Privacy Notice
Privacy notice
In order to work ethically I need to hold your personal contact details and records of your therapy sessions. This privacy notice tells you what I will do with your personal information from initial point of contact through to after therapy has ended.
Your privacy is very important to me. Your personal information will be kept securely 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 also adhere to the British Association for Counselling and Psychotherapy (BACP) ethical guidelines regarding protecting client privacy and confidentiality.
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. 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.
I look after disclosed sensitive personal information (‘special category personal information’) appropriately. The lawful basis for me processing any special categories of personal information is that it is for provision of health treatment (in this case therapy sessions) and necessary for a contract with a health professional (in this case, a contract between me and you).
How I use your information
I will never use your personal data for any purposes other than the administration of the therapy service that I am providing to you (to arrange, cancel and re-arrange appointments). I will only retain your personal information for as long as is necessary. This is in line with guidance from the Information Commissioner’s Office.
Initial contact
When you contact me to book your first session I will collect some brief information to help me process your enquiry. This will include your name and a contact method (phone number and email). This information is requested so that you can be informed if I am unable to attend an appointment due to unforeseen circumstances.
Alternatively, an organisation such as your employer may send me your details when making a referral or a third party may give me your details when making an enquiry on your behalf. If an enquiry is made and you decide not to proceed I will ensure that all of your personal data is deleted within one month. If you would like me to delete this information sooner please let me know.
While you are accessing therapy
Your email address or phone number may be used to provide you with written confirmation of your appointment times if you have given consent for this. Your email address and telephone number will only be used to contact you regarding appointment times, unless we have agreed that I will also use your email address to email you information that is relevant to your therapy sessions.
Before your first session, I will send you the contract and ask you to provide details including - your name, address, date of birth, contact details, medical information and in case of an emergency, your GP name, address and phone number. This form is stored securely and password protected on a hard drive. To fulfil my duty of care towards you while also maintaining your confidentiality I will only contact your GP if it is necessary and should these circumstances arise, I would discuss this with you wherever possible before contacting your GP.
What is discussed in our sessions will be kept confidential. I am a Registered Member of the British Association of Counselling and Psychotherapy (MBACP), and I abide by their professional code of ethics. Confidentiality will only be broken if there are legal or ethical obligations, for example, if you disclose abuse/neglect of a child or vulnerable adult, or say something else that implies serious harm to yourself or others, or if a court of law requires me to disclose information. In the event that confidentiality must be broken I will always try to speak to you about this first, unless there are safeguarding issues that prevent this.
All BACP counsellors are required to have regular supervision support so I may discuss our work with my supervisor. This is done without identifying you and my supervisor is also a counsellor who abides by the BACP’s code of ethics regarding confidentiality.
I keep brief notes of our therapy sessions for the purpose of assisting our work together. The notes help me to keep track of the issues that we are working on and they are for my use only. The notes do not include any personal details that could be used to identify you and they are stored securely in a locked filing cabinet that only I have access to. Your therapy notes are stored separately to your personal details form.
After therapy has ended
There are reasons why counsellors are required to keep records after therapy has ended, for example, I can continue to offer you an efficient service if you make contact after therapy has ended. Your therapy notes do not include any personal details that could be used to identify you and continue to be stored securely in a locked filing cabinet that only I have access to for seven years after therapy has ended. This time frame adheres with current industry guidelines. Seven years after your therapy has ended your therapy notes will be confidentially destroyed.
Your personal details form is confidentially destroyed on ending your therapy sessions. Please note that I need to keep a record of your name, date of birth and your client reference number for seven years after therapy ends. Your client reference number corresponds with a client reference number on your therapy notes and therefore enables me to identify your therapy notes if necessary.
Third party recipients of personal data
I will never pass on your contact details to any third party organisations for the purposes of sales, marketing or research. If your appointments are paid for or arranged via a third party, for example, your employer, the only information shared with the third party is your dates of attendance and non-attendance for invoicing and payment purposes. Details about what is discussed in your appointments will remain confidential and can only be shared if you give me your written consent to do so.
Data security
I take the security of the data that I hold about you very seriously. My computer and mobile phone are used to respond to your emails are all password protected. Additionally, the records on the computer are encrypted.
Website visitors
By accessing my website, you are consenting to the information collection and use practices described in this privacy notice. Should you choose to contact me using the contact form on the website, none of the data that you supply will be stored by the website or passed to any third party data processors. This website does not use cookies. It is hosted by IONOS.
Your rights
Under GDPR, 2018 guidelines you have the following rights: The right to request access to the personal information that I store and process about you. You can ask for corrections to be made to the information held or for your personal information to be deleted. You can also ask me to restrict the processing of your personal information or to object to the processing of it altogether in some circumstances. You can read more about your rights at www.ico.org.uk/your-data-matters. Please be aware that in certain situations counsellors may be unable to comply with the above requests. For example, if compelled to retain records by a court of law. Please also be aware that there may be a charge for complying with a request if it is deemed to be excessive in nature.
Queries
‘Data controller’ is the term used to describe the person or organisation that collects and stores and has responsibility for people’s personal data. In this instance, the data controller is Janet Reed and I am registered with the Information Commissioner’s Office: the registration number for is ZB861949.
Complaints
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.
Changes to privacy notice
This privacy notice may be updated from time to time, so please check occasionally for any updates.