Your privacy is very important 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. 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
Your data protection rights.
I am happy to chat through any questions you might have.
‘Data controller’ is the term used to describe the person/organisation that collects, stores and has responsibility for people’s personal data. In this instance, the data controller is myself.
I am registered with the Information Commissioner’s Office [ZA396778].
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 you and myself).
How it might look
How I use your information
When you contact me with an enquiry about my counselling services I will collect information to help me satisfy your enquiry. Alternatively, your GP or other health professional may send me your details when making a referral.
A 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 48 hours. 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 for vital reasons which will be provided in the working agreement ahead of the beginning of therapy. 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 [insert relevant device/s] and are not shared with any third party.
I will keep written notes of each session, these are kept locked away in a filing cabinet.
For security reasons I do not retain text messages for more than 7 days. Likewise, any email correspondence will be deleted after 7 days if it is not important.
Once counselling has ended your records will be kept for 7 years from the end of our contact with each other and are then securely destroyed.
I sometimes have to share personal data with third parties, for example, where I have been asked by a court of law or a health professional to carry out specific tasks. I ensure that they do not use your information in any way other than the task for which they have been contracted.
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 it, 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. I would welcome any suggestions for improving my data protection procedures.
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.
Visitors to my website
I use wix.com as the content management system for this website.
No user-specific data is collected by me or any third party. If you fill in a form on my website, that data will be temporarily stored on the web host before being sent Freedom Living Counselling.