Introduction
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 chat through any questions you might have about my data protection policy and you can contact me via e-mail or by completing a contact form on my website. ‘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 person responsible for this is me.
I am registered with the Information Commissioner’s Office [Registration number: Z5329647].
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
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 and contact details and why you may want to contact me. If we agree to proceed, I will also collect additional, personal information such as (but not limited to) your address, your GP details and history of mental health. 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. These initial details will be recorded and kept securely, either:
- on paper and will be kept separate from any notes I may make during our therapy sessions in the future. These are stored in a locked filing cabinet in my home office, the keys of which are stored in a locked safe. My home office is protected with an alarm and is monitored via a security camera. Or,
- in an encrypted way on my mobile phone and/or laptop computer and are not shared with any third party.
If you decide not to proceed I will ensure all your personal data is deleted within 1 calendar month. 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 you disclose something to me that suggests a risk of harm to yourself or someone else, or if I am required to provide it to a third party by law. I will always try to speak to you about this first, unless there are safeguarding issues that prevent this.
I will continue to keep a record of your personal details on paper to help the counselling services run smoothly.
I will make brief, anonymised notes of each session, which are kept securely in an encrypted and password-protected way on my computer. These session notes do not identify you by name and are not linked in any way to the initial contact details I collect when you first contact me.
For security reasons I do not retain text messages for more than 1 calendar month. If there is relevant information contained in a text message, on rare occasions I will copy and paste this to a printable document that I can add to your notes, deleting the original. Likewise, any email correspondence will be deleted after 1 calendar month if it is not important. If necessary I will archive e-mails to a dedicated, password-protected folder that is held securely on an encrypted device.
After counselling has ended
Once counselling has ended your records will be kept for a maximum period of 6 years (according to applicable contract law in the U.K.) from the end of our contact with each other, and are then securely destroyed. This also accommodates the continuity of our work together if you decide to return to therapy. If you want me to delete your information sooner than this, please tell me.
Third party recipients of personal data
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.
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 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 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 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 me and sending it via e-mail.
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 previously. 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.
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 password-protected and encrypted devices, messaging services using end-to-end encryption, encrypted video applications for online work, two-factor authentication or facial-recognition methods for folder access, locked filing cabinet for paper records, home-office security and monitoring systems etc.
Visitors to my website
When someone visits my website, I use a third-party service, GoDaddy, 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 GoDaddy 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.
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.