Privacy Notice
In order to support you in the best way possible, I need to hold personal contact details and records relating to therapy or supervision sessions. This privacy notice explains how I collect, store and use your personal information from the initial point of contact through to after therapy or supervision has ended.
I offer counselling to individuals and couples, and clinical supervision to counsellors, psychotherapists and trainees. This privacy notice applies to personal data collected and processed in relation to individual therapy, couples therapy and clinical supervision.
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 UK General Data Protection Regulation (UK 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 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 requires that I have a lawful basis for processing your personal data. The lawful basis depends on the stage at which I am processing your data.
If therapy or supervision has ended, I rely on legitimate interest as my lawful basis for holding and using your personal information.
If you are currently attending therapy or supervision, or if you are in contact with me to consider working together, I process your personal data where it is necessary for the performance of our contract.
Some of the information you share with me may be classed as ‘special category personal data’. For therapy, the lawful basis for processing this data is that it is necessary for the provision of health treatment by a regulated professional. For clinical supervision, the lawful basis is that it is necessary for the performance of a professional contract and for legitimate professional interests.
How I use your information
I will never use your personal data for any purposes other than the administration and provision of therapy or supervision services, for example arranging session times.
I only retain personal information for as long as is necessary and in line with legal, regulatory and professional guidance.
Initial contact
When you contact me to make an enquiry or to book an initial chat, I collect brief information to help me respond. This usually includes your name and a contact method such as an email address or phone number so that I can arrange the appointment and send joining details.
Sometimes an organisation such as an employer may send me your details when making a referral, or a relative may contact me on your behalf.
If you decide not to proceed after an enquiry or initial chat, I will delete your personal data within a reasonable period. If you would like this information deleted sooner, please let me know.
While you are attending therapy
Your email address or phone number may be used to confirm appointments or to contact you if we need to rearrange a session, where you have consented to this. Sessions usually take place online via Zoom. If you do not join a scheduled session, we may agree that I will attempt to contact you by telephone. If you do not wish me to do this, please let me know.
Before our first session, I will send you an agreement form requesting personal details such as your name, address, date of birth, contact details, and contact details for your GP and an emergency contact. This information is stored securely online and is password protected.
I will only contact your GP or emergency contact if it is necessary to fulfil my duty of care, and wherever possible this would be discussed with you beforehand.
Almost everything discussed in sessions is confidential. There are situations where I may need to break confidentiality, such as if there is a serious risk of harm to you or others, certain serious criminal disclosures, or if I am legally required to disclose information by a court order. I would aim to discuss this with you wherever possible. There are exceptions, for example in some safeguarding situations.
Couples therapy
When I work with couples, the client is the relationship rather than either individual. Personal information is collected from each partner in order to provide couples therapy.
Information shared in sessions is treated as confidential to the couple. I do not usually keep secrets between partners, and this approach is discussed fully within the couples agreement before therapy begins.
Session notes relate to the couple as a unit rather than to either individual separately and are stored securely.
Clinical supervision
If you attend clinical supervision with me, I will collect and store personal information relevant to the provision of supervision. This includes contact details, professional role, training status and supervision records.
Supervision notes may include anonymised references to your client work. You are responsible for ensuring that any client material brought to supervision does not include identifying details. I do not hold identifiable personal data about your clients.
Supervision records are stored securely and retained in line with legal, regulatory and professional requirements.
Records and notes
My records include basic contact information and brief, factual session or supervision notes. Notes are for my use only and do not include identifying personal details. Personal details and notes are stored separately and are password protected.
I attend regular clinical supervision, where themes from my work may be discussed. My supervisor is bound by professional confidentiality and the BACP Ethical Framework.
I also have a clinical will in place. This sets out arrangements for the secure handling of client and supervisee records in the event of my incapacity or death, in line with ethical and legal requirements.
I am registered with the Information Commissioner’s Office. You have the right to request a copy of the personal data I hold about you, and I will respond within one month.
After therapy or supervision has ended
There are professional and legal reasons why records must be retained after work has ended, including regulatory, insurance and accounting requirements.
Session and supervision notes are stored securely for an appropriate period in line with professional guidance and are then confidentially deleted.
Personal details forms are deleted at the end of therapy or supervision, aside from a minimal record required to identify records if necessary.
Third party recipients of personal data
I share a limited amount of personal data with third parties only where necessary to provide services or meet legal obligations, for example my accountant having access to invoices.
Where I work with external suppliers, they are required to use your information only for the task for which they have been contracted. I never share personal data for marketing, sales or research purposes.
If your sessions are funded or arranged by a third party such as an employer, only attendance information is shared for invoicing purposes. Session content remains confidential unless you give written consent.
Data security
I take data security seriously. My email account, devices and online storage systems are password protected and use appropriate security measures. Emails are deleted within a reasonable period unless it is necessary to retain them.
Website visitors
By accessing www.georginasturmer.co.uk, you consent to the information collection practices described in this notice.
If you use the website contact form, the information you provide is sent to me by email and is not stored on the website. Emails are transmitted securely using encryption.
The website uses cookies and Google Analytics to collect anonymous information about website usage, such as page views and visitor numbers. This helps improve the website. Some embedded content, such as Google Maps, may also use cookies. I do not control these cookies.
You can opt out of Google Analytics via Google’s opt-out tools.
Your rights
Under GDPR you have the right to access the personal information I hold about you, to request corrections, to request deletion, to restrict processing, or to object to processing in certain circumstances.
If you wish to exercise any of these rights, please contact me in writing at hello@georginasturmer.co.uk. In some situations I may not be able to comply, for example where records must be retained by law.
More information about your rights is available at ico.org.uk/your-data-matters.
Queries
The data controller is Georgina Sturmer. I am registered with the Information Commissioner’s Office under Deedeedee Limited, registration number ZB518924.
If you have questions about this privacy notice or how I handle personal data, you can contact me at hello@georginasturmer.co.uk or on 07355 436003.
Complaints
If you are unhappy with how I have handled your personal data, please contact me in the first instance. You also have the right to lodge a complaint with the Information Commissioner’s Office at ico.org.uk/make-a-complaint.
Changes to this privacy notice
This privacy notice may be updated from time to time. Please check occasionally for any updates.