Privacy Policy for counselling clients

Under the General Data Protection Regulation (GDPR) I need to explain what data I hold about you, why, and how I use it. I hold data for what GDPR classifies as contractual, legal and legitimate interest reasons:

• Contractual - I cannot offer counselling services without holding data such as your email address or telephone number. 
• Legal - I have a legal obligation to hold data about payments for tax purposes. 
• Legitimate interest - I need to hold and store data in the form of session notes for the purposes of running my practice.

I will hold the following data about you, supplied by you, for the contractual purpose of providing you with counselling:

1. Your name
2. Your mobile number
3. Your email address
4. Your home address
5. Your GP surgery
6. Details of any medication you are on
7. Payment records

I store your data in an electronic spreadsheet. I will keep this information for 7 years to comply with insurance requirements after which time I will delete it. I will only ever use your data for the purpose of providing counselling. The email address I use for counselling activities is used only for counselling activities. I archive emails and I encourage you to keep emails to me brief and factual so that what’s most personal and important to you is discussed in the confidentiality of our sessions, or by phone, rather than by email. I will retain payment receipts for up to 6 years to comply with HMRC accounting rules.

My session notes

I will keep brief handwritten session notes of the main themes that emerge in our sessions to support our work together. I write these notes after sessions, not during. I omit as far as possible any personally identifiable information e.g. your name or the names of family and friends. Session notes are likely to include what GDPR classifies as 'special category data' such as sexuality and ethnicity. If you decide to stop counselling I will keep session notes for up to 7 years to meet insurance requirements. After this time I will shred notes. I do not store session notes electronically nor do I store them with your personal data. 

Under data protection law, you have the following rights:

• Your right of access - You have the right to ask me for copies of your personal information. 
• Your right to rectification - You have the right to ask me to rectify personal information you think is inaccurate. You also have the right to ask me to complete information you think is incomplete. 
• Your right to erasure - You have the right to ask me to erase your personal information in certain circumstances. 
• Your right to restriction of processing - You have the right to ask me to restrict the processing of your personal information in certain circumstances. 
• Your right to object to processing - You have the right to object to the processing of your personal information in certain circumstances.
• Your right to data portability - You have the right to ask that I transfer the personal information you gave me to another organisation, or to you, in certain circumstances.
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You are not required to pay any charge for exercising your rights. If you make a request, I will respond to you as quickly as possible and by law I have one month to do so.

If you have any concerns about my use of your personal information please raise this with me.You can also complain to the ICO if you are unhappy with how I have used your data.  The ICO’s address is:         

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline number: 0303 123 1113