Privacy Policy
Privacy notice
In order to provide you with the best service possible I need to hold your personal contact details and records of your therapy sessions. This privacy notice tells you what I will do with your personal information from initial point of contact through to after therapy has ended. 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 the Data Protection Act 2018, the UK’s implementation of the General Data Protection Regulation (GDPR). I also adhere to the ethical guidelines regarding protecting client privacy and confidentiality set by the British Association for Counselling and Psychotherapy (BACP).
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. 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 therapy sessions) and necessary for a contract with a health professional (in this case, a contract between me and you).
How I use your information
I will never use your personal data for any purposes other than the administration of the therapy service that I am providing to you i.e. to arrange, cancel and rearrange appointments. I will only retain your personal information for as long as is necessary. This is in line with guidance from the Information Commissioner’s Office.
Initial contact:
When you contact me to book your 20 minute first meeting I will collect some brief information to help me to process your enquiry. This will include your name so that I can book the appointment into my diary and also a contact method, for example an email address or phone number. This information is requested so that you could be informed if I was unable to attend an appointment due to unforeseen circumstances. If you do not want to be contacted under any circumstances you do not need to provide a contact method. Alternatively, an organisation such as your employer may send me your details when making a referral or a relative may give me your details when making an enquiry on your behalf. If an enquiry is made and you decide not to proceed I will ensure that all of your personal data is deleted within one month. If you would like me to delete this information sooner please let me know.
While you are accessing therapy:
Your email address or phone number will be used to provide you with written confirmation of your appointment times if you have given consent for this. Your email address and telephone number will only be used to contact you regarding appointment times unless we have agreed that I will also use your email address to email you information that is relevant to your therapy sessions.
Once we have agreed to work together and before your first appointment, I will ask you to complete a new client information form containing your name, address, date of birth, contact information, contact information for your GP, general health information and reason for seeking support. This form is then stored on a password protected hard drive. To fulfill my duty of care towards you while also maintaining your confidentiality I will only contact your GP if it is necessary and should these circumstances arise I would discuss this with you wherever possible before contacting your GP.
Rest assured that what is said in our sessions will be kept confidential. I am a Registered Member of the British Association of Counselling & Psychotherapy (BACP) and I abide by their professional code of ethics. 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. In the event that confidentiality must be broken I will always try to speak to you about this first, unless there are safeguarding issues that prevent this.
Counsellors are required to have regular supervision support so I may discuss our work with my supervisor. This would be done without identifying you and my supervisor is a counsellor who also abides by the BACP’s code of ethics regarding confidentiality.
I keep brief process 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 in a locked cabinet. Your therapy notes are stored separately to your personal details form.
After therapy 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 for three years after therapy has ended. This time frame adheres to BACP guidelines. Three years after therapy has ended your therapy notes will be confidentially destroyed. Your new client information form is confidentially destroyed on ending your therapy sessions.
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 ends. 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.
Data security
I take the security of the data that I hold about you very seriously. My email account is password protected and mobile phones and laptops used to respond to your emails are password protected. 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 screen shot the information and store it on a password protected hard drive, deleting the original from my email account.
Website visitors
By accessing the website, you are consenting to the information collection and use practices described in this privacy notice. Should you choose to contact me using the contact form on the website none of the data that you supply will be stored by the website or passed to any third party data processors. Instead the data will be collated into an email and sent to me over the Simple Mail Transfer Protocol (SMTP). SMTP servers are protected by TLS (sometimes known as SSL) meaning that the email content is encrypted before being sent across the internet. The email content is then decrypted by local computers and devices.
Your rights
Under GDPR, 2018 guidelines you have the following rights: The right to request access to the personal information that I store and process about you. You can ask for corrections to be made to the information held or for your personal information to be deleted. You can also ask me to restrict the processing of your personal information or to object to the processing of it altogether in some circumstances. You can read more about your rights at ico.org.uk/your-data-matters.
If you would like to make a request relating to any of the rights above, please send a request in writing by emailing judelawsontherhiddenapy@gmail.com Please be aware that in certain situations I may be unable to comply with the above requests. For example, if compelled to retain the records by a court of law. Please also be aware that there may be a charge for complying with a request if it is deemed to be excessive in nature.
Queries
‘Data controller’ is the term used to describe the person or organisation that collects and stores and has responsibility for people’s personal data. In this instance, I am the data controller for Jude Lawson Therapy and I am registered with the Information Commissioner’s Office: the registration reference for Jude Lawson Therapy Services is ZB531085 If you have any questions about this privacy policy or the way in which I handle your personal information you can email me at judelawsontherhiddenapy@gmail.com
Complaints
If you have a complaint about how I handle your personal data please do not hesitate to get in touch by email at judelawsontherhiddenapy@gmail.com 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 https://ico.org.uk/make-a-complaint.