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, and
• 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: info@freshperspectivescounselling.co.uk

‘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. My ICO reference number is ZA601392.

My phone number is 07464303405.

My email address is info@freshperspectivescounselling.co.uk

My lawful basis for holding and using your personal information

The GDPR states that I must have a lawful basis for processing your lawful 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)

1: 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 your name, telephone number and/or email address. Alternatively, your GP or other health professional may send me your details when making a referral or a 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 14 days. If you would like me to delete this information sooner, just let me know.

While you are accessing counselling

The information discussed in our counselling sessions remains confidential between you and I – and I recognise how important it is for you to view this as a safe space to express your thoughts and feelings.

The only exception to this is if you disclose information which suggests that either you or another person is at an imminent risk of harm. In this situation, I have a duty of care to share this information with statutory safeguarding agencies, for example, your GP. It is for this reason that I ask for your GP’s details. Before breaking confidentiality, I will always inform you first, unless there are safeguarding issues that prevent this.

Please note, it is part of my professional accrediting body’s regulations that I regularly consult with a more experienced counsellor (supervisor) about the work that I am undertaking with clients, to ensure that my practise remains ethical and effective. I will never disclose a client’s name or other identifying information when undertaking such discussions.

I will keep a record of your personal details to help the counselling services run smoothly. These details are kept securely on an encrypted computer owned by me and are not shared with any third party. I will keep brief written notes of each session, these are kept secure in a locked filing cabinet.

For security reasons, I do not retain text messages for more than 28 days. If there is relevant information contained in a text message, I will copy the information onto a file on an encrypted computer owned by me. Likewise, any email correspondence will be deleted after 28 days if it is not important. If necessary, I will copy the information onto a file on an encrypted computer owned by me.

After counselling has ended

Once counselling has ended, your records will be kept for 5 years from the end of our contract with each other and are then securely destroyed. If you want me to delete your information sooner than this, please tell me.

2: Third party recipients of personal data

I sometimes share data with third parties, for example, where I have contracted with a supplier to carry out specific tasks. In such cases I have carefully selected which partners I work with. I take great care to ensure that I have a contract with the third party that states what they are allowed to do with the data I share with them. I ensure that they do not use your information in any way other than the task for which they have been contracted. The third parties I share your information with are the HMRC (for the purpose of auditing my financial information) and the Information Commissioners’ Office (ICO, for the purpose of ensuring my business is compliant with the GDPR).  Information is shared with Microsoft as part of my storage/processing of data using Microsoft Office 365, on an encrypted computer owned by me.

3: 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 info@freshperspectivescounselling.co.uk

If you have any complaint about how I handle your personal data, please do not hesitate to get in touch with me by emailing using 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.

4: Data security

I take the security of the data I hold about you very seriously and as such I take every effort to ensure it is kept secure. For example, I use a locked filing cabinet to keep paper records of session notes. For all electronic storage of information, I use an encrypted computer owned by me.

5: Additional information for website owners and employers

Visitors to my website

When someone visits my website, I use a third party service, WordPress, to collect standard internet log information and details of visitor behaviour patterns. I do this to keep track of the number of visitors to the various parts of the site. This information is only processed in a way that does not identify anyone. I do not make, and do not allow WordPress to make, any attempt to find out the identities of those visiting my website.

I use legitimate interests as my lawful basis for holding and using your personal information in this way when you visit my website.

I use Google Analytics so that I can continually improve my service to you. You can read Google Analytics’ privacy notice here: https://policies.google.com/privacy#infocollect

I use WordPress as the Content Management System for our website.

Like most websites, we use cookies to help the site work more efficiently – find out about our use of cookies here: https://www.freshperspectivescounselling.co.uk/cookies

No user-specific data is collected by me or any third party. If you fill in a form on my website, that data will be temporarily stored on the web host before being sent to me.