Privacy Policy
I am committed to protecting your privacy - 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. 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.
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. These are:
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 (our counselling contract).
The personal information I hold
The information I hold will vary depending on the stage you are at with accessing counselling.
Initial contact
When you contact me with an enquiry about my counselling services the information I hold will usually be your email address, phone number if provided and the information contained in your initial message. If you decide not to proceed I will ensure all your personal data is deleted within four weeks. If you would like me to delete this information sooner, just let me know.
While you are accessing counselling
Session content
Rest assured that everything you discuss with me is confidential. There are just a few limitations to this:
I believe that you, or vulnerable others, are at serious risk of harm. I will always try to speak to you about this first, unless there are safeguarding issues that prevent this. Please also know you can check with me if you are unsure how this would work.
If you infer knowledge of, or involvement in: a safeguarding risk to children or vulnerable adults; an act of terrorism; money laundering; drug trafficking
For the benefit of our therapeutic work together, I may discuss our sessions with my supervisor who also adheres to confidentiality terms.
I keep very brief notes on what was covered in sessions to aid our work together. These are kept in a locked cabinet, with initial only and separate to your contact information.
These notes are not shared with anyone other than anonymously within supervision. Under rare circumstances, notes can be subpoenaed in a court of law. Because of this, I keep my notes to a minimum. I will keep your notes for the period to which I am obliged which can be up to 7 years, after which they will be destroyed.
Personal information
I will keep a record of your personal details to help the counselling services run smoothly. These details are kept securely and are not shared with any third party. The details I ask for prior to the first session are:
Name, address and date of birth. Having these details mean that if, during an online session, there was an emergency impacting your safety (medical or otherwise) I have the needed details to access help for you. If I ever need to write to your GP (if I am concerned for you and your are unable to yourself, or to support a referral for a specialist assessment) I would also need this information.
GP name and address. For the reasons listed above.
Phone number. Having your phone number gives us a back-up option for if a session via Zoom is not possible or not working for technical reasons. I will also notify you of cancellations via text. For these reasons I will need to store your number in my phone (with initials only) for speed of access. This phone is password protected and only used by myself.
Pronouns. These help me understand how you identify and how to refer to you, but there is no pressure to provide them.
Emergency contact - name, relationship, phone number and if they know you're having therapy: These are asked for so I have someone to contact if there was to be an emergency during the session, or if I’m concerned about your imminent safety. We will discuss this in first consultation.
Medications It can be helpful for me to be aware of any medications you are on and how these may impact you and your mental state so I can best support your wellbeing. However you do not have to provide this information.
My clinical supervisor will have your first name and phone number, in the rare instance of if a session cannot go ahead and I am unable to contact you myself (such as through severe illness, injury or death).
Correspondence
Email contact is for practical arrangements around rescheduling, cancellations or other administrative requests. To minimise a paper trail any email correspondence will be deleted after 4 weeks if it is not needing to be kept.
After counselling has ended
Once counselling has ended your records will be kept for seven years from the end of our contact with each other (in line with legal purposes around taxes and insurance obligations) and are then securely destroyed. If you want me to delete your information sooner than this, please tell me.
Data Security
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. Printed documents are kept within a locked filing cabinet, which only I can access. Digital communications are secure via password protected devices and accounts, which only I can access, with information only kept as long as is necessary.
Third party recipients of personal data
It is very rare that a third party will have access to your data. Where this might occur is if a company (the bank, HMRC, financial services) need access to my bank statements to assess income and so may have access to your name due to payments being by bank transfer. They will be abiding by professional confidentiality terms also.
Your 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
Limit how I use your personal information
To stop processing your personal information
Provide a copy of any information that I hold about you
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 it
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. If you request your counselling notes I will require time to type these up and so will endeavour to provide them within one calendar month. Please note these notes are very brief.
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 via email.
Queries and complaints
If you have any queries or complaints about how I handle your personal data please get in touch with me if you feel able so I can clarify and hopefully resolve your concerns. 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 Information Commissioner’s Office (ICO) which is the statutory body that oversees data protection law in the UK.
Website visitors
When someone visits my website, I use a third party service, [Squarespace] 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 Squarespace 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 Squarespace as the content management system for this website. Like most websites we use cookies to help the site work more efficiently. 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.