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17th December 2018 

Privacy Policy

Will This Website Collect my Data?
If you choose to contact me using the link on this site an email will be sent directly to me. The contact form will capture your name, email address and the IP address of the computer you use to make the enquiry. The email will also include any information you choose to share with me at that time. The website provider will only retain the information until they are satisfied your email has been successfully delivered to me. At that point it will be deleted. No cookies are captured.

I am registered with the Information Commission Office and abide by the ethical code of practice of the BACP.

Lawful Basis for Processing Personal Data
•The client gives consent for contact information to be held in order for me to communicate with them between sessions.
•Session information is held that is in the legitimate interest of the client to ensure safe, ethical monitoring and therapeutic processing of the work.
•Sharing information with a GP, or similar professional, is only done when it is in the vital interest of the client to protect their life or well-being.

Data Held
•Name, email address, phone number, address, GP.
•Personal / medical history deemed of relevance by the client.
•Session and process notes which are identifiable only by a reference code.

Where does the Information The Counsellor Hold Come From?
•All information is given to me directly by the client, verbally or in writing.
•If the client uses an online contact form (such as the one on this website) the information they supply will come via that forum.

How Does The Counsellor Seek Consent and Communicate About Privacy?
•Clients are provided with privacy information verbally, with key details in writing, during the initial consultation. Written copies of this full policy are provided on request and are available via my website.
•Consent is requested as part of the contracting process.

Who Does The Counsellor Share Information With?
•Information is for my use only.
•In the event of my death, or severe incapacitation, information will be shared with my clinical executors for the sole purpose of informing and supporting the client in a safe and professional manner, in line with ethical practice.
•Non-identifiable information regarding the process of my work is shared with my supervisor.
•The GP only if I am concerned for the client’s immediate well-being, or that of someone else. Where possible, I will discuss this with the client in advance.
•With a client’s express written request, I may provide them with written evidence of the broad fact of their attendance for their personal use.

How does The Counsellor Seek, Obtain and Record Content?
•My website and advertising agency, Counselling Directory, which provides contact links to my website.
•Clients phone me directly and this leaves a number on my phone.
•I hold active client phone numbers on my phone which has a security code access the numbers are identified by first name and initial.
•Emails are sent by clients to my work email address which is held on my home PC, phone and iPad. These are deleted when the information is dealt with.
•I take written details at the time of the first consultation.
•Changes to information are made if a client informs me of changes of contact or GP.
•Clients are entitled to withdraw their consent to my holding their information at any time.

Why does The Counsellor Hold a Client’s Data?
•For contacting a client for the purposes of our work.
•For contacting the client’s GP, with their written consent.
•To record session notes to allow for accountability and monitoring of the work by me according to ethical practice.

Where does The Counsellor Hold Information?
•Written information is kept locked in a file.
•Information with identifiable details are kept locked separately from session or process notes and are double locked.
•Written information is held for 7 years and then destroyed by shredding.
•Any information not required (e.g. an enquiry that does not move forward to an appointment) to be held is shredded.
•Phone numbers with first name and Surname initial only are held in a password protected phone.
•Emails are held until the information has been recorded elsewhere.

How does The Counsellor Respond to Requests for Data?
•Clients are entitled to see their own notes and any data I keep regarding them. I can provide a client access to see their notes in my presence if requested.
•Clients are entitled to withdraw their consent at any time by notifying me in writing.
•Clients are entitled to lodge a complaint with the ICO or with my professional body, BACP, if they are not satisfied with the way their data is being used.
•A request from an outside agency will be discussed with the client where legally appropriate. I would only provide confirmation of a client’s attendance and only with their written consent required by law to do otherwise.
•In the event of further information being subpoenaed I reserve the right to provide redacted notes to ensure only relevant and factual information is shared.

Detection of Data Breaches
•A data breach could occur in the event of the hacking of my phone or email system or a forcible break-in to my locked records.
•In the event of this happening I will inform all affected client’s immediately.

May 2018