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 (GDPR EU/2016/679), 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 and you can contact me on email@example.com. I am registered with the Information Commissioner's Office [Registration Number: ZA356536].
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).
In the case that you have subscribed to receive notification of blog postings, your email address will not be shared with any other parties and will not be used to send you any junk mail.
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, telephone number, and email address, postal address, nationality, GP details, emergency contact details, and relevant mental health history. If you decide not to proceed I will ensure all your personal data is deleted within one week. 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 I believe that you are at risk of harm to yourself or to somebody else. 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 in a locked filing cabinet and/or in password-protected documents and are not shared with any third party. I will keep written notes of each session, these are kept in a locked filing cabinet. For security reasons, I do not retain text messages for more than two weeks. If there is relevant information contained in a text message I will add this to your paper notes that are kept in a locked filing cabinet. Likewise, any email correspondence will be deleted after two weeks if it is not important. If necessary I will add any important information to your paper notes which are kept in a locked filing cabinet.
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.
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. I have a supervisor, with whom I discuss aspects of my counselling work, but you [the client] will remain anonymous. In the case that you see me for an appointment in my Balham office, your name and email address will be shared with them as part of the booking system. You may also be asked to fill in further information by them upon arrival to your first appointment.
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 make every effort to make sure it is kept secure. Any paper notes are stored in a locked filing cabinet. Any notes from sessions are stored under a code rather than the client's name and are stored separately from any personal data about the client. Any data that is stored electronically is done so under password-protection.
Visitors to my website
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.