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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,

• 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 my email jennydark@proton.me

 

‘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 [00012102932]My email address is: jennydark@proton.me

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. These are 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

 

Visitors to my website

 

When someone visits my website, I use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. I do this to find out things such as 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 Google Analytics 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 How Google uses information from sites or apps that use our services – Privacy & Terms – Google

 

I use WIX.com as the content management system for my website - find out about WIX.com and their data protection here: About Privacy | WIX

 

Like most websites we use cookies to help the site work more efficiently. Cookies on used on the website are WIX CMS and Usercentrics for WIX. You have the options to opt out of cookies when you visit the website.

 

If you fill in a form on my website, that data will be temporarily stored on the web host before being sent to me.

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 any initial information you give about your reason for seeking counselling. If you choose to book an initial session, I require you to complete a counselling agreement which includes personal data such as name, contact details, GP details, emergency contact details and information about your health and any previous counselling.

 

While you are accessing counselling.

 

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 and these are kept in a password protected document.

 

After counselling has ended.

 

Once counselling has ended your records will be kept for a minimum of three year but may be kept for up to seven 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 contact me.

 

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 jennydark@proton.me.

 

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. I

 

f 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 by using a secure, end-to-end encrypted email service and password protected documents.

 

Limits to confidentiality in counselling

 

Everything you discuss with me is confidential. Although confidentiality is an ethical commitment there are limits to confidentiality and therefore, I want you to be clear as to what I must report (disclose) to relevant authorities, and what I reserve the right to report if I have concerns about your own or another person’s safety and welfare (a disclosure made in the public interest).

 

In some circumstances it may not be possible or appropriate to obtain your permission before I make the disclosure. In other cases, I may not be able to tell you about a disclosure, for example, if by doing so could interfere with an ongoing police investigation, or where this may give you or another person a warning as in ‘a tip-off’ which might prevent the course of justice. 

 

I have a legal duty to respond to:

• court orders requesting release of records or other information shared with me in counselling/psychotherapy

• police requests for certain types of information, for example, in relation to road traffic offences

I have a legal duty to report:

• terrorism (including the prevent duty)

• drug trafficking

• money laundering

• serious crime, e.g. rape, murder 

I have a duty to report for safeguarding:

• people trafficking/modern slavery

• female genital mutilation

• forced marriage

• other serious concerns relating to safeguarding of other people, especially vulnerable adults or children

 

There is an ethical requirement for me to report according to my discretion

Serious and urgent safeguarding concerns relating to clients, for example:

• imminent risk of suicide, self-harm

• serious risk of harm from another person (for example, in domestic violence), provided if in doing so it does not further increase the risk of harm to the client or their dependents

• harm and neglect of animals

 

Where possible I will discuss with you the need for disclosure and gain your consent for sharing your personal information. In all cases, I will only share with others the minimum needed for a concern to be investigated or acted on. When making a decision as to whether to disclose information, I will seek advice and guidance from my clinical supervisor, experienced peers as appropriate, the legal team of my insurance company and my professional body. I will not share any information with them that could identify you.

 

My clinical will

In the case that I was suddenly incapacitated, my supervisor holds my clinical will and will be provided the means to access client details in order to alert you as to what has happened. If I am no longer able to hold client records, my supervisor will be provided with the means to take over this role and maintain them confidentially for the agreed period of time in order to fulfil a request from any client for their therapy notes.

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