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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 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, the Privacy and Electronic Communications (EC Directive) Regulations 2003, and the ethical guidelines of COSCA.
This privacy notice tells you what I will do with your personal information from the 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 store it for
· Whether there are other recipients of your personal information
· Whether I intend to transfer it to another country,
· Whether I do automated decision-making or profiling, and
· Your data protection rights.
I am happy to chat through any questions you might have about my data protection policy, and you can contact me via email at email@example.com.
‘Data controller’ is the term used to describe the person/organisation that collects, stores, and is responsible for people’s personal data. In this instance, the data controller is me.
I am registered with the Information Commissioner’s Office; reference number ZB373046.
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. Depending on the stage at which I am processing your data, there are different lawful bases. I have explained these below:
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 are in contact with me to consider therapy, I will process your personal data where necessary for our contract's performance.
The GDPR also ensures that I look after any sensitive personal information 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 the provision of health treatment (in this case, counselling) and necessary for a contract with a health professional (in this case, a contract between you and me).
How I use your information
When you contact me with an enquiry about my counselling services, I will collect information to help me satisfy your enquiry. This will include for example your name, address, email address and telephone number. Alternatively, your GP or other health professionals may send me your details when making a referral or a parent or trusted individual may give me your details when enquiring on your behalf.
If you decide not to proceed, I will ensure all your personal data is deleted within one calendar week. Please let me know if you would like me to delete this information sooner.
While you are accessing counselling.
Rest assured that everything you discuss with me is confidential. There are situations in which I can break confidentiality without your consent:
Where you give consent for confidentiality to be broken and information to be shared.
Where a court of law compels me.
Where the information is of such gravity that confidentiality cannot be maintained. This includes instances in which I consider you or others to be in imminent danger.
In the case of a disclosure concerning acts of terrorism or vulnerable adult or child protection issues, confidentiality will be breached, and such disclosures will be passed onto the relevant authority without delay.
I will always try to speak to you about this first unless there are safeguarding issues that prevent this.
I discuss my clinical work with a supervisor. This is to ensure that I am offering you the best service possible. These conversations are bound by confidentiality, and you will only be referred to by your first name.
I will keep a record of your personal details to help the counselling service run smoothly. I use Microsoft 365 cloud service to store your personal details. Access to my Microsoft 365 cloud service account is double password protected (password, Multi-Factor Authentication - MFA).
I will also keep notes of each session. These are anonymised and are stored within a password-protected file on my laptop and/or in a password-protected folder at the cloud service provider I use, Microsoft 365. These notes are for my use only and help keep track of everything being discussed. In line with industry guidelines, these notes will be held securely for up to seven years after your therapy ends. After this time, they will be securely destroyed.
For security reasons, I do not retain text messages for more than one calendar week. If relevant information is contained in a text message, I will store it in a password-protected file on my laptop and/or in a password-protected folder at the cloud service provider I use, Microsoft 365. Likewise, any email correspondence will be deleted after one calendar week if it is not essential. If necessary, I will store it within a password-protected file on my laptop and/or in a password-protected folder at the cloud service provider I use, Microsoft 365.
After counselling has ended.
Once counselling has ended your contact details will be kept for one month from the end of our contact with each other and are then securely destroyed. If you want me to delete your information sooner than this, please tell me.
Please note that I will need to keep a record of your name and client reference number for seven years after the end of your therapy, so that I can respond effectively to any potential requests regarding your clinical notes and treatment.
Third-party recipients of personal data
My email account uses the secure GSuite server and is double password protected (password, MFA).
I use Microsoft 365 cloud service to store my client files. Access to my Microsoft 365 cloud service account is double password protected (password, MFA).
All phones, tablets and laptops used to respond to your emails are encrypted, fully protected with anti-virus software and password/PIN protected.
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 I hold about you and to object to using 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.
You can also ask me at any time to correct any mistakes there may be in the personal information I hold about you.
To request any personal information I may hold about you, please put the request in writing, addressing it to firstname.lastname@example.org.
If you have any complaints about how I handle your personal data, please do not hesitate to contact me by email at 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, the statutory body that oversees data protection law in the UK. For more information, go to 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.
My laptop and tablet are encrypted, and if stolen, any data stored in them will not be accessible to anyone other than me. All client information is stored in a password-protected file on my laptop. My notes are stored within a password-protected file on my laptop and/or in a password-protected folder at the cloud service provider I use, Microsoft 365.
A PIN protects my mobile phone, and accessing my emails requires biometrics or a password.
Visitors to my website
When someone visits my website, I use a third-party service, WIX, to host my website and collect standard internet log information and details of visitor behaviour patterns. I also use Google Analytics to analyse the use of this website. 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 use legitimate interests as my lawful basis for holding and using your personal information in this way when you visit my website.
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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