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
- 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 email. '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 under registration number ZB809748. My email address is: imogen.ruth@proton.me
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 that it is for provision of health treatment (in this case counselling) and necessary for a contract with a health professional (in this case, a contract between me and you).
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 that it is for provision of health treatment (in this case counselling) and necessary for a contract with a health professional (in this case, a contract between me and you).
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 your name, the contact details you used to enquire, and may include brief information about what has led you to seek therapy, and any other relevant clinical information where appropriate. Alternatively, your GP or other health professional may send me your details when making a referral or a 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 7 days. If you would like me to delete this information sooner, just let me know.
If you decide not to proceed I will ensure all your personal data is deleted within 7 days. 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 there is a risk of serious harm to you or others, there are safeguarding converns involving a child or vulnerable adult, or if disclosure is required by law or requested by court order. I will always try to speak to you about this first, unless there are safeguarding issues that prevent this.
As part of my commitment to ethical practice as outlined by my membership body, the NCPS, I access regular supervision where I may share material from counselling sessions. This material is anonymised where possible.
Boundaries regarding confidentiality and its specifics are discussed at the beginning of counselling, and included in individual written agreements.
I will keep a record of your personal details to help the counselling services to run smoothly. These details are kept securely on a password-protected, encrypted service which can only be accessed from a password-protected device, and are not shared with any third party. Passwords are strong and changed on a regular basis. I use 2-factor authentication as an added layer of security.
I will keep brief, factual handwritten notes of each session. These are kept within a locked briefcase in a secure property.
As part of my commitment to ethical practice as outlined by my membership body, the NCPS, I access regular supervision where I may share material from counselling sessions. This material is anonymised where possible.
Boundaries regarding confidentiality and its specifics are discussed at the beginning of counselling, and included in individual written agreements.
I will keep a record of your personal details to help the counselling services to run smoothly. These details are kept securely on a password-protected, encrypted service which can only be accessed from a password-protected device, and are not shared with any third party. Passwords are strong and changed on a regular basis. I use 2-factor authentication as an added layer of security.
I will keep brief, factual handwritten notes of each session. These are kept within a locked briefcase in a secure property.
After counselling has ended
Once counselling has ended your records will be kept for 7 years from the date our contract ended, in line with professional guidance and insurance requirements. After this time, alll records will be securely destroyed or deleted. 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. 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.
Examples of these third parties are clinical supervisors, encrypted, privacy-first and secure cloud softwares such as Proton, professional indemnity insurers (if required), and legal/safeguarding authorities (if required).
I also have a Clinical Will, where a trusted professional counsellor - the Trustee - will have access to your data if I am seriously incapacitated, or in the case of my death. The Trustee will only have access to your data under these circumstances and they will only use it in order to inform you of them, and to arrange continuity of care according to your wishes.
I do not share your data for marketing purposes, and I will never sell your data.
Examples of these third parties are clinical supervisors, encrypted, privacy-first and secure cloud softwares such as Proton, professional indemnity insurers (if required), and legal/safeguarding authorities (if required).
I also have a Clinical Will, where a trusted professional counsellor - the Trustee - will have access to your data if I am seriously incapacitated, or in the case of my death. The Trustee will only have access to your data under these circumstances and they will only use it in order to inform you of them, and to arrange continuity of care according to your wishes.
I do not share your data for marketing purposes, and I will never sell your data.
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. As detailed above:
- Written notes are kept in a locked briefcase, stored in a secure property;
- Digital notes are kept on an encrypted, two-factor authenticated privacy-first software, accessible only from password protected devices;
- No third-party can access your data without explicit and compliant agreements as detailed above.
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:
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 its, 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 imogen.ruth@proton.me.
If you have any complaint about how I handle your personal data please do not hesitate to get in touch with me by 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.
If you have any complaint about how I handle your personal data please do not hesitate to get in touch with me by 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.
