Privacy Policy 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. I am registered as an individual practitioner with the Information Commissioner’s Office. I collect and hold information about you as a legitimate interest as defined under the General Data Protection Regulations. This privacy policy explains how I use any personal information I collect about you when you use my service. It also informs you of your rights and my responsibilities in the processing of your personal information under the General Data Protection Regulations. 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 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. 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. 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 satisfy your enquiry. This will include name & 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 after 6 months. While you are accessing counselling Rest assured that everything you discuss with me is confidential. That confidentiality will only be broken: •Where the information is such that confidentiality cannot be maintained i.e. in cases of fraud, crime and/or where there is an immediate risk of serious harm to self or others. •Where the client gives consent for information to be shared (it is an ethical requirement for me to undertake supervision, so my work with you may also be discussed as part of my clinical work with my supervisor) •Where the counsellor is compelled by a court of law 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 and are not shared with any third party. I will keep written notes of each session, these are kept in a locked filing cabinet or in password protected files. For security reasons I do not retain text messages. Likewise, any email correspondence will be deleted if it is not important. After counselling has ended Once counselling has ended your records will be kept for 3 years from the end of our contact with each other and are then securely destroyed (insurance requirement). Third party recipients of personal data I do not discuss your personal information with third parties. However, if there was an immediate and serious risk that you might harm yourself or someone else then I may have to share your personal information with a third party such as your GP or the emergency services without first obtaining your consent. This might be because it is not practically possible to obtain your consent or because attempting to do so might lead to a delay in accessing help and therefore endanger your life or that of another. In situations where I did have to share your personal information with third parties to protect you or another, I will only share your personal information in so far as it is relevant and necessary to protect you or someone else. I will inform you what personal information is shared and to whom. It is possible that your personal information may be requested by a Court of Law, Coroner’s Office or Professional Body in which circumstances you may have limited or no rights of refusal. 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. 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. 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. I use encrypted devices and a locked filing cabinet. Visitors to my website When someone visits my website, I use a third-party service, Wix.com 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 wix.com 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. Like most websites we use cookies to help the site work more efficiently - find out about our use of cookies. For reference see bacp.co.uk/notices/cookies. 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. Length of storage of your personal information I keep your personal information and the record of our work together for three years (as required by my insurance). I then securely erase your records. Changes to the privacy policy I keep the privacy policy under regular review and this privacy policy was last updated on 8th May 2023. Right to complain You have the right to complain to the Information Commissioners Office without prejudice about the processing of your personal data. www.ico.org.uk