This Policy was last updated in May 2018 in line with the General Data Protection Regulation (GDPR) reform that is due to take effect from May 2018. The reform sets out more rights for individuals and greater transparency in how personal data is processed. My lawful basis for processing your personal data is set out in Article 6 of the GDPR: (a) Consent: ‘the individual has given clear consent for you to process their personal data for a specific purpose.’
I will only ask for personal information that’s needed to provide a counselling service which may include your name, address, date of birth, contact information, personal and medical history for example and those whose personal data you have with express authority disclosed to me (e.g. next of kin) whenever you complete an online or paper form, make a telephone enquiry with me, or visit my practice to receive services. If you submit an online enquiry you will be required to agree to the terms of this Policy which include permitting me to contact you for the purposes of the related enquiry via the contact means of which you provide me with the details of. i.e. email address, telephone number, etc.
I will obtain some personal data (e.g. name and contact details) when you contact me for any reason, or to make an appointment). I may hold sensitive personal data if you provide me with such information and it is relevant for your case. Any sensitive personal data obtained and recorded will only be done so with your explicit consent and as part of the work.
I will use the personal data you disclose to me for making contact with you and for the purposes of the work. In extreme circumstances (e.g. if you are taken ill in a session) and with your permission I might contact your next of kin.
I am a member of British Association for Counselling and Psychotherapy (BACP) and as such am bound by the Ethical Framework for Good Practice in Counselling and Psychotherapy upon which a counselling contract is based. I will provide the highest level of confidentiality possible according to the law and the Codes of Ethics of BACP. To work ethically I will discuss your case with my supervisor, however identifying details are changed to maintain confidentiality. With your permission, I may use sessional material for training purposes and examinations, however all identifying details are changed to maintain confidentiality.
Confidentiality may need to be broken in the following circumstances:
Depending on the particular circumstances, I would always aim to discuss this with you before taking any action.
Marketing and Opting-in
Please be aware that I will not sell or otherwise disclose any personal data provided to me to any other party.
Disclosure of Personal Data
I may disclose personal data which you provide to me to law enforcement agencies in connection with any investigation to help prevent unlawful activity. In situations of public interest, I would have a legal obligation to disclose information without your consent and also would not be able to inform you prior to taking any such action, e.g. certain illegal activities, acts of terrorism and child protection issues.
Keeping Data Secure
I currently safeguard personal data by storing it in a locked cabinet or on a device protected by a password. Whilst I will use all reasonable efforts to safeguard such personal data, you acknowledge that the use of the internet is not entirely secure and for this reason I cannot guarantee the security or integrity of any personal data which are transferred from you or to you via the internet. To maintain confidentiality sessional notes are identified with a number only and you are referred to as ‘the client’.
By entering into counselling work with me you agree that I can process and store your personal information in connection with this agreement including data collected from the sessions.
I may record sessions with you for the purpose of clinical supervision, training or for an exam. I will be responsible for the recordings and keep them safely and securely stored so that nobody else can access them. Recordings will be destroyed after use.
Express permission from you will be requested and you will be asked for written consent. You are under no obligation to agree to recordings and can withdraw consent at any time. Declining recording will not impact on counselling and you will not be put under any pressure to consent.
Information About Other Individuals
If you give me information about others, you confirm that the other third party person has consented.
Under the third party authorisation, the other person can:
Such authorisation will remain in place until this has been revoked, either by verbal or written communication.
You have the right to request access to your personal data which I process.
This formal request is made under the DPA and is referred to as a Subject Access Request. If you wish to exercise this right and make a Subject Access Request, you should;
You have the right to require me to correct any inaccuracies in your data free of charge. If you wish to exercise this right, you should:
You have the right to complain to the ICO if you think there is a problem with the way I am holding your data.
I will only process your personal data providing you have given your consent for me to do so. Session notes and contact information for clients I work with will be held for 7 years and then destroyed.
My Contact Details
I welcome your feedback and questions. If you wish to contact me, please send an email to firstname.lastname@example.org or call us me on 07377 470 640.
I may change this Policy from time to time. You should check this policy occasionally to ensure you are aware of the most recent version which will apply each time you deal with me.