The Terms & Conditions were last updated on 08/12/2021
This privacy notice tells you what I will do with your personal information from the initial point of contact through to after your therapy has ended, including:
- Why I am able to process your information and what purpose
- What 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.
Confidentiality and your privacy are 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 work in accordance with the British Association of Counselling and Psychotherapy (BACP) Ethical Framework for Good Practice in Counselling & Psychotherapy. This includes my adhering 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.
I am happy to chat through any questions you might have about my policies and can you please contact me in writing via my contact form.
2. Data controller
The term “data controller” is 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.
- My postal address is: 63 Twineham Road, Swindon, Wiltshire. SN25 2AG
- My phone number is: 07536 989448
- My email address is: firstname.lastname@example.org
3. 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 counselling 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 counselling 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 the 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).
4. 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:
- Your name
- Your email address
- Your telephone number
- Your date of birth
- Your GP name and surgery (optional)
Alternatively, your GP or other health professionals 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 3 months. 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 if in my opinion:
- you or others are/seem to be in danger or at serious risk of being harmed
- you infer involvement in or knowledge of acts of terrorism; money laundering; drug trafficking or harm/neglect to children and/or vulnerable adults
- I am required to do so by appropriate legal authorities
I will always try to speak to you about this first unless there are legal or safeguarding issues that prevent this. However, I retain the right to break confidentiality without prior consultation with you should I consider that the urgency of the situation requires me to act immediately to safeguard the physical safety of yourself or others.
I will keep a record of your personal details to help the counselling services run smoothly. These details are kept securely in my online IT systems (detailed below) and are not used by any third party.
I will keep written notes of each session, these are kept locked in a filing cabinet in my home office.
Some aspects of our sessions will be taken to a third-party supervisor used to monitor my practice. My supervisor is contracted by me but will not receive any personally identifiable. My supervisors will also follow BACP guidelines and will abide by the same standards for confidentiality and data protection.
For security reasons, I do not retain text messages for more than 1 month. If there is relevant information contained in a text message I will transfer it to my online IT systems or written notes as necessary. Likewise, any email correspondence will be deleted after 1 month if it is not important.
After counselling has ended.
Once counselling has ended your records will be kept for 6 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.
5. Third party recipients of personal data
I sometimes share personal data with contracted 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 sometimes share personal data with your GP if I have serious concerns about the risk to you (client) or others and ask you for that personal data and permission for me to contact your GP.
6. 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 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 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 on my Contact me form.
If you have any complaints about how I handle your personal data please do not hesitate to get in touch with me by writing or emailing 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.
7. Data security
I take the security of the data I hold about you very seriously and as such, I make every effort to make sure it is kept secure. I use secure online IT services, encrypt my computer and phone and only store anonymous written notes in a locked filing cabinet.
8. Visitors to my website and online booking service
When someone visits my website, I use a third-party service, Google 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 to make, any attempt to find out the identities of those visiting my website.
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.
When someone visits my online booking service to make a booking, you will be asked to provide some basic personal details (specified earlier in this policy). Users can also create an online account to allow self-maintenance of personal details and to make booking changes easier.
I use legitimate interests as my lawful basis for holding and using your personal information in this way when you visit my website and online booking services.
- I use Google so that I can continually improve my service to you.
- I use WordPress as the content management system for our website.
- I use Square as my online customer directory; appointment booking; contract signature and payment service.