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:
• 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.
I am happy to chat through any questions you might have about my data protection policy and you can contact me via [Helen.Holmes837@gmaill.com]
‘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 [ZB4777].
My contact details are - postal address: 13, Oaklands House, 59-65, Belsize Road, London. NW6 4BE; Mobile number: 07952 717 951 and Email address: Helen.Holmes837@gmail.com
· 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 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).
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 full name, Date of Birth, home address and GP 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 one week. If you would like me to delete this information sooner, just let me know.
· While you are accessing counselling, be assured that everything you discuss with me is confidential.
All information shared by you with me, would be held in strict confidence. The exceptions to this rule are 1. To prevent harm to self or other (including serious crimes, balance of public interests: murder, manslaughter, rape, treason, kidnapping, child abuse); acts of terrorism; drug trafficking and money laundering; road traffic offenses; child protection; Female Genital Mutilation; court order; tribunals; family court and civil court; criminal court; mental capacity 2. Where there is a need to discuss anonymised client material with a supervisor.
Additionally, information sent electronically cannot be guaranteed to be secure. You can talk to whoever you choose about your therapy. I would not accept or give friends invitations for social media sites.
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 on an encrypted device and locked in an irremovable cabinet and are not shared with any third party.
I will keep anonymised written notes of each session, these are kept on an encrypted device separate from your personal details.
For security reasons I do not retain text messages for more than six years. If there is relevant information contained in a text message I will copy this into a word documents and store this anonymously on an encrypted device. Likewise, any email correspondence will be deleted after six years if it is not important. If necessary I will store these on an encrypted device, locked in an irremovable cabinet, solely accessible by myself.
After counselling has ended
Once counselling has ended your records will be kept for six 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.
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 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. To make a request for any personal information I may hold about you, please put the request in writing addressing it to Helen.Holmes837@gmail.com
· 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 by storing anonymised data on encrypted devices and in a locked cabinet.
Additional information for website
Visitors to my website
· When someone visits my website, I do not use a third party service, to collect standard internet log information and details of visitor behaviour patterns.
· I use legitimate interests as my lawful basis for holding and using your personal information in this way when you visit my website.
Third party links
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.
The data I collect about you
· Identity Data includes first name, maiden name, last name, username or similar identifier,
marital status, title, date of birth, job status/description, and gender.
· Contact Data includes billing address, delivery address, email address and telephone number.
· Financial Data includes bank account and payment card details.
· Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
· Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug - in types and versions, operating system and platform, and other technology on the devices you use to access this website.
· Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
· Usage Data includes information about how you use our website, products and services.
· Marketing and Communications Data includes your preferences in receiving marketing from me and our third parties and your communication preferences.
Change of purpose
How long will you use my personal data for?
Your legal rights
· Request access to your personal data
· Request correction of your personal data
· Request erasure of your personal data
· Object to processing of your personal data
· Request restriction of processing your personal data
· Request transfer of your personal data
· Right to withdraw consent
What I may need from you
Time limit to respond