Fair Processing Notice
This notice explains what information I collect, when I collect it and how I use this. During the course of our activities, I will process personal data (which may be held on paper, electronically, or otherwise) about you and I recognise the need to treat it in an appropriate and lawful manner. The purpose of this notice is to make you aware of how I will handle your information.
- My role regarding your data
- How I collect information from you and what information I collect
- Why I need this information about you and how it will be used
- Sharing of Your Information
- Transfers outside the UK and Europe
- How long I will keep your information
- Your Rights
My role regarding your data
I take the issue of security and data protection very seriously and strictly adhere to guidelines published in the General Data Protection Regulation (EU) 2016/679 which is applicable from the 25th May 2018, together with any domestic laws subsequently enacted.
My business does not meet the requirements to need a Data Protection Officer. However, I am the ‘data controller’ of any personal data that you provide to me. A data controller is defined as someone who collects, stores and processes personal data for a business and is responsible for ensuring compliance with the General Data Protection Regulation (EU) 2016/679. I am notified as a Data Controller with the Office of the Information Commissioner under registration number: ZA374099
For any questions relating to this notice and my privacy practices, please use the contact details below:
- Name: Frey Case-Leng
- Address: c/o Brighton Therapy Practice, 72 Carlton Hill, Brighton, BN2 0JF
- Email: firstname.lastname@example.org
How I collect information from you and what information I collect
I collect information about you through the counselling contract we enter. I also store information through brief notes from our sessions. These notes are anonymised and stored separately from the counselling contract.
I may collect the following information about you:
- Name, e-mail address, telephone number, contact address;
- The name and contact details of whom to contact in an emergency;
- Your GPs details;
- Physical and mental health conditions and medication;
- Religion, ethnicity, sexuality
- Family, lifestyle and social circumstances
- Employment and education
- Political beliefs
- Criminal convictions
Why I need this information about you and how it will be used
I need your information and will use your information:
- to undertake and perform my obligations and duties to you in accordance with the terms of our counselling contract;
- to work within the Ethical Framework of the British Association for Counselling and Psychotherapy (BACP) to which I adhere;
- to enable me to supply you with information and details regarding any services which you may request, if relevant and appropriate to my role as your therapist;
- to contact you in order to send you details of any changes to my suppliers which may affect you;
- to reflect on session content so that I can support, improve and develop the service I offer you as a therapist;
- to take to clinical supervision so that I can remain at my best as a therapist. Any identifying details will be anonymised in this context.
- for all other purposes consistent with the proper performance of my role as your therapist
Only the information relevant to the purpose will be used for each point above.
Sharing of Your Information
The information you provide to me will be treated by me as confidential. However, I may disclose your information to third parties for the following reasons:
- If there is a serious risk of harm to yourself or others. In such a case I may contact the emergency services or your doctor. I would always endeavour discuss this with you first.
- If compelled to do so under the Terrorism Act 2000, section 38B
- If approached by the police in regards to the Road Traffic Act 1991, section 21 (2)(b)
- If compelled to do so by a court order
I will not otherwise share any of the information you provide to me without your consent.
Transfers outside the UK and Europe
Your information will only be stored within the UK and EEA
When you give me information I take steps to make sure that your personal information is kept secure and safe. Information is stored on a computer. This is protected by professional antivirus software that is regularly updated.
The computer is password-protected and only accessible by me. The files are also password-protected. The counselling contract and any notes taken are stored in separate folders with the notes being anonymised so they cannot be connected to the contract. The paper contracts are completely destroyed as soon as they are uploaded electronically.
The records I hold are backed up on an external hard drive which is locked in a safe place to which only I have access.
How long I will keep your information
I review my data retention periods regularly and will only hold your personal data for as long as is necessary for the relevant activity, or as required by law, or as set out in any relevant contract I have with you. Data will be destroyed six years after from our last point of contact, as necessary under contract law.
You have the right at any time to:
- ask for a copy of the information about you held by me in my records;
- require me to correct any inaccuracies in your information;
- make a request to me to delete what personal data of yours I hold; and
- object to receiving any marketing communications from me.
If you would like to exercise any of your rights above please contact me at: email@example.com
Should you wish to complain about the use of your information, you should contact me to resolve this matter in the first instance. You also have the right to complain to the Information Commissioner’s Office in relation to my use of your information. The Information Commissioner’s contact details are noted below:
The accuracy of your information is important to me – please help me keep my records updated by informing me of any changes to your email address and other contact details.