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 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

• Your data protection rights

• Whether I do automated decision-making or profiling

I am happy to discuss any questions you might have about my data protection policy and you can contact me here.

‘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 (ref ZB598161). My phone number is: 07508 160549. My email address is: offbeatcounselling@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 consent initially. I will then retain any counselling records in case of the need to reference them in the future (the official legal basis is to defend against potential legal claims).

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 respond to your enquiry. This will include your full name and contact details you choose to provide. It may also include your age, and a brief description of your reasons for seeking support. 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 two months of our last contact. If you would like me to delete this information sooner, just let me know.

While you are accessing counselling.

Everything we discuss is confidential, in line with the counselling agreement discussed at the outset of our work together. This applies to in-session material as well as any communications between sessions. The only exceptions to this are as follows:

•        I may take the content of some of our work to supervision, to ensure I am working ethically. (My supervisor is bound by the same confidentiality as our sessions.) 

•        If I have serious concerns that you or someone else are at risk of harm.

•        If you disclose knowledge of or involvement in any terrorist activities.

•        If you disclose knowledge of or involvement in any drug trafficking or money laundering. 

Please note that wherever possible, I will always aim to discuss these instances with you before taking any further steps, unless there are safeguarding issues that prevent this.

I will keep a record of your personal details to help the counselling services run smoothly. I may also keep the details of an emergency contact or your GP in case , but it is your decision to share this information with me. These details are kept securely on a password-protected laptop and are not shared with any third party. I will keep brief, hand-written notes of each session. These are identified via a coded system kept separately to other personal details, and kept in a locked cabinet.

For security reasons I do not retain text messages for more than one month. If there is relevant information contained in a text message I will record this separately, within your client notes. Likewise, any email correspondence will be deleted after one month if it is not important. If necessary I will save content under a secure folder on a password-protected laptop.

After counselling has ended.

Once counselling has ended your records will be kept for 7 years from the end of our contact with each other and are then securely destroyed. This is in accordance with my legal responsibilities and the requirements of my insurance provider.

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. Please contact me for details of any such current contracts.

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/for-the-public.

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 offbeatcounselling@gmail.com.

Data security

If you have any questions or complaints 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.

Visitors to my website

When someone visits my website, I use a third party service, Squarespace 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 Squarespace 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 Squarespace analytics so that I can continually improve my service to you. You can find out more about this and how cookies are used in the Website Terms of Use above.