PRIVACY
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Your privacy is 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 provided for. 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 the initial point of contact through to after your counselling has ended, including:
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Why I am able to process your information and what purpose I am processing it for.
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Whether you have to provide it to me.
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How long I store it for.
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Whether there are other recipients of your personal information.
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Your data protection rights.
I am happy to discuss any questions you might have about my data protection policy and you can contact me through the details given here.
​‘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, the data controller is me.
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I am registered with the information commissioner's office (registration number ZB566667).
​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. These are explained below:
If you have had counselling 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 counselling or if you are in contact with me to consider counselling, 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).
How I use your information
Initial contact:
When you contact me with an enquiry about my counselling services, I will collect information to help me to satisfy your enquiry. This will include your name and the contact information that you provide me with, as well as the content of any message you send me. Alternatively, another health professional may send me your details when making a referral. Or a trusted individual may give me your details when making an enquiry on your behalf.
If you decide not to proceed, I will ensure all your personal data is deleted within two weeks. If you would like me to delete this information sooner, just let me know.
While you access counselling:
Please be assured that everything you discuss with me is confidential. That confidentiality will only be broken if:
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If I am concerned about your safety or the safety of others.
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All counsellors work with supervisors. I would need to discuss client content with my supervisor (who is also bound by confidentiality), where you would be referred to by your first name only.
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If I am unable to practise due to illness/sudden incapacity, when a qualified colleague would contact you to enquire about your wish for further counselling.
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If I am compelled by a court of law to disclose notes/information about you.
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If non-payment of fees result in legal action being taken against you.
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At your request that you would like me to breach confidentiality.
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 service run smoothly. These details are kept securely on a password protected, encrypted device and are not shared with any third party.
I will keep written notes of each session. These are anonymised, and are held separate from your name and contact details, kept securely on a password protected, encrypted device, and are not shared with any third party.
For security reasons I do not retain messages for more than two weeks. If there is relevant information contained in a text message or an email that you send, I will transfer it to the written notes that I keep (see above).
After counselling has ended:
Once counselling has ended, your records will be kept for six years from the end of our contract with each other and are then securely destroyed.
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 (for example this website host, for the purposes of the operation of the website). In such cases, I carefully select 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 for the task for which they have been contracted.
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, to limit how I use your personal information, or to stop processing your personal information. However these requests may be refused where processing of your data continues to be necessary for the performance of our contract or where there is a legitimate purpose which outweighs your interests in having your data deleted or the cessation of processing. 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 about your rights at ico.org.uk/your-data-matters.
If I do hold information about you, I will:
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Give you a description of it and where it came from.
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Tell you why I am holding it, tell you how long I will store your data and how I made this decision.
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Tell you who it could be disclosed to.
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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 the contact details here.
​If you have a complaint about how I handle your personal data, please do not hesitate to get in touch with me in writing 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, see ico.org.uk/make-a-complaint.
Data security
I take the security of the data I hold about you very seriously and as such I take every effort to ensure it is kept secure, in a password-protected, encrypted device.
Visitors to my website
When someone visits my website, I use a third-party service, the website host Wix, 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 my site. This information is only processed in a way that does not identify anyone. I do not make, and do not allow the website host Wix 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 Wix as the content management system for my website. Like most websites I use cookies to help the site work more effectively. You can opt out of these by choosing 'decline' in the pop-up cookie banner. 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.
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