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 am a sole practitioner, and 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. I am the ‘Data controller’ for my practice, which is the term used to describe the person who has responsibility for people’s personal data. I am registered with the Information Commissioner’s Office, registration number ZA801574.
I am happy to talk through any questions you may have about my data protection policy and how I look after your privacy. My email address is: bhargreavecounselling@gmail.com
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. 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. 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. 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 or social care or treatment (in this case, counselling), and necessary for our contract.
How I use your information
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, contact details and brief details about your enquiry. If you decide not to proceed after your initial enquiry, I will ensure all your personal data is deleted within 48 hours. If you would like me to delete this information sooner, just let me know. If we do proceed with therapy, I will collect certain sensitive personal information about you to help me offer the appropriate service.
Everything you discuss with me is confidential. That confidentiality will only be broken if there is a serious risk of harm to you or someone else, a court order, or a child protection/other safeguarding issue. I will always try to speak to you about this first if possible, unless there are safeguarding issues that prevent this. I may also discuss, anonymously, elements of our work with my clinical supervisor. Supervision is a requirement by my professional body, the BACP, and my supervisor is bound by the same ethical framework I adhere to, including confidentiality.
I will keep a record of your personal details to help the counselling services run smoothly. These details are kept securely in password protected digital files and/or on password protected private, locked devices, which are not shared with any third party. I will keep brief written notes of each session, these are kept in password protected digital files, and are kept separate from your personal identifiable information. Once counselling has ended your records will be kept five years from the end of our contact with each other, in accordance with my professional insurance policy, and they are then securely destroyed. If you want me to delete your information sooner than this, please tell me.
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. This information is only processed in a way that does not identify anyone. I do not make, and do not allow Google 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. You can read Google's privacy notice here. Like most websites I use cookies to help the site work more efficiently. 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.
Your rights
You have a right to ask for a copy of any information I hold about you, and to object to the use of your personal data in some circumstances. You can ask me to delete your personal information, or correct inaccuracies within it.
You can read more about your rights at https://ico.org.uk/your-data-matters
To make a request for any personal information I may hold about you, please put the request in writing addressing it to bhargreavecounselling@gmail.com. If you have any complaint about how I handle your personal data please get in touch with me by emailing the address given above. If you do not feel this results in resolving your complaint satisfactorily, you can make a formal complaint about the way I have processed your personal information by contacting the Information Commissioner’s Office (ICO) which is the statutory body that oversees data protection law in the UK. For more information go to https://ico.org.uk/make-a-complaint/data-protection-complaints/
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