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 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 email: 6blueroom@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 ZB546553.
My postal address is: Philipp Grote, 6 Ermington Terrace, Plymouth, PL4 6QG
My phone number is: 07707828584
My email address is: 6blueroom@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 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, telephone number and/or email address. Alternatively, your GP or other health professional may send me your details when making a referral 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 1 month. 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. All counselling and psychotherapy in the UK is confidential, subject to the constraints of English law and ethical practice. As a counsellor I have a legal duty to report anything to do with terrorism or acts of terror.
If my client were to disclose matters involving a serious/life-threatening risk of harm to self or others, I might have to act on it. If something like that came up, I would talk with my client about it. Where possible, I would not break confidence without my client’s prior knowledge and, ideally, consent.
I adhere to the ethical framework of the British Association of Counsellors and Psychotherapists (BACP), which is available here: https://www.bacp.co.uk/media/3103/bacp-ethical-framework-for-the-counselling-professions-2018.pdf
I keep a record of your personal details to help the counselling services run smoothly. These details are kept securely on a hand-written piece of paper locked away in a secure location and are not shared with any third party. These details include our Working Agreement (or Counselling Contract), as well as a code by which I can identify the session notes of our meetings.
I keep separate written notes of each session, these are kept in handwriting in a separate securely locked location. I do not use your full name or other identifying details about you in these hand written notes. For security reasons I do not retain text messages for more than one month. If there is relevant information contained in a text message, I will create a hard copy and keep this with my client notes. Likewise, any email correspondence will be deleted after one month if it is not important. If necessary, I will make a hard copy and store it with my client notes.
After counselling has ended.
Once counselling has ended your records will 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.
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.
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.
I do encourage my clients to keep their own notes and reflections of the work they do in their sessions with me, as I write my notes as a memory aid, comprehensible to myself, written by my own hand. If a client would like to have a summary of our work together, I encourage them to discuss that with me.
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 6blueroom@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. I send my emails using encryption and I store all of my files in a securely locked filing cabinet.
Visitors to my website
When someone visits my website, I do not use a third party service to collect standard internet log information and details of visitor behaviour patterns. My website is hosted on a Google domain. You can find Google's privacy notice here: https://sites.google.com/view/newfreeapps/privacy-policy. However, I have minimized all interactions on my website to exclude the need for you to submit any personal data. Google may still use cookies, which if you accept them, will track some information on how you access my site.
I do not use google analytics to extract data of how you use my website.
No user-specific data is collected by me when you use my website.