PRIVACY POLICY

I take your privacy seriously, and work in accordance with the General Data Protection Regulation 2018. I will be asking you for, and recording, personal data to deliver a counselling service to you. There are six lawful justifications for me doing this and those I use are:

(a) Consent: The individual has given clear consent to process their personal data for a specific purpose.

(b) Contract: The processing is necessary for a contract with the individual, or because they have asked to take specific steps before entering into a contract.

(c) Legal obligation: The processing is necessary to comply with the law (not including contractual obligations).

(d) Vital interests: The processing is necessary to protect someone’s life.

(f) Legitimate interests: The processing is necessary for legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests. (This cannot apply to a public authority processing data to perform official tasks.)

I will not use or disclose your personal information for any other purpose which is not related (or in the case of sensitive information, directly related) to the above purposes without your consent, unless otherwise authorised, required or permitted under the laws of England and Wales. I will not sell your data to third parties.

Detailed information on the collection, processing, sharing, retention and destruction of data is held on my Data Audit which is available to you on request. A summary of this information is given below.

DATA COLLECTING AND PROCESSING

Where I require consent, I will provide a way for you to positively decide about the information that you make available and how this is shared.

The data, I collect will come from contact that we have about booking appointments and from counselling therapy sessions. I will be update this data when necessary to ensure it is accurate, and it will be stored in the following formats:

Session Booking Information
Client Information Sheets
Outcome Monitoring Information
Client Payment Receipts
Client Case Notes

These will not contain your name or the names of anyone else that you know, but will contain some details of the things you have spoken about in therapy. This information could include special categories of personal data such as your racial or ethnic origin, political opinions, sex life, sexual orientation, religious or philosophical beliefs, trade union membership. It will include some personal history, our ideas about, and details of, the issues you bring to therapy and plans you have made to make changes in your life.

Session Booking Information, Client information Sheets, Client Contracts, Outcome Monitoring Information and Client Case Notes will be used to provide a counselling service to you under the contract we have.

I will collect, hold, use and disclose the information collected to compile statistical data and to; maintain my database; notify you of any upcoming marketing, training or other events that you have opted in to; manage quality control; manage systems administration and attend to legal and professional compliance issues.

If you no longer wish to receive information about my services, please let me know by email.

DATA SHARING

I may also use this data to improve my ability to deliver services as a counsellor, and in doing this – if I want to share information with a third party that could identify you – I will explicitly seek your consent for this.

If your counselling service is being paid for by a third party, I may be required, as a part of our contract, to share some data with them. In this case I will inform you of the type of data I am sharing. I will ensure that external service providers are committed to meeting their requirements under GDPR and are only authorised to use personal data for the limited purposes specified in my agreement with them.

Relevant Information may be shared with your GP or other professionals in circumstances where I think it is necessary to protect your life or the life of another

Relevant Information will be shared when it is required by law or legislation.

Client payment receipts will be shared with HMRC as part of the requirement to fulfil my legal obligations.

DATA RETENTION

Personal data is retained for 7 years, which covers the minimum 6 years by law in which I have to keep certain information plus the current year. Personal data that is not needed any longer, such as communications relating to the booking of sessions will be deleted as soon as it is no longer necessary. There are certain exemptions in relation to financial data and health data.

YOUR RIGHTS

You have the following rights in relation to personal data held on you:

• The right to be informed about how personal data is used – (this notice)
• The right to access a copy of personal data that I hold about you
• The right to rectification of any errors in personal data held
• The right to erasure of any personal data
• The right to restrict processing
• The right to data portability
• The right to object
• Rights in relation to automated decision-making including profiling

If you wish to learn more about these rights and how they operate, please look at the ICO’s website https://ico.org.uk/for-the-public/ .

I do not operate any automated decision-making systems.

You have a right to request a copy of the personal data that I hold about you. If you would like a copy of some or all of your personal data please email or write to me. Proof of your identity will be required for security purposes.

If you are unhappy with the response that I provide when you exercise your GDPR rights or Data Protection Act 2018 rights, you have the right to lodge a complaint to the ICO. More guidance about raising a complaint with us is available on the ICO’s website https://ico.org.uk/your-data-matters/raising-concerns/ and for raising a complaint with the ICO, more information is available on https://ico.org.uk/concerns/ .

If you want to see a copy of the information I hold then please contact me in writing. I am required to keep some information about you for a period after we have stopped meeting and ended our contract. I will store this securely and dispose of it securely at the correct time. Further details of this are contained in the Data Audit.

WEBSITE DATA

Cookies

My website uses Google Analytics, a web analytics service provided by Google, Inc. Google Analytics sets a cookie in order to evaluate your use of this website and compile reports for us on activity on the website. Google stores the information collected by the cookie on servers in the United States and the transfer of the data to servers in the USA is governed by the EU-US Privacy Shield framework. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above. More information about Google’s compliance with GDPR can be obtained from their website https://privacy.google.com/businesses/compliance.

Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. This information is used to track visitor use of the website and to compile statistical reports on website activity. For further information visit www.aboutcookies.org. You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser.

Other websites

My website contains links to other sites. This privacy policy only applies to this website so when you link to other websites you should read their own privacy policy.

Please review the website regularly as this statement may change from time to time. If you have any questions about my privacy policy or information I hold about you please contact me via email.