Privacy Statement
Introduction
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.
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, 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 a phone call, text or email.
‘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.
I am registered with the Information Commissioner’s Office ZA270428.
My postal address is: Poplar Road Office Suite 8, Poplar Road, Cleethorpes, DN35 8BL
My phone number is: 0750 387 7938.
My email address is: davidcounselling@aol.com.
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. 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 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 (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 satisfy your enquiry. This will include your name and contact details such as your email address and/or phone number, any information you provide about what kind of counselling you are seeking and/or what information you provide about your counselling goals. Alternatively, your GP or other health professional may send me your details when making a referral or a parent or 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 provided to me via an email enquiry is deleted within one year, or if information is taken over the phone on paper this will be destroyed via shredding immediately after knowing that you will not be proceeding with me. If you would like me to delete this information sooner, just let me know.
While you are accessing counselling
What you discuss with me is confidential. That confidentiality will only be broken if you tell me that you are about to commit a crime that I could be expected to report (such as robbing a bank with or without a weapon, selling illegal drugs, money laundering, involvement in terrorism) or safeguarding in respect of children or vulnerable adults, or the intention to harm someone else or to harm yourself. 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 (including your name and address, contact details, the name and phone number of an emergency contact (in case you fall ill during a counselling appointment), the name and phone number of your general practitioner, and permission to seek emergency help on your behalf if this is necessary (eg to phone 999 for urgent medical care if you appear to be having a heart attack or other medical condition risking your life), and to help the counselling services run smoothly. These details are kept securely on paper, locked in a metal cabinet, and are not shared with any third party.
I will keep brief written notes of each session, identifiable to me by a code number and not names or other information which would identify who or where you are, which are kept in a locked metal cabinet.
For security reasons I do not retain text messages for more than one year. If there is relevant information contained in a text message I will write this on the paper notes which are locked in a metal cabinet. Likewise, any email correspondence will be deleted after one year if it is not important. If necessary I will copy and paste anonymised content and store with your session notes in the metal cabinet.
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, which is required by my insurance company, and are then securely destroyed. The notes made about our sessions are separated from your personal details to further increase the security of those notes, being code-numbered only.
The only time personal data is shared with third parties is when our counselling is contracted via a supplier such as an Employee Assistance Program. In such cases I have carefully selected which partners I work with, and they are the holders of the personal data, including brief notes of our sessions. In this work I keep only brief notes, if any, for invoicing purposes. 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 brief session notes I share with them. I ensure that they do not use your information in any way other than the task for which they have been contracted.
Third party recipients of personal data
When you pay me via bank transfer, the details on my bank account statement (the name from which the payment was made) will be visible to my business bankers, and my accountant. This information remains confidential, and will be seen only by my accountant, and possibly HMRC if they require to see my bank account. These organisations will be required to maintain confidentiality unless there is a legal reason to do otherwise as a result of a Court Order.
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. 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 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 its, 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 make a request for any personal information I may hold about you, please put the request in writing addressing it to davidcounselling@aol.com.
If you have any complaint about how I handle your personal data please do not hesitate to get in touch with me by writing or emailing 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 go to 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 make sure it is kept secure. by using encrypted devices, and keeping personal information and number-coded session notes on paper in a locked filing cabinet.
Visitors to my website
When someone visits my website, and sends an enquiry, Squarespace forwards the enquiry form to me.
My business website is basic, does not use cookies, and does not store data on usage.
I use legitimate interests as my lawful basis for holding and using your personal information in this way when you visit my website.