confidentiality which you need to be aware of:
In accordance with the ethical framework of the British Association for Counselling and Psychotherapy (BACP), I am required to undertake regular supervision. For this purpose, I may disclose some details of our work to my supervisor.
I may be legally or ethically obliged, to break confidentiality, for example if I consider your wellbeing or that of others to be seriously at risk.
I make brief notes after each session and store the contact details you provided. This information is stored in a locked cabinet and are subject to my GDPR policy which can be found on my website or can be provided if requested.
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 a smartphone that is dedicated to my counselling service so there is no possibility that this will be shared unintentionally. These details are not shared with any third party.
I will keep written notes of each session, these are kept in a locked filing cabinet in the counselling room, with the key kept securely and only accessible by me.
For security reasons I do not retain text messages for more than 6 months. If there is relevant information contained in a text message this will be stored dependant on the type of data:
Contact details: in the address book of my smartphone;
Counselling details: transferred to your written record and deleted from smartphone.
Likewise, any email correspondence will be deleted after 6 months if it is not important. If necessary, I will retain this for up to 2 years, however after 6 months this will be printed and stored in you record.
After counselling has ended
Once counselling has ended your records will be kept for 1 year from the end of our contact with each other and are then securely destroyed. If you want me to delete your information sooner than this, please tell me.
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 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 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 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. I limit the amount of information stored electronically I use encrypted email and messaging services, locked filing cabinet etc.
When someone visits my website, I use a third-party service, wix.com, 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 wix.com 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 also use Wix.com to provide me with analytics so that I can continually improve my service to you, as well as their content management system. You can read their privacy notice here https://www.wix.com/about/privacy.
There are two types of cookies:
Session (transient) cookies: These cookies are erased when you close your browser, and do not collect information from your computer. They typically store information in the form of a session identification that does not personally identify the user.
Persistent (permanent or stored) cookies: These cookies are stored on your hard drive until they expire or until you delete them. These cookies are used to collect identifying information about the user, such as web surfing behaviour or user preferences for a specific site
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.