Privacy Policy
Your privacy is very important to me, you can be confident that your personal information will be kept safe, 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) and Data Protection Act (the GDPR). The Data Protection Act 2018 and the Privacy and Electronic Communications (EC)Directive) Regulation 2003.
I adhere to the Ethical Frameworks regarding protecting client privacy and confidentiality set by the British Association for Counselling and Psychotherapy (BACP)
If you would like a copy of the Policy below sent to you please contact me.
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 laws depending on the stage at which I am processing your data. I explain this below.
If you are currently having therapy with me 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
If you have had therapy with me and we have now ended, I will use legitimate interest as my lawful basis for holding and using your personal information.
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 consent, relating to the provision of therapy and is necessary for the provision of a professional contract.
I retain any counselling records to allow for any future reference
How I use your personal information
I will never use your personal data for any purposes other than administration of the therapy service I.e. to cancel or rearrange appointments. I will only retain your personal information as long as is necessary. This is in line with guidance from the Information Commissioner’s Office.
Initial Contact:
When you contact me to book your first appointment I collect some brief information to help me process your enquiry. This includes your name and contact details.
Alternatively, an organisation such as your employer, may send me your details when making a referral or a relative may give me your details when making an enquiry on your behalf.
If an enquiry is made and you decide not to proceed I will ensure that all of your personal data is deleted within one month.
While you are accessing therapy: Your email address or phone number will be used to provide contact during our agreed contract arrangements
First Appointment
At the beginning of your first appointment I will ask you to complete a personal information form containing your name, address, date of birth, contact information and also contact information for your GP. The form is stored in a locked filing cabinet that can only be accessed by myself. Please be aware that I will not routinely contact your GP. I hold a duty of care towards you and will only contact your GP in exceptional circumstances and wherever possible I would discuss this with you prior to making contact.
Rest assured that the content of our therapy sessions will be kept confidential. I am an Accredited Member of the British Association of Counselling & Psychotherapy (BACP) and I abide by their professional Code of Ethics. Confidentiality will only be broken if there are legal or ethical obligations to do so, for example, if you disclose abuse/neglect of a child or vulnerable adult, or say something else that implies serious harm to yourself or others, or if a court of law requires me to disclose information.
In the event that there is a legal or safeguarding issue that requires disclosure of information I will always try to speak to you about this first, unless there is a legal reason that prevents this.
Counsellors are required to have regular supervision and I may discuss our work with my supervisor. This is without identifying you and my supervisor is a Therapist who also abides by the BACP’s Code of Ethics regarding confidentiality.
I keep brief notes of our therapy sessions for the purpose of assisting our work together. The notes help me to keep track of the issues that we are working on and they are for my use only. The notes do not include any personal details that could be used to identify you and they are stored securely in a locked filing cabinet that only I have access to.
After therapy has ended:
There are reasons why counsellors are required to keep records after therapy has ended, in the case of financial transactions personal information must be retained for as long as legally required for tax or accounting purposes.
Retaining your therapy notes ensures that I can continue to offer you an efficient service if you make contact after therapy has ended. Your therapy notes do not include any personal details that could be used to identify you.
Seven years after therapy has ended your therapy notes will be confidentially destroyed, unless there is any legal reason for the notes to be retained for up to 10 years or you are under the age of 18 in which case the notes are retained until you reach the age of 25.
Third Party and Personal Data
I share a limited amount of personal data with third parties in order to provide therapy services and to fulfil legal obligations in respect of tax and accounting purposes.
If your appointments are paid for or arranged via a third party, for example, your employer, the information shared with the third party is your dates of attendance and non-attendance for invoicing and payment purposes. Details of our discussions will remain confidential and will only be shared if you give your written consent to do so.
Data Security
I take the security of your data very seriously. My mobile phone, I pad and MacBook used to respond to your texts, phone calls and emails are password protected.
Website Visitors
By accessing my website you are consenting to the information collection and use practices described in this privacy notice. If you choose to contact me using the contact form on the website none of the data you supply will be stored by the website or passed to any third party data processors. Instead the data will be collated into an email and sent to me over the Simple Mail Transfer Protocol (SMTP) SMTP servers are protected by TLS (Sometimes known as SSL) meaning the email content is encrypted before being sent across the internet. The email content is decrypted by local computers and devices.
The website uses cookies and Google Analytics. Google Analytics is a service provided by Google that gathers anonymous data on how people are using websites and then provides visitor statistics, details of page views etc. This service is used by many website owners to improve their websites.
Some page elements are embedded from trusted third parties in order to provide you with Interactive Maps. This makes the website more helpful to you as a site visitor, however most of these come with their own cookies. This applies to Google Maps. I do not control these cookies so I cannot guarantee what they do. In many cases the cookies are used to generate identical information to Google Analytics and indeed use Google Analytics, so opting out of Google Analytics will also opt out you out of these cookies too. You can opt out of Google analytics and other Google services - http://tools.google.com/dlpage/gaoptout and https://www.google.com/dashboard/.
Your Rights
Under GDPR, 2018 guidelines you have the following rights:
Right to request access to personal information that I store and process about you.
Right to rectification/erasure. You can ask for corrections to be made to the information held or for your personal information to be deleted.
Right to restriction of processing. You can ask me to limit how I use your personal information
Right to object to processing. You can object to processing of your personal data.
Right to data portability. You can ask me to transfer your personal information to another organisation or to you.
Right to withdraw consent. When consent is used as the lawful basis, you can withdraw your consent at any time.
You can read more about your rights at eco.org.uk/your-data-matters. If you wish to make a request relating to any of the above rights please send a request in writing by emailing julia@gosportcounselling.com
Please note that in certain situations counsellors may not be able to comply with requests, e.g. if compelled to retain the record by a court of law. There may also be a charge for complying with a request if it is deemed to be excessive in nature.
Queries
“Data Controller“ is the term used to describe the person or organisation that collects, stores and has responsibility for personal data. In this instance the Data Controller is Julia Carter and I am registered with the Information Commissioner’s Office, Registration Number ZA343909, Gosport Counselling.
If you have any queries about this Privacy Policy or the way in which I handle your personal information you can contact me through the Contact Page on this website.
Complaints
If you have a complaint about how I handle your personal data please don’t hesitate to contact me by email julia@gosportcounselling.com
If you wish to make a formal complaint about the way I have processed your personal data information you can contact the Information Commissioner’s Office (ICO,) the statutory body that oversees data protection law in the UK. For more information go to ico.org.uk/make-a-complaint.
Their helpline number is 03031231113,
Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
I work within the Ethical Framework of Association for Counselling & Psychotherapy (BACP )
Registration number 9173 Julia Carter
Telephone 01455 883300,
Address: BACP, 15 St John’s Business Park, Lutterworth, Leicestershire, LE17 4HB