PRIVACY NOTICE
Introduction
Your privacy is very important to me. Your personal information will be kept safe and secure, and will only be used for the purpose it was given to me. I am guided by the requirements of current data protection legislation.
The following Privacy Notice sets out in more detail when and why I collect your personal information, how I use it, the very rare conditions under which I might be required to share it with others, and how I make sure it is secure.
I would never rent out or trade email lists or personal details with other companies and businesses for any reason.
I am happy to chat through any questions you might have about my data protection policy, and you can contact me by telephone on 07984 290514.
‘Data controller’ is the term used to describe the person that collects, stores and has responsibility for people’s personal data. In my therapy practice, I am the data controller.
I am registered with the Information Commissioner’s Office.
Visitors to my website
When someone visits my website, I use a third party service (Webhealer, PhD Interactive) to collect standard internet log information and details of visitor behaviour patterns, legitimate interest being the relevant lawful basis for that.
No user-specific data is collected by me or any third party. If you fill in an email contact form on my website, it will be sent directly to me by email from the web host (Webhealer, PhD Interactive) and then deleted from Webhealer’s systems. Email contact forms are only temporarily retained by Webhealer until they are confident they have been successfully delivered to me.
My lawful basis for holding and using your personal information
The GDPR (‘General Data Protection Regulation’) states that I must have a lawful basis for holding and using your personal data. Different lawful bases will be relevant at different times:
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 hold and use your personal data, where necessary, for 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 holding and using any special categories of personal information is that it is for provision of health treatment (in this case counselling and / or psychotherapy) 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 deal with your enquiry. Alternatively, your GP or other health professional may send me your details when making a referral, or a 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 three months. If you would like me to delete this information sooner, please just let me know.
How I use your information: While you are accessing therapy
Please be assured that everything you discuss with me is confidential. There are rare circumstances, however, in which your needs, or public interest, might outweigh that general duty of confidentiality. Such circumstances include the prevention of serious harm to you or to others, and the prevention and detection of serious crime. Just like any member of the public, I also have a statutory duty to disclose in certain instances, including under the Terrorism Act 2000, Drug Trafficking Act 1994, Proceeds of Crime Act 2002, and the Money Laundering Regulations 2007; and I could also become subject to a court order to disclose documents or information. Alternatively, disclosure might also be required in order to protect or safeguard a child or vulnerable adult. In such rare circumstances, I will always try to speak to you and obtain your consent, if possible, before sharing information, unless there are safeguarding issues or statutory requirements that prevent this.
As a registered member of the British Association for Counselling & Psychotherapy (‘BACP’), and in accordance with the BACP Ethical Framework, 2018, I attend regular individual confidential supervision sessions where client matters may be discussed. This is always for the benefit of clients. Information which might identify a client will not be shared with my supervisor. Client confidentiality is further protected under a contract of confidentiality made between me and my supervisor.
I will keep a record of your personal details to help me to provide you with a smooth therapy service. These details, including your email address and telephone number, are kept securely on a password protected devices.
I do not retain text messages or emails for more than three months. If there is relevant information contained in a text message or email I will store it securely with the case notes, as detailed below. Likewise, any email correspondence will be deleted after three months if it is not important. If necessary I will securely store any important information with the case notes, as detailed below.
I will keep written notes of each session. Case notes are stored under a reference number only, separate from other documents that might identify you, and in a locked cabinet. They will be confidentially destroyed six years after the end of the therapy relationship.
Notes from the assessment session are kept in a separate locked cabinet to the case notes. They include contact details: usually name, address, email, telephone number and GP details. They may also include information on family and support structures, medications prescribed and non-prescribed, eating and sleeping patterns, brief mental health history of self and immediate family and goals for therapy. These will be securely destroyed six years after the end of the therapy relationship. If you return as a client within six years, the date for confidential destruction of historical notes will be re-set to six years from the date of the end of the most recent episode of therapy.
How I use your information: After therapy has ended
Once counselling has ended your records will be kept for six years 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.
