PRIVACY NOTICE (DATA PROTECTION)

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 comply with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations (PECR). 

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 your information to me. 

• How long I store your information for. 

• Whether there are other recipients of your personal information. 

• Whether I intend to transfer your information to another country. 

• Whether I do automated decision-making or profiling. 

• Your data protection rights. 

I am happy to talk about any questions you might have about my data protection policy and you can contact me via counselling@tillyline.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. 

My business is registered with the Information Commissioner’s Office (Registration number ZB589025). 

My email address is: counselling@tillyline.co.uk 

 

My lawful basis for holding and using your personal information 

The UK GDPR requires that I 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’. My lawful basis for processing personal information during counselling is that it is necessary for the performance of a contract between us. Where I process special category data relating to your health or wellbeing, I do so under Article 9(2)(h) UK GDPR for the provision of health or social care. 

 

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, email address and phone number.  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 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 there are legal or ethical obligations to disclose, 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.  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 process of counselling run smoothly.  This includes details of your GP and an emergency contact.  These details are kept securely on an external password-protected hard drive which is stored in a locked filling cabinet that only I have access to.  Your details are not shared with any third party.  

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 the locked filing cabinet. Your therapy notes are stored separately to your personal details form.   

For security reasons I do not retain text messages for more than one month.  If there is relevant information contained in a text message I will make a note of it and keep the locked filling cabinet.  Likewise, any email correspondence will be deleted after one month if it is not important. If necessary I will print the email and keep this in the locked filling cabinet. 

After counselling has ended: 

There are reasons why counsellors are required to keep records after therapy has ended. For example, in the case of financial transactions personal information must be retained for as long as legally required in respect of 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 and continue to be stored securely in a locked filing cabinet that only I have access to for seven years after therapy has ended. This time frame adheres with current industry guidelines. Seven years after therapy has ended your therapy notes will be confidentially destroyed. 

Your personal details form is confidentially destroyed on ending your therapy sessions. Please note that I need to keep a record of your name, date of birth and your client reference number for seven years after therapy has ended. Your client reference number corresponds with a client reference number on your therapy notes and therefore enables me to identify your therapy notes if necessary. 

 

Third party recipients of personal data 

I use third-party service providers to support the delivery of my services.  My banking services are provided by Mettle. My email and IT services are provided by Microsoft and Google. My mobile phone service is provided by EE. 

These organisations may process personal information on my behalf as part of the services they provide. They only process personal information where necessary and in accordance with their own data protection obligations. Where they act as data processors, they do so under contractual arrangements that comply with UK data protection law. 

If your appointments are paid for or arranged via a third party, for example, your employer the only information shared with the third party is your date of attendance and non-attendance for invoicing and payment purposes. Details about what is discussed in your appointments will remain confidential and can only be shared if you give me your written consent to do so. 

 

International transfers of personal data 

I do not routinely transfer personal information outside the United Kingdom. If, in the future, I use a service provider that processes personal information outside the UK, I will ensure that appropriate safeguards are in place to protect your personal information in accordance with UK data protection law. 

 

Automated decision-making and profiling 

I do not use automated decision-making or profiling when processing your personal information. 

 

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, and, where applicable, to request that your personal information is transferred to another organisation or provided directly to you in a portable format.  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 counselling@tillyline.co.uk.  I will normally respond to requests relating to your personal information within one month.  Please be aware that in certain situations counsellors may be unable to comply with the above requests. For example, if compelled to retain the records by a court of law.  Requests are normally provided free of charge. However, a reasonable fee may be charged where a request is manifestly unfounded or excessive, particularly if it is repetitive. 

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 appropriate technical and organisational measures to protect personal information against unauthorised access, loss, misuse or disclosure.  My email account is password protected and mobile phones and laptops used to respond to your emails are password protected and have anti-virus software. Any email correspondence will be deleted within one month if it is not necessary to keep it. If it is necessary to retain the information I will print the email and store it securely in a locked filing cabinet that only I have access to.