Overview - last updated April 2023
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 will Collect.
· 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 Record
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).
Thank you for reading this information
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
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.
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.
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.
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.
If you have any questions or concerns or wish for your information to be removed please contact me directly on:
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
Copyright © 2009 to 2024 Trauma Informed ltd trading as Counselling Wiltshire, Rated therapies, THERAPY MATTERS
- All Rights Reserved. Company Number 10842054