In order to provide you with the best service possible I need to hold your personal contact details and records of your therapy sessions. This privacy notice tells you what I will do with your personal information from initial point of contact through to after therapy has ended. 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 and the Privacy and Electronic Communications (EC Directive) Regulations 2003. I also adhere to the ethical guidelines regarding protecting client privacy and confidentiality set by the British Association for Counselling and Psychotherapy (BACP).
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. 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 therapy sessions) and necessary for a contract with a health professional (in this case, a contract between me and you).
How I use your information
I will never use your personal data for any purposes other than the administration of the therapy service that I am providing to you i.e., to arrange, cancel and rearrange appointments. I will only retain your personal information for as long as is necessary. This is in line with guidance from the Information Commissioner’s Office.
Initial contact: When you contact me to book your first appointment, I will collect some brief information to help me to process your enquiry. This will include your name so that I can book the appointment into my diary and a contact method, for example an email address or phone number. This information is requested so that you could be informed if I was unable to attend an appointment due to unforeseen circumstances. Alternatively, an organisation such an Employee Assistance Programme may send me your details when making a referral or a relative may give me your details when making an enquiry on your behalf. If an enquiry is made and you decide not to proceed, I will ensure that all your personal data is deleted within one month. If you would like me to delete this information sooner, please let me know.
While you are accessing therapy: Your email address or phone number will be used to provide you with written confirmation of your appointment times if you have given consent for this. Your email address and telephone number will only be used to contact you regarding appointment times, unless we have agreed that I will also use your email address to email you information that is relevant to your therapy sessions.
At the start of therapy, I will ask you for some personal details - your name, address, date of birth, contact information and contact information for your GP, or another emergency contact, if you would prefer. This information is stored in password protected computer that can only be accessed by me. Please be aware that I will not routinely contact your GP to inform your GP of your attendance, as your attendance is confidential. To fulfil my duty of care towards you while also maintaining your confidentiality, I will only contact your GP if it is necessary, and should these circumstances arise I would discuss this with you, wherever possible, before contacting your GP.
I keep brief notes of our therapy sessions for the purpose of assisting our work together. The notes help me to keep track of the issues that we are working on, and they are for my use only. The notes do not include any personal details that could be used to identify you and they are stored in a password protected computer that only I have access to. Your therapy notes are stored separately to your personal details.
Disclosure of your information
All my dealings with you and any information that I have about you is confidential except when I may have a legal obligation to share, such as terrorism, money laundering and radicalisation.
After therapy has ended: There are reasons why counsellors are required to keep records after therapy has ended. For example, in the case of financial transactions personal information must be retained for as long as legally required in respect of tax or accounting purposes. Retaining your therapy notes ensures that I can continue to offer you an efficient service if you make contact after therapy has ended. Your therapy notes do not include any personal details that could be used to identify you and continue to be stored in a password protected computer that only I have access to, for up to one year after therapy has ended.
Third party recipients of personal data
I share a limited amount of personal data with third parties to provide therapy services to you and to fulfil legal obligations in respect of tax and accounting purposes. For example, my accountant is permitted access to my invoices, if necessary.
Where I have contracted with a supplier to carry out tasks, I have carefully selected which organisations I work with. I state that they do not use your information in any way other than the task for which they have been contracted. I will never pass on your contact details to any third-party organisations for the purposes of sales, marketing, or research.
If your appointments are paid for or arranged via a third party, for example, a family member, the only information shared with the third party is your dates of attendance and non-attendance for invoicing and payment purposes. In the case of an Employee Assistance Programmes (EAP’s), reports containing information, for instance, regarding case management and safeguarding will be sent to the EAP’s, however, they will be written in consultation with you.
Visitors to my website
With regard to each of your visits to my site, I may automatically collect the following information:
technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from my site (including date and time); services you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
Strictly necessary cookies are cookies that are required for the operation of my site.
Analytical/performance cookies allow us to recognise and count the number of visitors and to see how visitors move around my site when they are using it. This helps us to improve the way my site works, for example by ensuring that users are finding what they are looking for easily.
Functionality cookies are used to recognise you when you return to my site. This enables us to personalise my content for you and remember your preferences.
Google Analytics Cookies
You can find out more about Google Analytics here developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
Access to information
You can request access to the personal information that I hold about you. I will provide this except in the limited circumstances in which I am permitted not to. Any access request may be subject to a fee of £10 to meet my costs in providing you with details of the information I hold about you.
You may request amendments to the personal information I hold about you that is inaccurate or out-of-date. If you request that I delete your personal information, I will take all reasonable steps to do so unless I need to keep it for legal, auditing or internal business purposes.
I am happy to chat through any questions that you might have about my data protection policy and you can contact me via firstname.lastname@example.org