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 Regulations (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 counselling/therapy has ended, including:
- Why I am able to process your information and what purpose I am processing it for
- Whether you have to provide it to me
- How long I store 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, and
- Your data protection rights.
‘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 - Emma French.
I am registered with the Information Commissioner’s Office, reference number ZA761514.
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:
If you have had counselling/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 counselling/therapy or if you are in contact with me to consider counselling/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).
How I use your information
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, telephone number, email address and the reason you are seeking counselling at this time. 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 1 month. 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 think there is a risk of serious harm to yourself or to another, for the prevention of serious crime or if the law requires it. 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 my counselling services run smoothly. These details are kept securely in a locked storage box and are not shared with any third party. However in the event that I am too unwell or otherwise unable to contact you to inform you that I can no longer honour our contract, for example in case of my serious illness or death, I have trusted a fellow counselling professional with the details necessary to administer my affairs if I am unable to. They may need to contact you in this eventuality and will professionally and sympathetically inform you of what you need to know.
I will keep brief written notes of each session, these are kept in a separate locked storage box.
For security reasons I do not retain text messages for more than 31 calendar days. If there is relevant information contained in a text message I will add this to your securely stored notes. Likewise, any email correspondence will be deleted after a maximum of 31 calendar days if it is not important. If necessary, I will add this to your securely stored notes. It is not stored for more than 31 days electronically.
After counselling has ended
Once counselling has ended your records will be kept for 5 years (as required by my insurer) 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.
Third party recipients of personal 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.
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 www.ico.org.uk/your-data-matters.
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 it
- 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 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 www.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. I password protect my devices, do not store mobile numbers in my contacts and keep paper records in locked storage. Where possible records are anonymised.
Additional information for website owners and employers
Visitors to my website
When someone visits my website, I use a third party service, Google Analytics, 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. I do not make, and do not allow Google Analytics to make, any attempt to find out the identities of those visiting my website.
I use legitimate interests as my lawful basis for holding and using your personal information in this way when you visit my website.
I use Google Analytics so that I can continually improve my service to you, you can read their privacy notice here https://policies.google.com/privacy?hl=en-US
I use Joomla as the content management system for my website - find out about Joomla and data protection here https://www.joomla.org/privacy-policy.html