Privacy Notice
Introduction
I take privacy and data protection seriously. Any personal information you provide will be kept safe and secure, and will only be used for the purpose for which it was given. I adhere to current data protection legislation, including the General Data Protection Regulation (EU/2016/679) (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’m happy to chat through any questions you might have about my data protection policy - you can contact me via email: eliotkeirl@gmail.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. I’m registered with the Information Commissioner’s Office - registration reference ZB401387.
My lawful basis for holding and using your personal information
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:
If you’ve 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’re currently having therapy or if you’re in contact with me to consider therapy, I will process your personal data where it is necessary for the performance of our contract.
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 counselling, I will collect information to help me satisfy your enquiry. This will include your name and contact details.
If you decide not to proceed I will ensure all your personal data is deleted within 1 month. If you would like me to delete this information sooner, just let me know.
While you’re accessing counselling
Everything you discuss with me is confidential. However, there are some important limits to that confidentiality. I may have to break confidentiality if you disclose something that indicates:
you or someone else is at significant risk of harm, or
involvement in certain criminal activities.
In such an event, whenever possible, I will speak to you about this first, unless there are specific safeguarding issues that prevent this. I work in accordance with the BACP’s Ethical Framework, which provides more detail.
I will keep a record of your personal details to help the counselling service run smoothly. These details are kept securely and are not shared with any third party. I also keep brief, written notes of each session, and these are kept securely and anonymously.
After counselling has ended
As a legal requirement, once counselling has ended your records will be kept for 7 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.
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.
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 make a request for any personal information I may hold about you, please make the request via written email to eliotkeirl@gmail.com.
If you have any complaint about how I handle your personal data please do not hesitate to get in touch with me using the email address 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 as securely as possible. I store all information in an encrypted folder on a password protected computer that nobody else has access to. The notes I make are brief, containing no identifying details. Clients are anonymised using codes, the details of which are kept in a separate, password protected file.
Visitors to my website
I use SquareSpace for all aspects of my website. When someone visits my website, I 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 anyone else to make, any attempt to find out the identities of those visiting my website.