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 for which it was given to me. I adhere to current data protection legislation, including the retained EU law version of 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 (as amended).
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:
• My purpose and lawful basis for holding and using your personal information.
• How I use your information, when I may share it and how long I keep it.
• Your data protection rights.
I am happy to talk through any questions you might have about my data protection policy and you can contact me via firstname.lastname@example.org.
‘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, I am the data controller.
My registration reference with the Information Commissioner’s Office is ZB610979.
My purpose and lawful basis for holding and using your personal information.
The GDPR states that I must have a purpose for and a lawful basis for processing your personal data.
My purpose is to process your personal data for the performance of our counselling contract and to retain it afterwards for 6 years for insurance and legal purposes.
Explained below are the different lawful basis depending on the stage at which I am processing your data:
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 personal information in case further counselling is required, and for insurance and legal purposes.
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 in 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 I may share it and how long I keep it.
Initial contact will be a free phone call. If you decide to proceed, I will take the following details to help me satisfy your enquiry:
• Phone number
• Email address
During our first session together, I will collect further information to help the counselling services run smoothly. This will include:
• GP name and address
• Current medication
• Details of other relevant services you may have a relationship with for example Social Services or Community Mental Health Team
If you decide not to proceed, I will ensure all your personal data is deleted within 10 days. If you would like me to delete this information sooner, just let me know.
Please rest assured that while you are accessing counselling everything you discuss with me is confidential. That confidentiality will only be broken if I believe that you are at risk of serious harm to yourself or someone else may be at risk of serious harm, in which case I may share your information with the appropriate authorities. I will always try to speak to you about this first, unless there are safeguarding or legal issues that prevent this. Save for this, I will not share your personal information with any third parties and will not transfer it to any third countries or international organisations.
I will only keep paper records which I store in a locked filing cabinet separate from my counselling room. I will not share these with any third party.
I keep written notes of each session which will not contain any identifying information such as your name or the full names of anybody you might speak about. These notes are kept in a separate locked filing cabinet to your personal details and off site from the counselling room.
For security reasons I do not retain text messages for more than 10 days. Contact details will not be stored on my phone. Any email correspondence that is not important will be deleted after 10 days. If necessary, I will keep any important emails in a separate electronic email folder where access to my email is password protected.
After counselling has ended
Once counselling has ended your records will be kept for up to 6 years from the end of our contract with each other and are then securely destroyed. If you want me to delete your information sooner than this, please tell me and I will do what I can to comply. I do have to keep some information to comply with my insurance policy.
Your data protection 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 www.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, 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 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 email@example.com.
If you have any complaint about how I handle your personal data, please do not hesitate to get in touch with me by email. 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 www.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.