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.
I am happy to chat through any questions you might have about my data protection policy at any point and you can contact me via email to discuss this.
‘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 ZA813541].
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 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.
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 your name, phone number, email address and address. It may also include a brief description of why you are seeking counselling. 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 a month after all contact has ceased between us. 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 or someone else is at risk of serious harm or I am required to make a disclosure by law. 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 password-protected computer and dedicated phone and are not shared with any third party. All email and text communications are also only accessed on these secure devices.
I will keep written notes of each session, these are kept electronically on a password protected device.
After counselling has ended:
Once counselling has ended your records will be kept for ten 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 discuss this with me.
Third party recipients of personal data
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. You can read more about your rights at ico.org.uk/your-data-matters.
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. Any paper documents I hold, I keep in a locked filing cabinet. My computer and phone are password protected. I only use an encrypted email provider Protonmail for my counselling communications and encourage my clients to use this too.
Visitors to my website
When someone visits my website, I use a third party service, provided through the web hosting service Wix, 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 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 Wix as the content management system for our website - find out about Wix and data protection 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.