PRIVACY POLICY
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 tanya@thcounselling.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
[TBA].My phone number is: 07786749104. My email address is: tanya@thcounselling.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 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 [add personal information you record
at this stage]. 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 one 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 I believe that you may be of a danger to yourself or someone else. 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 and are not shared with any
third party.
I will keep written notes of each session, these are kept in a locked filing cabinet in my own office,
For security reasons I do not retain text messages for more
than the duration of our work together.. If there is relevant information
contained in a text message I will keep a hand written copy. Likewise, any email correspondence will be
deleted after one week if it is not important. If
necessary I will keep a hand written copy.
After counselling has ended.
Once counselling has ended your records will be kept for 3 years 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.
Third party recipients of personal data
I sometimes share personal 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.
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 its, 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 tanya@thcounselling.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 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. I use encrypted
devices, locked filing cabinet, recognised encrypted video conference platforms.