The website address is https://vinitalathamcounselling.co.uk
Your privacy is very important to me and you can be confident that your personal information will be kept safe and secure 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 the initial point of contact through to after your therapy has ended, including:
- Why I am able to process your information and what purpose I am processing it for
- Whether you have to provide it to me
- How long I store it for
- Whether there are other recipients of your personal information
- Whether I intend to transfer it to another country,
- Whether I do automated decision-making or profiling, and
- Your data protection rights.
I am happy to chat through any questions you might have about my data protection policy and you can contact me via email: email@example.com
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.
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 the 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
When you contact me with an enquiry about my counselling services I will collect information to help me satisfy your enquiry. This will include your name and contact details. Alternatively, your GP or other health professionals 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 I will ensure all your personal data is deleted within one month. If you would like me to delete this information sooner, just let me know.
While you are accessing counselling.
Rest assured that everything you discuss with me is confidential. That confidentiality will only be broken if I am required to disclose data about you: under a court order; if I am concerned about the welfare of a child, i.e., where there are child protection issues relating to potential physical, mental, sexual abuse or serious neglect or if you are considered a risk to yourself or others.
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 counselling service run smoothly. These details are kept securely on my password-protected apple computer (please read apple GDPR policy relating to their products https://www.apple.com/legal/privacy/en-ww/) and are not shared with any third party. I will keep written notes of each session and these are kept to a minimum to protect your data. For security reasons, I do not retain text messages for more than one week. If there is relevant information contained in a text message I will make a handwritten note that will be anonymised. Likewise, any email correspondence will be deleted after one week if it is not important. If necessary I will retain the email on my password-protected computer in my password-protected Gmail account firstname.lastname@example.org (please see Google’s GDPR compliant security measures https://privacy.google.com/businesses/compliance/#?modal_active=none)
Special category information is defined by the GDPR as being information that is more sensitive than other personal information and therefore requires higher levels of protection. Examples of this type of information could include information about your health, race, sexuality, sex life, or religion. In order to lawfully process special category information, I am obliged to identify a specific condition for processing it under Article 9 of the GDPR and communicate this to you. With this in mind, the condition of the GDPR that I apply to the processing of your special category information is that it is ‘pursuant to contract with a health professional’. This means that, if you begin psychotherapy with me, or ask me to assess whether or not you are eligible for me to offer psychotherapy to you, then I will likely need to process some special category information about you. Usually, this is information about your mental health, and I need to process it in order to fulfil my contractual obligations to you in delivering safe, effective psychotherapy.
After counselling has ended.
Once counselling has ended your records will be kept for three years from the end of our contact with each other and are then securely destroyed. If you want me to delete your information sooner than this, please tell me.
Third-party recipients of personal data
There may be occasions when I need to share personal or sensitive information about you with third parties, specifically, your insurance company or other health professionals involved in your care (see below). When I do so, I comply with all aspects of the Data Protection Act 1998 (DPA).
Your insurance company
If you are claiming the cost of your sessions through your insurance company, your insurance company may request details of your treatment and progress from me to authorise further funding for your treatment. I will share the minimum amount of information necessary with your insurance company.
Specialist healthcare providers
If there is a specialist healthcare provider, such as a consultant physician or psychiatrist, NHS mental health service, dietician or nutritionist, psychologist or other therapist involved in your care, and your treatment with them could be negatively impacted if they did not know you were working with me, I consider this very carefully.
I will always ask you for your consent before sharing any personal or sensitive information when liaising with other health professionals who may be involved in your care.
I will always ask you for your consent before making appropriate referrals to other healthcare providers.
I will also check with you what information you do and do not wish for me to share. I only share sensitive information that would be of direct importance to your healthcare i.e. directly relevant to you getting the most appropriate treatment for your needs.
I would ensure you have a copy of any email or report I send.
General practitioners(your GP)
It is not typically necessary for me to contact a client’s General Practitioner, unless you and I have concerns about the medication or treatment that a general practitioner may be prescribing you, or if your GP is the gateway to enable you to access other healthcare that you need.
If I share any information with your GP it will be in written form, in explicit consultation and collaboration with you, with the purpose of you getting better quality health care. I would ensure you have the opportunity to edit before it is sent and that you have a copy of the final draft.
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. 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 it. 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 request any personal information, I may hold about you, please put the request in writing addressing it to email@example.com. If you have any complaints about how I handle your personal data please do not hesitate to get in touch with me by email 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.
I take the security of the data I hold about you very seriously and as such, I make every effort to ensure it is kept secure. For adequate safety, I use a password-protected computer, password-protected email and I pseudonymise my notes which are kept to a minimum. Pseudonymisation enhances privacy by replacing most identifying fields within a data record by one or more artificial identifiers, or pseudonyms.