In order to support you in the best way possible I need to hold your personal contact details and records of your counselling sessions. This privacy notice tells you what I will do with your personal information from initial point of contact through to after counselling 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 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. 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 our counselling sessions have ended, I will use legitimate interest as my lawful basis for holding and using your personal information.
If you are currently attending counselling with me or if you are in contact with me to consider counselling, 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 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 counselling service that I am providing to you, for example arranging session times.
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.
When you contact me to make an initial enquiry or to book an initial chat, 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 I can send you the details for our meeting.
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, or if we have an initial chat, 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 attending 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. I will also use these details to contact you if we need to rearrange a session time. We will usually meet via the Zoom platform for our therapy sessions. If you do not join the Zoom we will agree that I will attempt to reach you via telephone. If you do not want me to do this, please let me know. I might occasionally send you other information that is relevant to your therapy sessions. Please let me know if you do not want me to do this.
Before our first session I will send you an agreement form, which includes a request for personal details. This form asks for your name, address, date of birth, contact information, and contact information for your emergency contact and your GP. This form is kept securely online and is password protected. To fulfil 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.
I take my duty to my clients seriously, and I want you to feel safe and comfortable. Almost everything that we discuss in sessions is confidential. There are occasions when I might need to break confidentiality and involve another party, such as my Supervisor, or your GP. These instances include if you were to tell me that you were to seriously harm yourself or somebody else, certain disclosures about drug trafficking, road traffic accidents, and other serious crimes, or if I were to receive a court order asking me to disclose information. I will hope to discuss this with you, if I am able to do so. There are exceptions, for example in certain child protection situations.
My client records include basic contact information, along with brief, factual, session notes. The notes help me to keep track of the issues that we are working on, and they are for my use only. They do not include any personal details that could be used to identify you and they are kept separately from the personal details form. These notes are password protected and kept securely online. These records will not be passed on to any third party. I am registered with the Information Commissioners Office. If you need a copy of the information that I hold about you, then please send a written request and I will respond within a month. In line with the BACP’s guidelines, I attend regular clinical supervision, where I discuss themes from my work with clients. My supervisor is a counsellor who also abides by the BACP’s code of ethics regarding confidentiality.
After counselling 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 session notes ensures that I can continue to offer you an efficient service if you make contact after therapy has ended. Your session notes do not include any personal details that could be used to identify you and continue to be stored securely online for seven years after therapy has ended. This time frame adheres with current industry guidelines. Seven years after counselling has ended these notes will be confidentially deleted.
Your personal details form is deleted on ending your counselling 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 counselling ends. Your client reference number corresponds with a client reference number on your session notes and therefore enables me to identify your notes if necessary.
Third party recipients of personal data
I share a limited amount of personal data with third parties in order to provide counselling services to you and to fulfil legal obligations in respect of tax and accounting purposes. For example, my accountant is permitted access to my invoices.
Where I have contracted with a supplier to carry out tasks I have carefully selected which organisations I work with. I state that they do not use your information in any way other than the task for which they have been contracted. I will never pass on your contact details to any third party organisations for the purposes of sales, marketing or research.
If your appointments are paid for or arranged via a third party, for example, your employer the only information shared with the third party is your dates of attendance and non-attendance for invoicing and payment purposes. Details about what is discussed in your appointments will remain confidential and can only be shared if you give me your written consent to do so.
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 and have anti-virus software. Any email correspondence will be deleted within one month if it is not necessary to keep it.
By accessing my website www.georginasturmer.co.uk, 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.
Some page elements are embedded from trusted third parties in order to provide you with Interactive Maps. This makes the website more helpful to you as a site visitor however most of these come with their own cookies. This applies to Google Maps. I do not control these cookies so I cannot guarantee what they do. In many cases the cookies are used to generate identical information to Google Analytics and indeed use Google Analytics, so opting-out of Google Analytics will also opt you out of these cookies too. You can opt out of Google analytics and other Google services here – http://tools.google.com/dlpage/gaoptout and https://www.google.com/dashboard/.
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 email@example.com. Please be aware that in certain situations counsellors 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.
If you have a complaint about how I handle your personal data please do not hesitate to get in touch by email at firstname.lastname@example.org. 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.
Changes to privacy notice
This privacy notice may be updated from time to time, so please check occasionally for any updates.