I practice under the jurisdiction of the law in the United Kingdom.
This Policy was last updated in October 2018 in line with the General Data Protection Regulation (GDPR) reform in effect from May 2018. The reform sets out more rights for individuals and greater transparency in how personal data is processed. My lawful basis for processing your personal data is set out in Article 6 of the GDPR: (a) Consent: ‘the individual has given clear consent for you to process their personal data for a specific purpose.’
Personal Data I May Collect
I will only ask for personal information that’s needed to provide a counselling service which may include your name, address, date of birth, contact information, personal and medical history for example and those whose personal data you have, with express authority, disclosed to me (e.g. next of kin) whenever you complete an online or paper form, make a telephone enquiry with me or visit my practice to receive services. If you submit an online enquiry you agree to the terms of this Policy which include permitting me to contact you for the purposes of the related enquiry via the contact means you provide (i.e. email address or telephone number).
I will obtain some personal data (e.g. name and contact details) when you contact me for any reason, including to make an appointment. I may hold sensitive personal data if you provide me with such information and it is relevant for your case. Any sensitive personal data obtained from you will only be recorded with your explicit consent.
How I use Personal Data
I will use the personal data you disclose to me for making contact with you and for the purposes of the work. In extreme circumstances (e.g. if you are taken ill in a session) and with your permission, I might contact your next of kin.
I am a member of UK Council for Psychotherapy (UKCP) and, as such, am bound by the Ethical Framework for Good Practice in Counselling and Psychotherapy upon which a counselling/psychotherapy contract is based. I will provide the highest level of confidentiality possible according to the law and the Codes of Ethics of UKCP. To work ethically I will discuss your case with my supervisor. However, identifying details are changed to maintain confidentiality. With your permission, I may use sessional material for training purposes and examinations, however all identifying details are changed to maintain confidentiality.
Confidentiality may need to be broken in the following circumstances:
In situations of concern regarding your emotional/mental well-being, (e.g. a mental health condition, risk of suicide or self-harm), I would encourage you to self-disclose in order to access further appropriate support. However if you prefer, and with your consent, I could do this on your behalf,
In situations where you do not have the capacity to self-disclose (e.g. a severe mental health condition or learning disability), I may have to disclose confidential information without your consent. However I would always aim to inform you prior to taking any such action,
In the event of my death or any unexpected circumstance that might stop me from working, my executor would contact you to inform you. They will only have your contact number and no other identifying details.
Depending on the particular circumstances, I would always aim to discuss this with you before taking any action.
Marketing and Opting-in
Please be aware that I will not sell or otherwise disclose any personal data provided to me to any other party.
Disclosure of Personal Data
I may disclose personal data which you provide to me to law enforcement agencies in connection with any investigation to help prevent unlawful activity. In situations of public interest, I would have a legal obligation to disclose information without your consent and also would not be able to inform you prior to taking any such action, e.g. certain illegal activities, acts of terrorism and child protection issues.
Keeping Data Secure
I currently safeguard personal data by storing it in a locked cabinet or on a device protected by a password. Whilst I will use all reasonable efforts to safeguard such personal data, you acknowledge that the use of the internet is not entirely secure and for this reason I cannot guarantee the security or integrity of any personal data which are transferred from you or to you via the internet. To maintain confidentiality sessional notes are identified with an alpha-numeric client code only and you are referred to as ‘the client’.
By entering into counselling work with me you agree that I can process and store your personal information in connection with this agreement including data collected from the sessions.
I may record sessions with you for the purpose of clinical supervision, training or for an exam. I will be responsible for the recordings and keep them safely and securely stored so that nobody else can access them. Recordings will be destroyed after use.
Express permission from you will be requested and you will be asked for written consent. You are under no obligation to agree to recordings and can withdraw consent at any time. Declining recording will not impact on counselling and you will not be put under any pressure to consent.
Information About Other Individuals
If you give me information about others, you confirm that the other third party person has consented.
Under the third party authorisation, the other person can:
Give consent on his/her behalf to the processing of his or her personal data for the purposes and reasons set out in this Policy; and
Receive on his/her behalf any data protection notices.
Such authorisation will remain in place until this has been revoked, either by verbal or written communication.
You have the right to request access to your personal data which I process.
This formal request is made under the DPA and is referred to as a Subject Access Request. If you wish to exercise this right and make a Subject Access Request, you should;
Put your request in writing; either by Email or by letter.
Include proof of your identity and address (e.g. a copy of your driving licence or passport, and a recent utility or credit card bill);
Specify the personal data you want access to.
You have the right to require me to correct any inaccuracies in your data free of charge. If you wish to exercise this right, you should:
Either speak to me via telephone or put your request in writing;
Provide me with enough information to identify you (e.g. name, address, email address); and
Specify the information that is incorrect and what it should be replaced with.
You have the right to complain to the ICO if you think there is a problem with the way I am holding your data.
I will only process your personal data providing you have given your consent for me to do so. Session notes and contact information for clients I work with will be held for 7 years and then destroyed.
My Contact Details
I welcome your feedback and questions. If you wish to contact me, please send an email to firstname.lastname@example.org or call me on 07999 018885.
I may change this Policy from time to time. You should check this policy occasionally to ensure you are aware of the most recent version which will apply each time you deal with me.