Privacy Notice

Consent to Hold Personal Data

I am committed to ensuring I protect your privacy and will seek explicit consent to hold personal data about you and only for the purposes of providing counselling or supervision to you. I may also use anonymised clinical data you provide me with for the purposes of providing the best possible service to you.

When you make contact, you will be asked to provide certain information. You can be assured that this information is held and only used in accordance with data protection and ethical principles as in the British Association for Counsellors and Psychotherapists (Ethical Framework for the Counselling Professions: July 2018).

You have the right to access information I hold about you. If you wish to read your notes you can do in a session, however they remain securely with me. After we have finished counselling or supervision those notes will be securely and completely destroyed. I am registered with the Information Commissioners Office (ICO).

Initial Contact

I will collect the following information:

> Name

> Date of birth

> Contact information (address, telephone, email etc)

> Other information relevant to you engaging in counselling with me, e.g. the name of your Doctor, medical practice and number

> Any relevant information about illness, medication and disability which will affect your counselling

> Your next of Kin and telephone number – Please ensure they are aware and in agreement that I have their name and number

This information is collected on a paper-based record and then held securely locked away until the end of counselling or until there is an amendment such as a change of address.

Free Consultation

At the initial consultation you will be asked for informed consent to give me permission to process your data and any contacts you have given me. I will also ask to use any anonymised data to evaluate the counselling and improve the service. You will have the right to decline this.

Notes

Your notes are anonymised and your identity is protected. The notes are not shared with anyone unless I am legally required to do so or you ask me to share them with a third party, which I have the right to refuse to do so. You have the right to view your notes during a session.  The notes remain my property, not the client’s.

The basis for holding this this data is to ensure good governance and to ensure I hold your best interests central to my work. I will meet any legal obligations placed upon me such as a request by the client for their data or information related to safeguarding children and young people at risk or acts of terrorism.

All notes will be stored securely locked away.

Online Counselling and Supervision

For the purposes of online sessions I will use an encrypted email address susan.withers@protonmail.com Please use this email if you wish to keep any details secure. It is possible you can also have your own encrypted email by searching a reputable provider on the internet.

I will use Doxy.me telehealth for video link. In the first instance this will be via a pc, however, should we lose connection, backup will be by a mobile phone.

Notes will be kept in accordance with above. After 6 years of being an adult, notes will be securely and safely destroyed.

All online communication whether email or online sessions is preferred through encrypted communication. You will be responsible for ensuring anything that is communicated via yourself is encrypted. I cannot be responsible for information you send to me which you have not sent from encrypted email.

I am committed to making sure your information is secure. I have suitable and appropriate physical and electronic procedures to safeguard and secure the information I collect. I do not share your personal information, unless it is with regards to someone supporting you on your behalf but only if I have your consent. This will be discussed with you.

Online - Children and Young People

It is necessary that children and young people have secure and private access to online communication. It is preferable to have their own email address for online sessions and they have a private environment to have the session in.

 

Privacy Notice

1. How we use your personal data

We are committed to protecting your personal data.

We will use your sensitive personal data (that is the data you completed in the form of assessments and questionnaires for the purposes of providing our services to you or if we need to comply with a legal obligation.

We will use your non-sensitive personal data to (i) register you as a new client, (ii) manage payment, (iii) collect and recover monies owed to us (iv) to manage our relationship with you, (v) send you details of our goods and services.

Our legal grounds for processing your data are in relation to points (i) to (iv) above are for performance of a contract with you and in relation to (iii) and (v) above, necessary for our legitimate interests to develop our products/services and grow our business and to recover monies owed.

We will not share your details with third parties for marketing purposes except with your express consent.

 

2. Disclosure of your personal data

 We may have to share your personal data with (i) service providers who provide IT and system administration support, (ii) professional advisors including accountants, lawyers, bankers, auditors and insurers (iii) HMRC and other regulatory authorities (iv) third parties to whom we sell, transfer or merge parts of our business or our assets and/or (v) [to other professionals for the purposes of discussing your treatment]/[to my supervisor].

We require all of these third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. They are only allowed to process your personal data on our instructions.

 

3. International transfers

 Some of our third party providers are businesses outside of the EEA in countries which do not always offer the same levels of protection for your personal data. We do our best to ensure a similar degree of security by ensuring that contracts, code of conduct or certification are in place which give your personal data the same protection it has within Europe. If we are not able to do so, we will request your explicit consent to the transfer and you can withdraw this consent at any time.

 

4. Data security

 We have put in place security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We also limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breaches and will notify you and any applicable regulator where we are legally required to do so.

In certain circumstances you can ask us to delete your data. See the section entitled ‘your rights’ below for more information.

We may anonymise your personal data (so that you can no longer be identified from such data) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

 

5. Data retention

We will only keep your personal data for as long as is necessary to fulfil the purposes for which we collected it. We may retain your data to satisfy any legal, accounting, or reporting requirements so for example we need to keep certain information about you for 6 years after you cease to be a client for tax purposes.

You have the right to ask us to delete the personal data we hold about you in certain circumstances. See section 6 below.

 

6. Your rights

You are able to exercise certain rights in relation to your personal data that we process. These are set out in more detail at

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

In relation to a Subject Access Right request, you may request that we inform you of the data we hold about you and how we process it. We will not charge a fee for responding to this request unless your request is clearly unfounded, repetitive or excessive in which case we may charge a reasonable fee or decline to respond.

We will, in most cases, reply within one month of the date of the request unless your request is complex or you have made a large number of requests in which case we will notify you of any delay and will in any event reply within 3 months.

If you wish to make a Subject Access Request, please send the request to SUSAN WITHERS ALDER BARN, NETHRCLAY LANE, THURLBEAR, TAUNTON, SOMERSET. TA3 5AX or email info@alderbarntherapy.co.uk marked for the attention of the Data Compliance Officer.

 

7. Keeping your data up to date

 We have a duty to keep your personal data up to date and accurate so from time to time we will contact you to ask you to confirm that your personal data is still accurate and up to date.

If there are any changes to your personal data (such as a change of address) please let us know as soon as possible by writing to or emailing the addresses set out in section 6 above.

 

8. Complaints

We are committed to protecting your personal data but if for some reason you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).

We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.