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 Counselling Wiltshire

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Privacy Policy

Overview - last updated February 2025

  

Privacy / General Data Protection Regulations Policy

The General Data Protection Regulation (GDPR) is concerned with the personal information about you that we collect, store, and share. This page details my GDPR policy.

Personal Information I may collect as part of your assessment or therapy.

· Name.

· Gender (or preferred identity).

· Age.

· Date of Birth.

· Relationships & Progeny.

· Occupation.

· Address.

· Telephone/SMS number (plus permission to send SMS & leave voice message).

· Email address.

· Counselling History.

· Medical conditions relevant to counselling.

· Prescribed medication.

· Your concerns/difficulties.

· Brief notes or diagrams or session summaries

How we will store your Personal Information.

Storage Methods.

· Paper or Digital: written notes or diagrams or session summaries (described below).

· Smartphone: We store your mobile number under first name only that backs up to my private Drive. This allows us to contact you in case of emergencies.

· Email/SMS/WhatsApp: your email address and correspondence will be stored in our email account (currently GMail) by nature of our joint communications. Your telephone number may be stored in our SMS or WhatsApp app should we exchange messages this way, at a future date and by specific arrangement. Electronic correspondence will also be held by the corresponding app (Gmail, Phone's SMS, WhatsApp).

· Website: Your initial contact information is stored as part of a list at the back of my website, and is only used to momentarily collect & send it to my Gmail account for the purposes of our initial contact.

Documents Held

Ø Paper

Contact Sheet

Client Code (linking documents)  

Some of our therapists use paper - Written notes or diagrams or session summaries 

Ø Electronic

Contract/Agreement

GDPR Agreement

Contact Name & Telephone: Email/SMS/WhatsApp.

Assessment & Counselling notes

Some of our therapists use digital - Written notes or diagrams or session summaries 

How I may Process/Share your Personal Information.

Consultation.

We seek regular consultation with an in house Counselling mentor / external Counselling supervisor qualified in this process. The consultation process is for the therapists practice (rather than seeking instruction on working with you). In order to protect your privacy, the consultant will not know you personally nor professionally. We may refer to you by a first name, and we may refer to information verbally when it's helpful to my professional processes.

Therapeutic Will.

Your name and contact details will be shared with a Therapeutic Executor. This is so that you will be contacted on the event of  illness or death, should you still be in therapy with us.

Emergencies.

If your health is in jeopardy we may share your contact information with an emergency healthcare service (e.g. Mental Health Crisis Team or ambulance should you collapse unexpectedly during a session). If we have become aware of your intent to cause harm to another person/organisation (e.g. terrorism), the law requires that we inform an authority without seeking your permission. In such a situation, the law may require that we share your personal information without your knowledge (known as: whistle-blowing).

Erasing your Information.

When we have finished working together, we will erase electronic copies of your information & correspondence within three years. We will hold onto your written information for up to three years past the end of our working together. This is so that we have a reference of our work in situations such as you returning to counselling in the future. After this time has passed, we will shred or delete this information.

Your Rights.

You have the following rights...

· To be informed what information we hold (i.e. this document).

· To see the information, we hold about you (free of charge for the initial request).

· To rectify any inaccurate or incomplete personal information.

· To withdraw consent to me using your personal information.

· To request your personal information be erased (though we can decline whilst the information is needed for us to practice lawfully & competently).


 

Artificial Intelligence (AI) Policy for Counselling Wiltshire

Introduction

At Counselling Wiltshire, we are committed to enhancing our therapeutic services through the responsible integration of Artificial Intelligence (AI) technologies. This policy outlines the framework for the ethical and effective use of AI in our practice, ensuring that client welfare, data privacy, and professional integrity remain paramount.

1. Purpose

This policy aims to provide clarity on how Counselling Wiltshire utilizes AI technologies to support therapeutic services, ensuring compliance with ethical standards and data protection regulations.

2. Scope

This policy applies to all therapists, administrative staff, and any third parties involved in the transcription and analysis of therapy sessions using AI tools within our practice.

3. Lawful Basis for Data Processing

In accordance with the General Data Protection Regulation (GDPR), our processing of personal data is based on the following lawful bases:

  • Contractual Necessity: Processing is necessary for the performance of our contract with the client. This includes maintaining accurate and adequate records of therapy sessions to deliver effective services.
  • Legitimate Interests: Processing is necessary for the legitimate interests of Counselling Wiltshire, such as ensuring high-quality care, adhering to ethical standards, and fulfilling insurance requirements. These interests do not override the rights and freedoms of our clients.

4. AI Integration in Therapeutic Practice

We utilize AI technologies to support and enhance the therapeutic process in the following ways:

  • Session Transcription and Analysis: Therapy sessions may be transcribed using secure methods. These transcripts are anonymized to remove personally identifiable information before being processed by AI tools. The AI analyzes the anonymized transcripts to identify recurring themes, patterns, unmet needs, and potential triggers. This analysis aims to provide insights that can inform therapeutic strategies and support client progress.
  • Resource Identification: AI assists in identifying relevant therapeutic resources tailored to individual client needs, thereby streamlining the therapeutic process and enhancing client engagement.

5. Data Privacy and Confidentiality

We prioritize the confidentiality and security of client information in all AI-related activities:

  • Anonymization: All session transcripts are anonymized prior to AI analysis to protect client identity.
  • Data Retention: Anonymized transcripts are retained only for the duration necessary to complete the AI analysis and are subsequently deleted. AI-generated summaries, once reviewed and approved by the therapist, are incorporated into the client's confidential records and stored in compliance with the General Data Protection Regulation (GDPR).
  • Data Security: We implement robust technical and organizational measures to safeguard data against unauthorized access, alteration, or deletion.

6. Client Information

Clients are informed about the use of AI technologies in their therapy, including the purposes and benefits. This ensures transparency and allows clients to make informed decisions regarding their care.

7. Ethical Considerations

Our use of AI is guided by ethical principles to ensure client welfare:

  • Transparency: We maintain openness with clients regarding the role of AI in their therapy and provide clear explanations of AI-derived insights.
  • Beneficence and Non-Maleficence: AI tools are employed to enhance therapeutic outcomes and are carefully evaluated to prevent any potential harm.
  • Professional Oversight: Therapists retain full responsibility for clinical decisions and ensure that AI-generated insights are used appropriately within the therapeutic context.

8. Mitigation of Potential AI Misuse

To address challenges associated with AI integration:

  • Over-Reliance: AI serves as a supplementary tool and does not replace the critical thinking and expertise of therapists.
  • Data Privacy Concerns: Strict protocols are in place to protect client data, and AI tools are designed to operate without accessing or storing sensitive personal information.
  • Education: We provide resources and training to our staff and clients on the ethical use of AI, ensuring an understanding of its benefits and limitations.

9. Training and Continuous Improvement

We are committed to ongoing learning and development:

  • Staff Training: All staff members receive training on this AI policy and the ethical use of AI in therapeutic practice.
  • Continuous Learning: We stay informed about advancements in AI and regularly update our practices to align with current ethical standards and technological developments.

10. Policy Review and Updates

This policy is subject to periodic review to ensure its relevance and effectiveness:

  • Regular Review: The policy will be reviewed annually or as needed in response to technological advancements or changes in legal and ethical guidelines.
  • Stakeholder Feedback: We welcome feedback from clients and staff to inform policy updates and improvements.

11. Contact Information

For questions or concerns regarding this policy, please contact:

Trauma Informed Ltd
Yeats Close, Blunsdon St. Andrew, Swindon, SN25 4EH, United Kingdom
Contact Form

By implementing this policy, Counselling Wiltshire aims to responsibly integrate AI technologies into our therapeutic practices, enhancing client care while upholding the highest standards of ethical and legal compliance.


Thank you for reading this information

Privacy Policy - nitty gritty

What happens to the data you share?

What happens to the data you share?

What happens to the data you share?

  

Your privacy and protection is important to me and your work. The General Data Protection Regulations are reviewed regularly and advice taken from the ICO about the data collected during the process of therapy.


Currently there is no requirement to be registered with the ICO.


This is because the information held is not considered identifiable as your specific data without additional information which would make it specific to you as an individual. For example a name without a address or date of birth is unlikely to be traceable.


Therefore data is not considered to be ‘collected’ to be ‘processed’ or ‘used’ or ‘shared’. Under these circumstances there is not a requirement to provide a privacy agreement. However because your privacy and your protection is important to me I have taken the decision to register anyway and to share with you what data is supplied and what happens to that data at each stage.




ICO Application Number A8922927

At enquiry stage...

What happens to the data you share?

What happens to the data you share?

  

You provide a first name, sometimes people provide a surname this is not required, an email address and a mobile number.

This information is stored on the business phone.

The email provider is Google – Gmail.

The phone system is provided by Android & Samsung.

The phone has an automatic locking facility and is able to be remotely wiped.

If you make contact via the website www.counsellingwiltshire.com  or www.counsellingwiltshire.co.uk

you will enter some data into a contact form. This data is held securely by GoDaddy the website host at the ‘back’ of the website which is encrypted. The purpose of this data being held is purely a back up system in the event of an enquiry or contact details being lost – such as the business phone being dropped and smashed. 

If you chose to become a member of the website you will be provided with log in details and can request your data be removed at any time.

The data you provide is used solely for the purposes of your enquiry and for the arranging of appointments and as such your first name will appear in the diary at the time of your initial  appointment.

During the work...

What happens to the data you share?

During the work ...reflective notes

  

Your first name will be marked in the diary at the time of your appointments.

Any payments made under your name or someone paying on your behalf, online will be captured on bank statements and as such are treated confidentially by my accountant.

You provide a story or narrative to your experience. This data stays between you and your Consultant. 

Between you and your Consultant, themes and conflicts are established, along with triggers for symptoms. This information (themes, conflicts, triggers & symptoms along with anything clinically significant) is supervised.

Generally this information (themes, conflicts, triggers & symptoms along with anything clinically significant) is presented verbally in supervision. Supervision is provided on a one to one basis with an ongoing supervisor of the practitioners choice according to their theoretical approach.

Notes from supervision are taken in accordance with the BACP ethical practices and refer to the continued professional development of the practitioner rather than the individuals receiving therapy.


During the work ...reflective notes

During the work ...reflective notes

During the work ...reflective notes

 On occasion the themes, conflicts, triggers & symptoms may be captured during or after session to be shared with the individual for reflective purposes.

Sometimes this will be a paper note, captured and sent.  

  

The paper note is then shredded. 

As a rule, notes captured on a chat, or email system are kept for the duration of the work.

Sometimes themes, conflicts, triggers & symptoms will be captured on a digital note on a device called a Remarkable. 

Digital notes of this kind are sent by PDF format and are stored and sent via the same Google platform. A copy of Google Cloud C10 Level encryption aimed at protecting customers data is available upon request.

Digital notes are saved under your first name until the work finishes. 

It is important to note that the information held by way of themes, conflicts, triggers or symptoms are written in such a way that they are highly unlikely in their presentation alone ever to be able to identify a client.

After the work...

During the work ...reflective notes

After the work...

  

Sometimes ending of the work is very clear and agreement is made about any data held. Where the work tails off without a clear ending clients details are archived initially.

Digital notes which were saved under the first name of the client are moved to an archived file and the first name is changed and saved under a reference number. The reference number is noted in the paper diary under your last appointment or a log at the back of the diary for quick reference. 

During the archiving process any information which is deemed unnecessary will be erased from the file.

Chats & Email & Digital Notes are reviewed or removed regularly, until such time they can be provided in the event of a client needing a reminder of the key reflective points. 

Your Consultant Therapist will weigh up the need to keep a copy of any correspondence shared between you beyond the work ending versus the risks of security breaches and any future need you may have for them or you returning to the work. 

Ethical caution will always be deployed. 

Questions

During the work ...reflective notes

After the work...

  

If you have any questions or concerns or wish for your information to be removed please contact me directly on:

Gillycounsellor@gmail.com 

Or by phone on 07716 492 753



  

Gilly Chapell Trauma Psychotherapy Limited

trading as Counselling Wiltshire


BACP Register of Counsellors & Psychotherapists- certificate number 054329 

Company Registration Number 10842054 


www.counsellingwiltshire.co.uk



Chat Bot Privacy

1. Data Collection

When you interact with our website's chatbot, powered by OpenAI, we collect certain

data to provide and improve the service. This includes:

Text inputs you provide during interactions with the chatbot.

Information about your device, browser, and usage to enhance the user experience.

2. Data Usage

The data collected during your interaction with the chatbot is used to:

Provide responses and improve the functionality of the chatbot.

Help us analyze usage patterns and improve the overall user experience.

Please note that OpenAI may process and store some of this data to improve the

performance of its models and services. For more information on how OpenAI handles data, please review OpenAI’s privacy policy.

3. Third-Party Access

OpenAI may have access to the data you provide when interacting with the chatbot, as

they operate the underlying AI model. This data may be used by OpenAI for purposes

such as training and improving the model, adhering to their privacy policy.

We do not share your personal data with any third-party entities other than OpenAI,

except as required by law or in the event of a merger or acquisition.

4. Data Retention

We may retain the data collected through chatbot interactions for as long as necessary

to fulfill the purposes outlined in this privacy policy. If you wish to request that your data

be deleted, please contact us at [your contact information].

5. User Consent

By interacting with the chatbot, you consent to the collection, use, and sharing of your

data as described in this policy. If you do not agree with this policy, you should refrain

from using the chatbot.

6. Security

We implement reasonable security measures to protect your data from unauthorized

access, disclosure, alteration, or destruction. However, please note that no data

transmission or storage system can be guaranteed to be 100% secure.

7. User Rights

You have the right to access, correct, or request deletion of your personal data. If you

wish to exercise any of these rights, please contact us at [your contact information].


Thank you for reading this information


Copyright © 2009 to 2025 Trauma Informed ltd trading as Counselling Wiltshire, Rated therapies, 

- All Rights Reserved. Company Number 10842054 

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