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 [Ref: ZB721399].
My email address is: counsellingwithlou@protonmail.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 sending you a client details form to collect some basic information. The form asks for your: Name Address Date of birth Pronouns Next of kin GP details Have you had counselling before and if so, was it helpful? Are you on any medication? Is there anything else you feel I need to know? Finally, I ask for your signature before you return this form to me.
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 1 month. 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: a) you are deemed to be at immediate risk of harming yourself or others b) terrorism related information is disclosed including being a member, funder or supporter of a proscribed group including Palestine Action. I am not allowed to notify you before reporting this. if there are serious concerns regarding a child's safety (under the age of 18) if I am legally required by a court case to provide my notes, during which I will seek to redact as much information as possible I will always try to speak to you about this first, unless there are safeguarding issues that prevent this.
I will keep a record of your personal details to help the counselling services run smoothly. These details are kept securely on my wearekiku client management account, and are not shared with any third party. Your first name is on my Zoom account when I schedule online counselling sessions. The initial of your first name is kept in my handwritten work diary to record dates and times of sessions. The diary does not contain any of my own personal identifying information except my initials as a discreet part of the cover design, so it cannot be traced back to you. When not in use, the diary is kept in a box in my office at my home.
I will keep brief written notes of each session, these are kept on wearekiku.com client management system.
For security reasons I do not retain general emails for more than 1 month. If there is clinically relevant information contained in an email I will log it in the 'general notes' section of your client record on wearekiku.com and then delete the email.
After counselling has ended
Once counselling has ended your records will be kept for 7 years in my wearekiku.com archive 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. I will then confirm to you when your data has been securely deleted. Third party recipients of personal data
I sometimes share personal data with third parties, for example, where a client has asked me to write to their GP. If this happens, I will email the letter directly to you the client, for you to print and send onto your GP on my behalf. This way, you are responsible for sharing your own data.
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 it, 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 counsellingwithlou@protonmail.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.No personal data is ever kept at my office above Centre Paws, except for my diary which may have your initial in it. Your details are only ever kept on my wearekiku.com client management system account and nowhere else.
When I share financial information with my accountant for tax returns, I either securely obscure the names of clients who have made bank transfers before I share bank statements, or I will share the data as a spreadsheet simply saying the date you paid, the amount, and the words 'client fee' as a description so you are anonymised to my accountant.