Privacy Statement
Introduction
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 UK General Data Protection Regulation (Data Protection Act 2018) known as UK GDPR.
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 there are other recipients of your personal information
• Whether I intend to transfer it to another country
• Whether I do automated decision-making or profiling
• How long I store it for
• Whether you have to provide it to me, and
• Your data protection rights.
I am happy to talk through any questions you might have about my data protection policy and you can contact me via email. ‘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 me.
I am registered with the Information Commissioner’s Office (ICO) registration reference ZB557641, under Ms Fiona Reid.
My phone number is 07434 661259. My email address is fionar.counselling@hotmail.com
I maintain a Clinical Will in line with ethical guidelines, so you may be informed in the event of my death or incapacitation during our counselling contract. You would be informed by the Clinical Trustee I have designated. They would only have access to your information in this specific circumstance.
My lawful basis for holding and using your personal information
The UK 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 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.
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.
The UK 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 the counselling contract and for my legitimate interest.
How I use your information
I do not share data with any third-party recipients. I do not transfer any data to others, including others in another country. I do not perform any automated decision-making or profiling.
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, email address and telephone number.
(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 five business days of your informing me. If you would like me to delete this information sooner, just let me know. If you do not contact me with a decision about whether to proceed, I will delete your personal data 20 business days after our last contact.
While you are accessing counselling
Everything you discuss with me is confidential. That confidentiality will only be broken if, as the result of the dialogue, I have reason to believe that you, or someone else, is at risk of harm, or you disclose terrorist or criminal activities. 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 one device and are not shared with any third party. I will keep handwritten notes of each session; these are stored in a locked box only I can access. These do not include your name or any identifying details. Signed online contracts are stored electronically on a password-protected cloud. Signed physical contracts are scanned to be stored electronically on a password-protected cloud and the paper copies shredded.
For security reasons I do not retain text messages for more than 5 business days. If there is relevant information contained in a text message, I will transfer it to the personal details record or the written notes as appropriate. The telephone used is password-protected. Likewise, any email correspondence will be deleted after 10 business days if it is not important. If necessary, I will keep email correspondence until the counselling has ended. If there is relevant information contained in an email, I will transfer it to the personal details record or the written notes as appropriate. If we meet for counselling online, I will not disclose contact details to the online platform used for counselling, sending the invite from my email address to yours. I will use a password and operate the wating room function. I will not record the session or allow AI applications to run.
After counselling has ended
Once counselling has ended, my written records and the electronic contract will be kept for three years from the end of our contact with each other and then securely destroyed. If you want me to delete your information sooner than this, please tell me. Digital information will be deleted. Physical paperwork will be shredded. Email correspondence and your address, date of birth, GP name, and optional emergency contact details will be deleted immediately upon counselling ending.
Your rights
You do not have to provide me with your personal information. This may affect the process of counselling and would be dealt with on a case-by-case basis.
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 https://ico.org.uk/for-the-public/your-right-to-get-copies-of-your-data/
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 its, 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. If I am aware of any updates to your data, I will update the data I hold, in conversation with you.
To make a request for any personal information I may hold about you, please put the request in writing, addressing it to fionar.counselling@hotmail.com
If you have any complaint about how I handle your personal data, please do not hesitate to get in touch with me by 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 https://ico.org.uk/make-a-complaint.
Data Security
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 email and telephone are password-protected, and only accessed by me.
Each device on which I might access my email had additional passwords to unlock them. Your contact details are kept securely in a password protected file on one device, which is itself password- protected. Paper records contain no name or identifiable information. I use a pseudonym system to file these, known only to myself. These are kept in a locked box only I can access. Should data be lost, stolen, or accidently deleted, I will respond in line with ICO policy. I will inform you as soon as is practically possible in the unlikely event of data being stolen.
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Who we share your data with
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How long we retain your data
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Where your data is sent
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