This privacy notice explains how I process data to comply with the General Data Protection Regulation (GDPR) 2018. I am a Data Controller registered with the Information Commissioners Office under reference ZA387889. I am committed to protecting your personal data and collecting only necessary data, processing it in a fair, transparent and lawful manner, keeping it no longer than necessary and thereafter securely destroying it.
I have implemented appropriate physical, technical and procedural measures to protect your personal data from improper access, use, alteration, destruction and loss. The lawful basis covered by article 6(1) (b) of the GDPR under which I process personal data is called ‘contract’. You are entering into an agreement with me for the supply of a service - counselling - and I am processing your data in order to either provide that service or to determine if the service is appropriate.
Some of the information you may disclose to me is considered ‘special category’ data. This is sensitive information that might include data about, for example, your health, mental health, sexual orientation, religious, cultural and political beliefs etc. I take extra care with such information.
The lawful basis under which I process special category data is that I am providing a health and/or social care service. I will never sell or share your personal data with other organisations for marketing or promotional, sales or other purposes. I do not use any form of automated profiling or decision-making.
What information do I collect?
In addition to your contact details and your GP details, I keep short factual notes about our counselling sessions which may include sensitive information that you have disclosed to me. I may also keep a record of creative work, writings, drawings or diagrams that we have used during our work.
What do I do with your data?
All information is held very securely-electronic records are kept in a secure way and paper records kept in a locked file cabinet. All material from sessions is stored in a way which is not personally identifiable. I am the only person who has access to your data. I will not discuss any therapeutic work with you electronically. I will only arrange either via email or text message your assessment and counselling times and dates and will delete those as soon as they become irrelevant. I will only keep counselling contract, assessment form and client notes for future reference.
How long do I keep records for?
Generally, I keep personal data for up to 5 years from the date our therapeutic work has ended as it could be useful and relevant for a client returning to counselling. I have chosen 5 years as a reasonable time between retaining potentially useful data and keeping data for no longer than is necessary.
Disclosure (or sharing) of personal information
Information stored electronically is not shared with anyone. I have regular supervision with a clinical supervisor, and he is the only person with whom I talk with about my work. Supervisors are bound by the same terms of confidentiality as I am. Clients are identified by first name only. In the event of my becoming incapacitated in some way, a supervisor is able to access only the contact details of my clients. This is stated in my Counselling Practice Living Will. The other occasions when data might be shared is when I have your consent to do so, or when I am obliged to break confidentiality for reasons which are discussed in the counselling agreement that I ask you to sign at the beginning of your counselling.
Your data rights:
request access to a copy of the personal data I hold about you.
ask me to change or complete any inaccurate or incomplete personal data held about you.
ask me to delete your personal data where it is no longer necessary for me to use it.
ask me to provide you or a third party with some of the personal data that I hold about you in a commonly used form, so it can be easily transferred.
ask me to restrict the personal data I use about you where you have asked for it to be erased or where you have objected to my use of it.
Note that some of these rights only apply in certain circumstances and I may not be able to fulfil every request. Please contact me if you wish to exercise any of these rights, or if you want to discuss with me any aspect of my privacy practices.