Your personal information is important to me and I only use and retain your personal information to provide the services which you have requested from us. I Claudia Smith will be the Data Controller in relation to the personal data held and be registered with the Information Commissioner's Office
I am happy to chat through any questions you might have about our data protection policy and you can contact me via email or phone.
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 we are 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 counsellor and client).
How I use your information
When you contact me with an enquiry about my counselling services I collect information to help me satisfy your enquiry. This will include name, date of birth, phone number, email address. 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 six weeks. If you would like me to delete this information sooner, just let us know.
While you are accessing counselling.
Rest assured that everything you discuss with me is confidential. That confidentiality will only be broken where you give consent for the confidence to be broken or; I am compelled by a Court of Law or where the information is of such gravity, in the case of fraud, crime or serious or imminent harm to the yourself or others including Child Protection issues, breach of the Terrorism Act or Proceeds of Crime Act, that confidentiality cannot be maintained. 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. I hold personal identifying data including name, date of birth, address, telephone number and e-mail address to arrange and contact you in relation to appointments. In addition, I hold GP and emergency contact details. I also retain separate client biographical notes, these will include medical information provided, personal history and session summary. These notes are anonymised with a code which links to the identifying data sheet to retain confidentiality to reflect on the sessions and support the counselling work.
These details are kept securely on password protected laptops and smartphones and are not shared with any third party.
I will keep written notes of each session, these are kept in a locked filing cabinet. For security reasons I do not retain text messages for more than two weeks. If there is relevant information contained in a text message I will record it and keep it with your paper notes. Likewise, any email correspondence will be deleted after two weeks if it is not important. If necessary I will retain it until your counselling has ended.
After counselling has ended.
Once counselling has ended your records will be kept for three 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 that includes The Westway Clinic who manage my in-person counselling booking and payments. 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 we 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.
Where appropriate client work may be discussed in counselling supervision in accordance with ethical practice and guidelines.
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 me. However, to protect the privacy of any other persons mentioned during the sessions clients are not entitled to copies of notes referencing any third party. Once provided you becomes responsible for the privacy of the notes and neither the counsellor or Reigate and Redhill Counselling are responsible for the disclosure of such records.
If you have any complaint about how I handle your personal data please do not hesitate to get in touch with me by emailing or phoning me. 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.
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. All devices e.g. laptops and smart phones are password protected and filing cabinets are locked and only accessible to me.
Data security breaches
If I become aware of a situation where your personal information may have accidentally or maliciously been obtained by a third party, I will notify you within three days. If you are concerned about the way that your information is being held please discuss this with your counsellor. If you are still unhappy you have the right to complain to the Information Commissioners Office.
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 use legitimate interests as my lawful basis for holding and using your personal information in this way when you visit our website.