GDPR Privacy Notice 

 

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. 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. I am registered with the Information Commissioner’s Office and my registration number is ZB747483. 


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 the purpose I am processing it for 
  • How I keep your information secure and how long I store it for
  • Your data protection rights.

I am happy to talk through any questions you might have about my data protection policy. 


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 my service and 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’ and includes, for example, information relating to any physical/mental health or condition. 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. When you contact me via my website or by email or phone this may include your name, email address, contact telephone number, and reason for your enquiry. Alternatively, a family member 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 month. If you would like me to delete this information sooner, just let me know. 


While you are accessing counselling.  

When you choose to proceed from a phone or online enquiry I will collect the following information as part of the assessment session: name, address, email address, telephone number, date of birth, GP name and contact details, current medications, mental health history, current mental health information including use of the GAD-7 (anxiety) and PHQ-9 (depression) questionnaires, family history, any physical health concerns. 

Please be assured that everything you discuss with me is confidential. That confidentiality will only be broken: 

  • Where you are at risk to yourself, or others, or from others   
  • Where there is a risk to the safety of others  
  • Where compelled by a court of law or otherwise required by law (e.g. terrorism, money laundering) 

I will always try to speak to you about this first, unless there are safeguarding issues or legal requirements 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 a computer which is password protected, within a personal vault electronic safe with two factor authentication system, and are not shared with any third party. Contact details on my phone are protected by biometric thumbprint.  

I will keep brief, relevant, written notes of each session. These are kept securely in a locked document safe and will not be shared, unless as a result of a Court Order. 

I do not retain text messages for more than one month. If there is relevant information contained in a text message, I will add this to the session notes. Likewise, any email correspondence will be deleted after one month if it is not important. If necessary I will add this to the session notes.  

 

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, in line with the requirements of my insurance company and professional bodies. The records 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, e.g. regarding IT software and website hosting. 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. 


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 to james@welwyngardencitycounselling.co.uk . If you have any complaint about how I handle your personal data please do not hesitate to get in touch with me by emailing the contact details given above. 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. 


Should you have any questions about my data protection policy I am happy to talk these through with you.