‘You’ and ‘your’ refers to a parent, your child for whom you are seeking counselling, a young person who has chosen to access counselling without parental consent (in accordance with Gillick competencies), or an adult client aged 18-25.
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:
I am happy to chat through any questions you might have about my data protection policy and you can contact me via email at firstname.lastname@example.org
‘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 [ ZA 766415 ].
My telephone number is 07515 789632. My email address is email@example.com.
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/your child).
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 child’s name, gender, date of birth and contact details. 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 30 days. If you would like me to delete this information sooner, just let me know.
Rest assured that everything you (or your child) discusses with me is confidential. That confidentiality will only be broken if there is imminent risk to the safety of a child or young person, or to others. I will always try to speak to you about this first, unless there are safeguarding issues that prevent this. I in this way work in accordance with the DfE 2018 guidance Working together to safeguard children, which means that I operate within recommended safeguarding practice, and have a duty to disclose information where I have a serious concern about the welfare or safety of a child or young person.
I will keep a record of your personal details to help the counselling services run smoothly. These details are kept securely, either in a locked filing cabinet, or password protected laptop device, and are not shared with any third party.
I will keep written notes of each session, these are kept in hard copy only in a locked filing cabinet.
For security reasons, I do not keep text messages for more than 48 hours. If there is relevant information contained in a text message, I will record this electronically and keep it on my password protected laptop. Likewise, any email correspondence will be deleted after the therapy has ended if it is not important. If necessary I will store this electronically and keep it on my password protected laptop. I will not store your details on my mobile device – these will be kept with your personal details.
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. If you want me to delete your information sooner than this, please tell me.
When I am required to share personal information with other people, I will ensure that I seek your consent. I will not pass your personal information to your friends, relatives or carers without your explicit consent. If you are unable to consent for any reason, I will only share information where it is clearly in your best interests to do so or it is required by law.
I will sometimes need to share the personal information I process with other organisations. When I do this I am required to comply with all aspects of the General Data Protection Regulation. Where necessary I also have data sharing agreements in place with organisations which will state the specific ways in which the shared data can be used.
The organisations I share information with can include:
The reasons why I would share your information could include:
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, 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:
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 firstname.lastname@example.org
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.
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. My devices are password protected, with anti-virus and encryption software installed. All notes are kept in a locked filing cabinet. Online counselling takes place over an end-to-end encrypted service.