GDPR Privacy Notice

This notice describes what personal data I collect from you and how I store and process it as part of the counselling service I provide. In the course of my practice I will collect, process and store personal data as a data controller.

I would like to reassure you that I adhere to all laws and procedures relating to the General Data Protection Regulation (GDPR) (EU) 2016/679, Data Protection Act 2018 or other applicable data privacy legislation and will only use your personal data to provide you with the specific service or services you explicitly agree to. I am registered with the Information Commissioner's Office (ICO) registration reference ZB036225.

A. 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. 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 appropriately look after any sensitive personal information that you may disclose to me. 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).

B. 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 telephone 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.

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, which are securely kept (see details in section D below). 

For security reasons, I do not retain text messages for more than one month. Likewise, any email correspondence will be deleted after one month if it is not clinically important.

After counselling has ended.

Once counselling has ended, your records will be kept for 7 years (as per the requirements of my insurance policy) from the end of our contact and then securely destroyed.

C. THIRD PARTY ACCESS

I do not disclose any information you provide to any third parties other than as follows:

• I may consult with other professionals involved in your welfare only with your explicit consent;
• If I believe you or another person is at risk of being harmed, e.g. if I am concerned that you are in serious danger of attempting or completing suicide, in imminent danger or temporarily unable to take responsibility for your actions, I would advise the relevant emergency authorities and/or your doctor and/or your nominated emergency contact. Any decision to break confidentiality would not be taken lightly. I will usually consult my clinical supervisor and where possible, advise you as well. You have an ethical and legal right to know the importance of and/or see what is being said about you if you wish and I will make every effort to include you in the process except in circumstances where it would harm you or others to inform you (e.g. child protection situations, mental incapacity, terrorism);
• I may discuss my work in a general way with my clinical supervisor and supervision group in order to maintain high standards of practice. I will never disclose personally identifiable details other than your first name;
• Your name may be contained in financial records and my online diary. It is possible that third parties may have access to those records, for example, an accountant;
• If an accident, illness or death prevents me from being able to contact you, I have nominated a trusted colleague who will be able to access my client list and contact you if necessary. I have documented the procedure to follow in a clinical will and you will be provided with necessary referrals. They will destroy personal and sensitive data and archive clinical notes safely at the appropriate time in line with GDPR requirements;
• I may be required to disclose certain data to regulators or other lawful authorities.
• if I am under a duty to disclose or share your personal data in order to comply with any legal obligation (for example, if required to do so by a court order or for the purposes of prevention of fraud or other crime);
• in order to enforce any terms and conditions or agreements for my services that may apply;
• as necessary in order to protect both my and your rights, property and safety (for instance in relation to fraud protection).

D. SECURITY

I will take reasonable steps to ensure that appropriate technical measures are carried out in order to safeguard the information I collect from you and to protect against unlawful access, accidental loss or damage. These measures may include (as necessary):

• encrypting all data stored electronically with an industry standard encryption method;
• protecting all devices with a password;
• using encrypted email;
• pseudonymising client records;
• securely disposing of or deleting your data;
• regularly backing up and encrypting all data I hold.

I will take reasonable steps to ensure that I am aware of my privacy and data security obligations.

E. WEBSITE VISITORS

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. You can read Google’s privacy notice here.

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 WordPress as the content management system for our website. Find out about WordPress and data protection.

Like most websites, we use cookies to help the site work more efficiently. Find out about our use of cookies via the cookie notice at the bottom of the page.

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 sent directly to me via email.

F. 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 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 enqiries@bluubellcounselling.co.uk.

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 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, the statutory body that oversees data protection law in the UK. For more information go to ico.org.uk/make-a-complaint.