"A journey of a thousand miles begins with a single step" - Lao Tzu
The General Data Protection Regulation (GDPR)(2018) is a regulation which replaces the Data Protection Regulation (1998). Your rights under GDPR are set out in this notice.
Please read the following, together with any other privacy notice I may provide on specific occasions when I am collecting or processing personal data about you, so that you are aware of how and why I am using your personal information.
Janine Unwin, as director of A Step for Change Ltd, is the data controller registered with the Information Commission Office (ICO).
I, Janine Unwin, as your counsellor/psychotherapist, promise to respect the confidentiality of any personal data you share with me and will always take every effort to protect your privacy. In line with the values and principles of the BACP Ethical Framework (2018) and the BABCP ‘Standards of Conduct, Performance and Ethics’ (2017), I will always be clear how, when and why I collect and process your information; I promise that I will never do anything with your details that you wouldn’t reasonably expect.
This privacy notice explains how I, as your counsellor/psychotherapist at A Step for Change Ltd, will use any personal information I collect about you; received both online and offline and received by you communicating with me face-to face, by phone, email, text or otherwise.
WHAT INFORMATION DO I COLLECT?
So that I may fulfil my contractual obligations to you; I collect information about you when you are referred, or you make application, for counselling/therapy. The information I collect about you can include your name, email address, phone number, date of birth (if relevant) any pertinent medical information and contact information for next of kin if relevant
WHERE DOES THE INFORMATION COME FROM?
I only hold the data given to me by your referrer when they refer you for counselling/psychotherapy or from you when you apply for counselling/therapy or engage in counselling/therapy.
HOW DO I USE THE INFORMATION ABOUT YOU?
- Purposes of the processing and the legal basis for the processing: I will only use your personal information when the law permits me to. I collect the minimum amount of information about you necessary to fulfil provision of an effective, professional service of counselling/psychotherapy and for welfare reasons as necessary. This may include creating and maintaining a record of your attendance, brief referral details and brief, factual and contemporaneous written session notes- including psychometric measures. These do not include your full name but will contain your reference code or initials.
I, as your counsellor/therapist will not write a report to your GP, college or employer but may, if required, complete a brief discharge summary report, which will require your consent. I may send an invoice to the referring agency, in which you are referred to by initials or a code, which will also require you consent. I may send copies of any invoices from counselling/therapy, in which you are referred to by initials or a code, to my accountants. This is to comply with HMRC and will also require your written consent.
HOW IS YOUR INFORMATION STORED?
This information is mainly stored in the form of written documents securely stored at the home of your counsellor/psychotherapist and, if stored in digital form, on a password protected computer. Any information that is stored remotely is stored in compliance with the GDPR (General Data Protection Regulation,2018).
HOW LONG WILL MY INFORMATION BE HELD?
The information will only be retained for as long as I need it to fulfil the purposes I collected it for and for as long as is legally necessary after your final appointment and in accordance with the GDPR. To determine the appropriate retention period for personal data, I consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which I process your personal data and whether I can achieve those purposes through other means, as well as the pertinent legal requirements.
WHO WILL USE YOUR PERSONAL INFORMATION?
Information will only be shared with those that “need to know” the information at the appropriate time. If any of your personal information is to be shared, I will obtain your prior consent. Most things you discuss with me as your counsellor/ therapist will not be repeated to anyone else, but there are several exceptions to total confidentiality. The confidentiality boundary may have to be breached if; • A court order requires disclosure for legal proceedings. • You give consent to disclose the information. • You threaten to injure or cause danger to another person. • You disclose information about abuse of a child. • You express strong suicidal tendencies. • You develop severe mental illness. • You are engaged in criminal activity. • You disclose information which is under statutory obligations regarding terrorism, proceeds of crime, drug trafficking and money laundering. This is for protection of both yourself and myself, as your counsellor/therapist. Normally, I will speak to you first if there is a need to breach confidentiality but if the risk is sufficiently acute, information may need to be passed on directly to the appropriate person/agency.
In accordance with the BACP ‘Ethical Framework for the Counselling Professions’ (2018) and the BABCP ‘Standards of Conduct, Performance and Ethics’ (2017); I must receive regular supervision from an appropriately qualified and experienced person. I may discuss aspects of your work in supervision but will take steps to ensure that you are not personally identifiable.
All personal data will be stored in accordance with the General Data Protection Regulation (2018). and under this, you have the right: • to access your notes held containing personal data. • to access a copy and explanation of your personal data. • to request correction or erasure of your personal data, in certain circumstances. • to request limiting or ceasing data processing of your personal data, where applicable. • to compensation for substantial damage or distress caused by data processing, where applicable. • In the event of a breach of data, I must notify you of any risk within 72hrs from point of breach. Please note: Unfortunately, the transmission of information via the internet is not completely secure. Although I will do my best to protect your personal data, I cannot guarantee the security of your data transmitted to my email; any transmission is at your own risk. Once your information has been received, I will use strict procedures and security features to try to prevent unauthorised access.
Your personal information will not be shared with any third parties without your prior consent, nor will it be sold or traded. I will not send you mailings on behalf of other unrelated organisations.
CHANGES TO THIS PRIVACY NOTICE This privacy notice is kept under regular review.
ACCESS TO YOUR INFORMATION AND CORRECTION I want to ensure that your personal information is accurate and up to date. Please contact me to correct information you think is inaccurate.
HOW TO CONTACT US
Please contact me if you have any questions about this privacy notice or information held about you: •By email: firstname.lastname@example.org •By telephone: 07704422883 Or write to me at the registered address (below) You have a right to complain to the ICO if you think there is a problem with the way I, your counsellor/ therapist, handle your data, at: Information Commissioner's Office (https://ico.org.uk/global/contact-us/ ) Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF Tel: 0303 123 1113 (local rate) or 01625 545 745 (national rate)
You will need to provide written consent to the fair and lawful processing of personal information under the General Data Protection Regulation (2018).
I,____________________________ confirm that I have read this privacy notice and give my written consent to the fair and lawful processing of my personal information for the purpose of record keeping of my work under the General Data Protection Regulation (2018). This will include: The creation and maintenance of a record of your attendance and brief, factual and contemporaneous written session notes. The sending of anonymised invoices from our work
I consent to contact by: Text Email Phone Letter
Signature: _________________________ Date:_______________________
J Unwin April 20th 2019.