Privacy Policy

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Privacy Notice 2024

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,

• 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 wellwatercounselling@gmail.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: ZB651521.

My phone number is: 07440 144317. 

My email address is: wellwatercounselling@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 satisfy your enquiry. This will include name, date of birth & preferred contact details (e.g., phone number, email address). 

If you decide not to proceed, I will ensure all your personal data is deleted within [4 weeks]. If you would like me to delete this information sooner, just let me know.

While you are accessing counselling.

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

-  if there is a serious concern for your or someone else’s safety, particularly if a child is at risk of serious harm;

-  if there is a legal obligation relating to your involvement in, or knowledge of, a serious crime;

-  if there is a court order requesting information about you;

-  if it is essential to prevent a serious and imminent threat to either public health or national security.

I will always try to speak to you about this first, unless there are safeguarding issues that prevent this. 

From our first session, I will keep a record of your additional personal details (address, medical history, current medications, GP contact, emergency contact details, family relationships and previous psychological therapy experiences) to help the counselling services run smoothly. These details are kept securely on Halaxy – a secure database - and are not shared with any other third parties. I will keep brief written notes of each session, these are kept on Halaxy as well. 

For security reasons I do not retain text messages for more than 3 weeks. If there is relevant information contained in a text message, I will copy this across to Halaxy and then delete the text message. Likewise, any email correspondence will be deleted after 3 weeks if it is not important. If necessary, I will save important emails on my password-protected business email. 

Sharing information

Supervision

As part of ethical practice, I am required to seek regular consultation with another psychological therapist who is qualified in this process. This is to ensure that I am able to work to my best ability and offer an ethical service that is helpful to you. The consultation process is also protected by confidentiality and my consultant will not know you personally or professionally. It takes place verbally and I refer to you by your first name. This process is to ensure my professional development.

You are asked to sign a consent form if your information is necessary to share with a third party. I ask you about sharing information with your GP during the first session. As discussed above the exceptions to sharing information about you may take place if there was a danger to yourself or others.

In case of emergency

If I have a reason to believe that you are at risk to you self, to someone else or there are child protection issues I am required to act upon these concerns. In that case I am obliged to breach confidentiality by speaking to e.g. a crisis team (harm to self) or the police (harm to others / an organisation e.g. in case of terrorism) or child protection services . If I have to breach confidentiality, where ever possible I aim to discuss this with you first.

In the event of an emergency in which I was involved whereby I was unable to contact you myself, your first name and telephone number will have been confidentially shared on a password protected document with my supervisor who is also bound by BACP regulations

and would inform you about the changes in our meetings or any other information that you may need to know. No other identifying personal information would be shared.

After counselling has ended.

Once counselling has ended your records will be kept for up to 7 years (for legal purposes) on Halaxy archive and are then securely destroyed. 

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 addressing it to wellwatercounselling@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.

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. 

-  Online notes, information and session details - all session data and personal information is stored on the secure Halaxy programme which has bank grade encryption.

-  Phone – I use a basic phone and store your contact details and SMS by first name and last name initial only.

-  Email – all email correspondence ad your email address will be stored in my business email account. 

Third party recipients of personal data

I use GoDaddy to support and host my website. They use cookies to analyse website performance. I do not make, and do not allow GoDaddy to make, any attempt to find out the identities of those visiting my website. 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.