PRIVACY POLICY

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. I also adhere to the ethical guidelines about protecting client privacy and confidentiality set by my professional body, the British Association for Counselling and Psychotherapy (BACP). 


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 phone or email for this purpose.  


‘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 with registration number ZB242156.


My postal address is: Unit 90264, PO Box 4336, Manchester, M61 0BW. My phone number is: 07434 645857. My email address is: CounsellingWithSophie@gmail.com.

The type of personal information I collect

I may hold and process some or all of the following information, if you choose to provide it to me:

  • Personal identifiers, contacts and characteristics (for example, your name and contact details);

  • Bank or credit/debit card details (if you choose to pay me electronically);

  • Physical or mental health details;

  • Racial or ethnic origin;

  • Religious or philosophical beliefs;

  • Political opinions;

  • Data concerning your sex life and sexual orientation; and

  • Offences, criminal convictions, and alleged offences.

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. 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 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 collect and use your information

Initial contact

When you contact me with an enquiry about my counselling services, I will collect information to help me deal with your enquiry. This will include your name and contact details, and may include other information such as information about your physical and mental health, marital status, physical or mental health details, racial or ethnic origin, religious or philosophical beliefs, political opinions, sex life and sexual orientation, and any offences, criminal convictions, and alleged offences, if you choose to share this information with me as part of your enquiry. 


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 within one year. If you would like me to delete this information sooner, just let me know. 


While you are accessing counselling

Everything you discuss with me is confidential, aside from situations where I am ethically or legally obliged to share the information. The reasons for this are set out in more detail in my standard counselling agreement, but broadly relate to situations where I consider you or someone else is at significant risk of harm, or I am legally required to disclose information to the police or justice system. I will always try to speak to you about this first, unless there are safeguarding issues or legal requirements that prevent this.


Before we start working together, I will also you to fill out a brief form with your contact information, date of birth, next of kin, and GP details. The next of kin and GP details will only be used if you ask me to or if I am concerned about your wellbeing, and wherever possible I will discuss this with you before making contact. 


I will retain your contact details to help the counselling services run smoothly, e.g. for the purposes of making and rearranging appointments. I also keep brief written notes of each session to help me keep track of our work; these are stored separately from any personal details that would identify you. 


These records and notes are securely on a password-protected laptop and a secure cloud-based system (Microsoft Office365), and not shared with any third party except as outlined within this privacy notice.


I am ethically obliged to have regular counselling supervision to monitor and improve my practice. I do discuss my client work with my supervisor, however only your first name will be provided. If you would prefer me to just use your initial(s), please let me know. My supervisor is also a member of the BACP and therefore abides by their ethical framework regarding confidentiality and data protection.  


After counselling has ended

I will need to keep records after therapy has ended for various reasons: for tax/accounting purposes; for legal/insurance reasons; or so that I can offer you a good service if you would like to resume counselling at a later date. Once counselling has ended, your records will therefore be kept for seven years from the end of our contact with each other and are then securely destroyed. If you want me to delete your information sooner than this, please tell me.

International transfers, automated decision-making, and profiling

I do not carry out any automated decision-making or profiling.  


I do not personally transfer your data out of the UK or the European Economic Area. However, some of the IT services I use, such as Zoom, NordVPN, Google Analytics, and Microsoft Office365, may have international servers. Wherever possible, I review the provider’s data processing agreements to ensure that your data will have a level of protection equivalent to that under the UK data protection regime.  

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, or where I have a safeguarding concern about you or someone in your life. These third parties may include:

  • Microsoft Office365;

  • Zoom;

  • Professional advisers such as my accountant;

  • Healthcare professionals such as your GP;

  • My regulators, including HMRC and the ICO;

  • My professional body, the BACP;

  • My professional indemnity insurer, Holistic;

  • My VPN provider, NordVPN.


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. I will also try to share the minimum amount of personal data possible.

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 its, tell you how long I will store your data and how I made this decision; 

  • Tell you who it could be disclosed to; and

  • 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 CounsellingWithSophie@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 securely. 


My session notes and records of client details are stored on a password-protected computer, to which only I have the password, and on a secure cloud-based server, Microsoft Office365.


I have a separate smartphone used only for counselling purposes. Contacts are saved using the person’s first name only.  


My emails are only accessed from a password-protected computer and from my counselling smartphone. 

I do not usually keep paper records. I may make brief paper notes while having an initial telephone call with you, but these will be securely destroyed afterwards. If for any reason it does become necessary to keep any hard copy information about you, this will be stored in a locked filing cabinet to which only I have the key.

Visitors to my website

When someone visits my website, I use my website provider, Wix, 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 to make, any attempt to find out the identities of those visiting my website. You can read Wix’s privacy notice here: www.wix.com/about/privacy


I use legitimate interests as my lawful basis for holding and using your personal information in this way when you visit my website. I use Google Analytics so that I can continually improve my service to you. You can read Google’s privacy notice here: policies.google.com/privacy To opt out of being tracked by Google Analytics across all websites, visit this link: tools.google.com/dlpage/gaoptout.


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 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.