Privacy Notice
Introduction
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 am I able to process your information and what purpose am I 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 discuss any questions you might have about my data protection policy, and you can contact me via email Derek@merseyinsighttherapy.co.uk
‘Data controller’ is the term used to describe the person/organisation that collects, 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.
My phone number is: 07396 974777 My email address is: Derek@merseyinsighttherapy.co.uk
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 consent initially. I will then retain any counselling records in case of the need to reference them in the future (the official legal basis is to defend against potential legal claims).
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 may include name, telephone number and email address. Alternatively, a 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, 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 are accessing counselling
Rest assured that everything you discuss with me is confidential. That confidentiality will only be broken if UK law requires me to do so. 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 services run smoothly. These details are kept securely predominantly in a non-portable locked cabinet, a passcode-protected mobile and email account. The protected mobile phone may be occasionally taken off-site and kept on my person within a button or zip-sealed pocket. All other devices are stored on the premises and are not taken offsite, and are not shared with any third party.
I will keep written notes of each session; these are kept in a non-portable locked cabinet. Notes over 2 years old will be transferred to an encrypted USB device.
For security reasons, I do not retain text messages for more than 1 month. If there is relevant information contained in a text message, I will take a screenshot, print and store it in the lockable cabinet. Likewise, any email correspondence will be deleted after 1 month if it is not important. If necessary. I will place emails into an email archive folder.
After counselling has ended
Once counselling has ended, your records will be kept for 5 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
I will only share your personal data in exceptional circumstances. For example, where I must adhere to UK law, such as the management of a safeguarding issue.
If you wish to be referred to another health professional, then as per your request, I will need to share your personal data to complete the referral.
Third-party recipients could consist of health, law enforcement or crime prevention professionals. During the course of counselling, It could also be that you request me to reach out to a trusted family member/friend due to feeling unwell.
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.
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 put the request in writing via email, addressing it to Derek@merseyinsighttherapy.co.uk
If you have any complaints about how I handle your personal data, please do not hesitate to get in touch with me by either writing or emailing the contact details given above. I would welcome any suggestions for improving my data protection procedures.
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 password-protected devices and accounts and a non-portable locked filing cabinet. I use shredding software to delete data and an Advanced Security P4 shredder to destroy printed documents.