This privacy policy outlines your rights, and my obligations to you, with regard to the recording and storage of your personal information; it concerns the information I need to collect from you before we start, during counselling and when our sessions have ended. It also sets out how I will look after your personal information, for how long I will store it, who I will share it with and what you are able to request from me with regard to this information.
What is personal information and why do you process it? The Data Protection Act 1998 defines personal information as any information that can be used to identify a living individual. I need to process your personal information in order to fulfil my contractual obligations to you as a counsellor; it helps guide my assessment and the work we do together. I may also use information in order to continue to develop my website and my professional practice.
What are the laws that protect personal information? The Data Protection Act 1998 and the General Data Protection Regulation 2018 (GDPR) require that all organisations that store personal information about people may only do so provided that the information is: processed lawfully, fairly and in a transparent manner; collected for specified, explicit and legitimate purposes; adequate, relevant and limited to what is necessary; accurate and, where necessary, kept up to date; kept in a form that permits identification of information subjects for no longer than is necessary for the purposes for which the personal information is processed; and processed in a secure manner.
How will you collect and treat my personal information? Personal information will be collected via my website, by phone, email, text or in writing, and in person during counselling sessions and assessment. I will treat your personal information in a way that is compliant with the Data Protection Act and the General Data Protection Regulation. The lawful and proper treatment of your personal information is important to me, to maintain your confidence and that of other clients.
How will you store my personal information? Personal information is stored securely both electronically and physically. Electronic information is password protected and held securely; any information held physically is filed in lockable storage that is only accessible by me. Please be aware that transmission of information via the internet, especially by email, cannot be completely secure, so this transmission is at your own risk in spite of security measures in place to protect your personal data.
How long will you store my personal information? According to the GDPR, your personal information should be stored for no longer than is necessary. It will be kept only for as long as is required to provide you with the services that you have requested; to support a claim in court or to comply with other law. After this time computer records will be deleted and any physical records shredded. My insurance company stipulates that counselling records must be kept for a period of 5 years; in the case of young people under the age of 18 their records will be kept until they reach the age of 18, plus another 5 years after this time.
What information will be collected? Information will be collected when you visit my website including IP address, location, search engine, operating system, and device. Following a request for further information I will collect name, contact details and an overview of the issues you are dealing with. During our assessment appointment I will ask for details of address, GP, and any personal details relevant to your past and current situation and the issues you are seeking support with. I will keep counselling notes on an ongoing basis that will be stored securely; these will not be shared with anyone unless there is a legal requirement to do so; personal data that identifies you and counselling notes are stored separately to further protect your right to privacy.
Under GDPR the lawful basis I rely on for processing this information, which may include more sensitive information defined by GDPR as special category, is your consent; I will ask you to read and sign a Counselling Agreement at the start of our work together which includes your understanding of how your data will be handled. This special category information may be needed ‘pursuant to contract with a health professional’ so that I can fulfil my obligation to deliver safe, effective counselling support.
Who will my personal information be shared with? I do not share your personal information with anyone else and I am committed to protecting your privacy. In exceptional circumstances I may be required by law or ethical responsibilities to break confidentiality; reasons for this include the risk of serious harm to you or to others, acts of terrorism or a serious safeguarding concern. I have regular consultations with my professional Supervisor to ensure my practise remains safe and professional but your identity would not be disclosed.
Can I ask for a copy of the personal information that you store about me? Under data protection law you have a right to see the information I hold about you, or ask for it to corrected, updated or deleted.
How to complain: I will do my upmost to deal with any concerns you may have, but if these are not resolved to your satisfaction you can contact the Information Commissioner’s Office on 0303-123-1113 / www.ico.org.uk
GDPR Number ZA335647
