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. To ensure I am following and communicating the correct procedures, I have copied guidance from my membership body – The British Association for Counselling and Psychotherapy which can be found here. https://www.bacp.co.uk/media/6208/bacp-privacy-notice-guide.pdf

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 statement tells you what I will do with your personal information from initial point of contact through to after your therapy has ended. I am happy to talk through any questions you might have about my data protection policy.

‘Data controller’ is the term used to describe the person/ organisation that collects and stores and has responsibility for people’s personal data. In this instance, the data controller is me. I am registered with the Information Commissioner’s Office. My registration number can be provided on request.

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 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 me and you).

How I use your Information

Initial Contact: When you contact me with an enquiry about my counselling service I will collect information to help me answer your enquiry. This will include your email address or phone number and any other details you wish to provide me with. 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 1 month. If you would like me to delete this information sooner, just let me know

While we are working together: Everything you discuss with me through counselling is confidential unless I feel you are at risk, in which case I will contact your GP. I always take GP details and an emergency contact for safeguarding purposes. In some circumstances, I will inform your GP that you are attending appointments with me. I will always talk this through with you first if this is the case.

Legally, I am obligated to pass on any information, should you share it, regarding the safety of a member of the public, child or vulnerable adult or details about child protection, money laundering, drug trafficking, terrorism or serious crime. I will always try to speak to you about this first, unless there are urgent safeguarding issues that prevent this.

I will keep a record of your personal details to help my counselling service run smoothly. These details are kept securely on my mobile and/or in my email and are not shared with any third party.

I am required by my insurance and membership to the BACP to make brief notes after each counselling session these are handwritten and often written in my form of short hand.

For security reasons I do not retain text messages for more than 6 months after we finish working together. Likewise, any email correspondence will be deleted after 6 months if it is not important. Once our work together has ended your records will be kept for 7 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

With your permission, I sometimes share personal data with third parties, for example, where I have contracted with a counselling associate to carry out specific tasks. In such cases I have carefully selected which partners/associates 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 I 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. The will likely follow the same privacy statement as me.

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: www. 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 lucy.gordon1@outlook.com. 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. 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

Data Security

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. Hand written notes are often coded and kept in a locked filing cabinet. Any digital devices I use to access your information (phone, ipad and laptop) are password protected.

Visitors to my website

When someone visits my website, I use a third party service, wordpress 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 wordpress 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. I use wordpress as the content management system for my. Like most websites they 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.