Privacy Notice
Introduction
Your privacy is very important to me and you can be confident that your personal information will be kept safely and securely and will only be used for the purpose it was given to me. I adhere to current data protection legislation, including the General Data Protection Regulation (EU/2016/679) (the GDPR), the Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2003. This privacy notice tells you what I will do with your personal information from initial point of contact through to after your therapy has ended.
I am happy to chat through any questions you might have about my data protection policy and you can contact me via fiona@springwelltherapy.co.uk. ‘Data controller’ is the term used to describe the person/ organisation that collects and stores and has responsibility for people’s personal data. In this instance, the data controller is me. I am registered with the Information Commissioner’s Office ZA732969. My postal address is: 143 Crownstone Road, London, SW2 1NB
My lawful basis for holding and using your personal information
The GDPR states that I must have a lawful basis for processing your personal data. There are different lawful bases depending on the stage at which I am processing your data. I have explained these below: If you have had therapy with me and it has now ended, I will use legitimate interest as my lawful basis for holding and using your personal information. If you are currently having therapy or if you are in contact with me to consider therapy, I will process your personal data where it is necessary for the performance of our contract. The GDPR also makes sure that I look after any sensitive personal information that you may disclose to me appropriately. This type of information is called ‘special category personal information’. The lawful basis for me processing any special categories of personal information is that it is for provision of health treatment (in this case counselling) and necessary for a contract with a health professional (in this case, a contract between me and you).
How I use your information
Initial contact. When you contact me with an enquiry about my counselling services I will collect information to help me satisfy your enquiry. This will include name/ name of you or your child, date of birth, address, telephone number, GP details, details of any medication and details for any professionals currently involved. Alternatively, your GP or other health professional may send me your details when making a referral or a parent or trusted individual may give me your details when making an enquiry on your behalf. If you decide not to proceed beyond an assessment session I will ensure all your personal data is deleted.
While you are accessing counselling. Rest assured that everything you discuss with me is confidential. That confidentiality will only be broken if
If you threaten to cause harm to yourself, I am permitted to reveal information to others (including your parent/carer and outside professionals including your GP and/or statutory services such as social care) if I believe it is necessary to prevent the threatened harm.
If you threaten to harm someone else, I am required to take steps to inform the intended victim, statutory services such as social care and appropriate law enforcement agencies.
If you reveal or I have reasonable suspicion that any child, elderly person, or incompetent person is being abused or neglected, the law requires that I report this.
If a court of law orders me to release information, I am required to provide that specific information to the court.
I will always try to speak to you about this first, unless there are safeguarding issues that prevent this.
I will keep a record of your personal details to help the therapy services run smoothly. These details are kept on encrypted devices and a secure password protected specialist software system (BACPAC) and are not shared with any third party. I will keep written notes of each session, these are kept in digital form on BACPAC. For security reasons I do not retain text messages for more than one year. If there is relevant information contained in a text message I will retain this digitally on BACPAC. Likewise, any email correspondence will be deleted after one year if it is not important. If necessary I will retain this digitally on BACPAC.
After counselling has ended. Once counselling has ended your records will be kept for a period of 5 years from the end of our contact (final session) with each other or 5 years after a child’s 18th birthday in line with requirements by my insurers. Your records are then securely destroyed. If you want me to delete your information sooner than this, please tell me.
Your rights
I try to be as open as I can be in terms of giving people access to their personal information. You have a right to ask me to delete your personal information, to limit how I use your personal information, or to stop processing your personal information. You also have a right to ask for a copy of any information that I hold about you and to object to the use of your personal data in some circumstances. You can read more about your rights at ico.org.uk/your-data-matters.
It is important to note that even if a child is too young to understand the implications of subject access rights, data about them is still their personal data and does not belong to anyone else, such as a parent or guardian. In the case of young children these rights are likely to be exercised by those with parental responsibility for them. If you request your child’s data, proof of parental responsibility will be required. If the young person is considered to be competent, I will respond to or consult the child or seek the child’s consent for disclosure to you (with parental responsibility).
If I do hold information about you I will:
• give you a description of it and where it came from;
• tell you why I am holding its, tell you how long I will store your data and how I made this decision;
• tell you who it could be disclosed to;
• let you have a copy of the information in an intelligible form.
You can also ask me at any time to correct any mistakes there may be in the personal information I hold about you. To make a request for any personal information I may hold about you, please put the request in writing addressing it to fiona@springwelltherapy.co.uk.
If you have any complaint about how I handle your personal data please do not hesitate to get in touch with me by writing or emailing to the contact details given above. I would welcome any suggestions for improving my data protection procedures.
If you want to make a formal complaint about the way I have processed your personal information you can contact the ICO which is the statutory body that oversees data protection law in the UK. For more information go to ico.org.uk/make-a-complaint.
Data security
I take the security of the data I hold about you very seriously and as such I take every effort to make sure it is kept secure. I use encrypted devices and a secure password protected specialist software system (BACPAC) for professional record keeping and notes.
Additional information for website owners and employers
Visitors to my website When someone visits my website, I use a third party service, Squarespace, to collect standard internet log information and details of visitor behaviour patterns. I do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way that does not identify anyone. I do not make, and do not allow Squarespace to make, any attempt to find out the identities of those visiting my website. I use legitimate interests as my lawful basis for holding and using your personal information in this way when you visit my website. I use Squarespace so that I can continually improve my service to you, You can read the Squarespace privacy notice here Privacy Policy — Squarespace. No user-specific data is collected by me or any third party. If you fill in a form on my website, that data will be temporarily stored on the web host before being sent to me.