Your privacy is very important to me. 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 Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2003.(‘The Regulations’)
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 will keep it for
- Whether there are, or may be, other recipients of your personal information
- Your data protection rights.
I am happy to chat through any questions you might have about my data protection policy. I can be contacted by emailing me at firstname.lastname@example.org
2. 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 our relationship when at 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 your personal information. This means that I have a legal right to continue to hold your information.
Both during and after therapy has ended the Regulations require me to look after your sensitive personal information appropriately. This type of information is called ‘special category personal information’. This type of information is often disclosed during the provision of health treatment. The lawful basis for me processing any special categories of personal information is for the provision of counselling and psychotherapy and is necessary for the contract between me and you to be fulfilled.
3. How I use your information
When you first contact me with an enquiry about my services I will collect information to help me satisfy your enquiry. This may include your name, address, email address, home and or mobile number and some limited information about the nature of your enquiry. This information may also be supplied by your GP or other health professional, or a friend or relative enquiring on your behalf.
If you don’t engage in therapy with me
If you decide not to meet with me, or decide not to continue with therapy with me after our initial session, I will ensure all your personal data is deleted within 10 working days. If you would like me to delete this information sooner, just let me know.
While you are accessing counselling
Everything that we discuss in your counselling sessions, and the fact that you are attending counselling, is confidential with a few exceptions. By law I will be required to disclose information if you tell me that you are involved in, or have information regarding certain serious criminal offences. I may also need to break confidentiality If I think that there is a risk of you causing yourself or someone else serious harm or if I become concerned that the safety or wellbeing of a child or other vulnerable person might be a risk.It is also normal practice for all counsellors and psychotherapists to have regular supervision during which I may discuss things that we have talked about. In doing so your anonymity would be maintained. My supervisor is bound by the same rules of confidentiality as me.
I will keep a record of your personal details to help the counselling services run smoothly. These details are kept securely on my laptop and mobile phone and are not shared with any third party. Both devices are password protected and security is kept up to date.
I also keep written notes of most sessions, these are kept in a locked filing cabinet. Your personal details are kept separately from your session notes which are anonymised.
Any text or email correspondence will be deleted after 2 weeks. If it contains relevant information this will be transferred to your paper file.
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 then paper records will be shredded and all other recoreds deleted. If you want me to shred and delete your information sooner than this, please tell me.
4. Your rights
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 also have a right to
- know what it is and where I got the information from;
- know why I am holding it, how long I will hold it, and why I decided to do this;
- know who else it could be disclosed to;
- have an understandable copy of the information.
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 by emailing email@example.com
You can read more about your rights at ico.org.uk/your-data-matters.
If you have any complaint about how I handle your personal data please do not hesitate to get in touch with me by emailing to the contact details given above.
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.