Under General Data Protection Regulations (GDPR) I am required to let potential and existing clients know what personal data I collect about them and how I store it. I need your explicit consent to hold and process your data and I am obliged to make clear the purpose of any data collection and processing. I am registered with the Information Commissioner’s Office (ICO) reference A8378158.
What information is collected about me?
When you contact me I will take your name, phone number and/or email address to allow me to answer your enquiry. Before our first appointment I will take further personal details such as your address, GP surgery, emergency contact details and information about your health and medication. During the course of our counselling I will make notes of our conversations and these may include other personal data such as age, gender, marital status, children, family and employment. These notes may also contain information about your race, ethnic origin, politics, religion, health, sex life or sexual orientation.
Why do you keep this information?
I keep personal data such as your phone number and/or email address so I can respond to your enquiry, to contact you to arrange or reschedule appointments and to share relevant information with you if we have agreed this. Your address is necessary for an emergency, for example if I am concerned about your safety and need to contact the Police. Details about your health and medication may be kept to provide a better understanding of how to support you. Your GP surgery and emergency contact details are kept so that I can help you should you need medical assistance or in the event of an emergency. During counselling I keep notes as a reminder of what we have discussed and to focus on the work we have agreed to do. I am required to keep notes by my insurance provider PPS and the BACP, the professional body that I am registered with, advise record keeping as part of good counselling practice. Emails and text correspondence are not kept as part of your notes.
How do you use this information?
I use this information about you in order to provide a personalised counselling service, for safeguarding purposes and to fulfil my professional and legal obligations. The lawful basis for collecting this information is to deliver a contractual service.
More information on this can be found at https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/lawful-basis-for-processing/contract/
How is my information stored?
Your personal details are kept in a locked filing cabinet. Your name is not used in written session notes which are coded and kept in a separate locked filing cabinet in a different location to your personal details. Your email and phone number(s) may be stored on a password protected mobile phone used only for business purposes and for the duration of counselling. Email addresses and
phone numbers are stored on this phone under your code. A document of client codes is kept electronically on a password protected laptop. The only information kept with this code is your name.
How long do you keep my information?
If you make an initial enquiry and I do not hear from you after one month then I will delete your message, text, email and/or any contact details you have provided.
Your data, including your session notes, will be kept for three years after counselling has ended before being securely destroyed.
Any email or text exchanges will be deleted once counselling has ended.
I will not use your details to contact you after counselling has ended. I will reply to you if you contact me after counselling has ended and you are welcome to return to counselling at any time.
Who do you share my information with?
Your data will not be shared with others with the following exceptions:
If there is a risk of harm to you or to others, I might need to seek help outside of the counselling relationship.
I am required by the BACP, the professional body that I am registered with, to undertake supervision on a monthly basis and will discuss aspects of our work with a supervisor. Your identity is protected in these supervision sessions.
If it became apparent that you were involved in illegal activity such as terrorism or money laundering I have a legal requirement to pass on such information. If you discussed serious crimes, or revealed information about others, including child protection issues, then I would report that to the relevant authorities.
If the Police made a request for information regarding a serious incident or crime, I would share this information.
If required to give evidence in court, I would have to do so.
If there were a public health issue I may have to disclose information.
What are your rights?
Under the General Data Protection Regulation (effective from 25 May 2018) you have the following new rights relating to data protection:
- The right to be informed
- The right of access
- The right of rectification
- The right to erasure
- The right to restrict processing
- The right to data portability
- The right to object
- Rights in relation to automated decision-making and profiling
How can I make a complaint?
If you would like to make a complaint about the collection or use of data, the UK’s independent authority set up to uphold information rights in the public interest and data privacy for individuals is the Information Commissioner’s Office https://ico.org.uk/