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, 9a Prince’s Street, Brighton, BN2 1RD
- Email: email@example.com
How I collect information from you and what information I collect
In regards to initial enquiries and making appointments, I may collect information about you via telephone, email, text messages or through the information you provide to online directory platforms. Information is also collected through the Client-Counsellor Contract and Client Information Form at the start of therapy. If therapy is online, this will be done via email. I make brief handwritten notes after our sessions.
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, gender
- 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 comply with the requirements of my insurance policy;
- to notify you of any change in appointments or other details related to sessions;
- 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 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 (anonymised) so that I can remain at my best as a therapist;
- to undertake appropriate risk assessments and identity those at significant risk of substantial harm;
- 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 is treated as confidential and can only seen by me apart from in the specific circumstances mentioned below. I discuss my work with my supervisor, but this is anonymised so you cannot be identified. This is a requirement of my professional body and insurers.
The limits to complete confidentiality are related to safety and the law. As such, I may disclose relevant data to third parties for the following reasons:
- If there is a risk of significant harm to yourself or others. In such a case I may contact the emergency services or your doctor. I would always endeavour to 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
- If compelled to do so by any legislation introduced which does not exist at the time of reading these terms.
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:
The Client-Counsellor Contract only includes the personal data necessary for its function with other basic information being recorded on a separate Client Contact Form. Both these documents are kept only as hard copies and are stored in a locked filing cabinet. For online clients, these forms are printed off and the electronic copies deleted.
The notes I take for each session do not directly identify clients but make use of a pseudonym/client code. They are stored separately from the Client-Counsellor Contract and Client Contact Form.
My email account is protected by a strong password which I change at regular intervals. Any emails are printed off regularly with the electronic copies being deleted. My computer is password protected and is completely private; it has no other users. It is protected by professional antivirus software and a firewall which is regularly updated.
Only information needed for contact is stored on my phone. The phone is protected by a passcode. I recommend that you do not send any sensitive information via text or email as these media are subject to outside risk.
Your name may appear against payments made. This is kept securely on my bank’s website or on Stripe.
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.
If no appointment is booked or an initial session is cancelled more than 48 hours beforehand, I delete emails and texts and destroy any handwritten telephone communication record after 7 days from point of contact.
If an initial session is cancelled with less than 48 hours’ notice or you do not attend, I will delete email and texts and destroy any handwritten telephone communication record after 30 days. This is to enable me to contact you regarding payment of the cancellation fee.
To maintain our therapeutic relationship the only contact outside of the counselling sessions is for cancellations, rearranging sessions or if you wish to inform me you are running late. Within 5 working days these will be deleted, when I have handwritten the content of the emails, text or voicemail into your case notes.
All remaining data will be destroyed seven years after our last point of contact, as required under contract law and my insurance policy.
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: firstname.lastname@example.org
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.