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 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 to email@example.com.
This notice does form part of any contract to provide services.
“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, Elspeth Gilliland. I am registered with the Information Commissioner’s Office (Registration Number ZA458603). My postal address is 10 Sunnyside, Cornhill-on-Tweed, Northumberland, TD12 4XN. My phone number is 0737 909 4466. My email address is firstname.lastname@example.org.
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 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, your postal and email addresses, your date of birth, your GP’s name and address and an emergency contact.. 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 is deleted within 4 weeks. If you would like me to delete this information sooner, just let me know.
While you are accessing counselling: Rest assured that everything you discuss with me is confidential. That confidentiality will only be broken if circumstances arise as detailed in the counselling contract. 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 services run smoothly. These details are kept securely in password protected files on my laptop and are not shared with any third party. I may keep brief written notes of each session, which will be kept in a locked metal filing box.
For security reasons I do not retain text messages for more than one month. If there is relevant information contained in a text message I will transfer this to an electronic, password protected file on my laptop.
Likewise, any email correspondence will be deleted after one month if it is not important. If necessary I will copy the email to a password protected file on my laptop.
After counselling has ended: Once counselling has ended your records will be kept for five years 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.
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 www.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 this
• 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 email@example.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 www.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. Wherever possible the data I hold is anonymised. I use a password protected laptop to which only I have access, and store computer data in password protected files and/or on encrypted USB sticks. Paper documents and USB sticks are kept in a locked filing box. Telephone numbers are only kept on my mobile device for the duration of our work together.
Third Party Recipients of Personal Data
I do not share personal data with third parties other than as detailed in the counselling contract (i.e. legal obligation and/or safeguarding).
Use of Third Party Platforms
I send emails via Microsoft Outlook and use Zoom for online video counselling. Having read the documentation provided by these third parties I believe that by adhering to their guidelines the platforms are as secure and safe as is possible for us to use. However, no internet-based platform, including email, is 100% secure, therefore I cannot be held responsible for unauthorised or unintended access that is beyond my control. When I communicate via email, there is always the possibility that the email platforms can be hacked, or email transmission may not be encrypted when corresponding back and forth.
I remain mindful of this and ensure that I do everything in my capability to protect your personal information, including a commitment to regularly review the security policies of these third party platforms, however I cannot be held responsible for any breach in security as a result of failings within their systems. By signing the counselling contract you acknowledge this fact.
My Website and Data Protection
My website may include links to third-party websites, plug-ins and other applications. By clicking on those links or enabling those connections this may allow third parties to collect or share data about you. I have no control over these third-party websites and I am not responsible for their privacy statements or the way in which they handle data. I recommend that, when you leave my website, you read the privacy notices from all the sites that you visit.