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.
I am happy to chat through any questions you might have about my data protection policy. ‘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 [Registration Number: C1084787].
My postal address is: 7 St George’s Street, Chorley, PR7 2AA. My phone number is: 07305 066452 My email address is: jaclyn@process-counselling.uk
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:
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).
How I use your information:
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 the contact details that you share with me (phone number, email address, DOB, address) and any further information you provide as to why you seek therapy. At the first session I will also request GP and Next of Kin details (this is for safeguarding should you give information during the sessions that suggest that you are at risk).
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 2 months. 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 if:
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 a locked filing cabinet within a locked room and are not shared with any third party. I will keep brief notes of every session to aid memory - these will be narrative based. these are kept with your personal details. You can request access to these notes via email, where the notes relate to couples counselling dual consent must be given.
SMS/Email
For security reasons I do not retain text messages/emails for more than 12 months. If there is relevant information contained in a text message I will add it to your written notes. Any email or attachment that is deemed important will be printed and stored with your notes before being deleted.
End of contact
Once counselling has ended your records will be kept for 5 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 discuss this with me.
Third Party Recipients of Data
I sometimes share personal data with third parties, for example, where I have contracted with a supplier to carry out specific tasks. In such cases I have carefully selected which partners I work with. I take great care to ensure that I have a contract with the third party that states what they are allowed to do with the data I share with them. I ensure that they do not use your information in any way other than the task for which they have been contracted.
Your Rights
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 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. As stated above, any request for notes relating to couples counselling must come with dual consent from both parties.
To make a request for any personal information I may hold about you, please put the request in writing. 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.
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. All paper records are kept in a locked filing cabinet in a locked room, of which only I have access. Any electronic communications are done on devices that are password and passcode protected, and emails in a private account to which only I have access.
When someone visits my website, I use a third party service, Google Analystics to collect standard internet log information and details of visitor behaviour patterns. I do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way that does not identify anyone and 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 to me.
If you wish to discuss any of the above with me, please email: jaclyn@process-counselling.co.uk
Please note that this privacy notice is subject to review and update, whereby current clients will be notified of any significant changes.