Privacy notice
This page tells you about how I look after your information
Your privacy is very important to me. I will keep your personal information safe and secure and will only use it for the purpose it was given to me. I adhere to current data protection legislation, including the UK GDPR (United Kingdom General Data Protection Regulation) 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 our first contact until after your counselling 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
Your data protection rights
I am happy to answer any questions you might have about my data protection policy. You can contact me by email at miriamv-counselling@proton.me or by telephone on 07833089205.
‘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. My registration number is XXXXXX. My postal address is: XXXXXX.
My lawful basis for holding and using your personal information
The UK 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. You can read about these below:
If you have had counselling 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 counselling or if you are in contact with me to consider counselling, I will process your personal data where it is necessary for the performance of our contract
The UK 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 your name, location you wish to access counselling in, your contact details and any other personal information you choose to disclose at this point. 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, I will ensure all your personal data is deleted within six months. If you would like me to delete this information sooner, just let me know. If you decide to be added to the Waiting List, I will store your contact details will be stored and contact you when a suitable session becomes available, usually via email. You can be removed from the waiting list at any time by contacting me and your details will be deleted within six months. If you would like me to delete this information sooner, just let me know. While you are accessing counselling Your counselling sessions are confidential and this confidentiality will apply to any records in accordance with relevant Data Protection legislation. All counsellors are required to be in supervision and I will take relevant issues from our sessions to supervision to ensure the highest standard of care and professionalism. You will be referred to anonymously and supervision sessions and data are bound by the same confidentiality policy and professionalism as your counselling sessions. In exceptional circumstances confidentiality might be broken. In all cases I will aim to discuss with you first and seek to gain your consent. Such circumstances could include:
Where you give consent for a confidence to be broken
Where I feel it is appropriate to consult with or involve other professionals such as your GP in circumstances where there is risk of harm to you or a third party
Where in extreme cases I am legally compelled by a court of law
Where statutory law requires me to inform the relevant authorities, such as with terrorist activities, drug trafficking or abuse of a child or vulnerable adult
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 service run smoothly. Your identifiable details, such as surname and address are kept separately from any session notes.
I will keep your identifiable details and any contract with me that you sign on an encrypted digital system called Proton.
I will keep your assessment document and brief notes on each session in a locked filing cabinet in my office. These notes will be anonymous and will not include any identifiable information such as your name.
No personal records are shared with any third party.
After counselling has ended Once counselling has ended your records will be kept for five 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.
For security reasons I do not retain text messages or emails for more than six months if not important. If there is relevant information contained in a text message or email, I will make a note of it in your paper written records. If necessary, I will keep any important electronic data such as email or text message on a password protected phone and/or computer for the duration of your contract and for five years after our last contact. This is necessary for insurance purposes and can be helpful if you decide to come back to counselling within that time.
Third party recipients of personal data
I do not routinely share your data with any third party, except for supervision (see above) and bookkeeping purposes.
For bookkeeping purposes, I use bookkeeping software Freeagent to store your details and send you invoices. You can check their privacy policy to understand how they use your data.
Please note, if you pay your session fees by Bank Transfer, this will also be recorded by your and my bank accounts.
If you contacted me via third parties such as the Counselling Directory or the BACP, please check their privacy policy to understand how they use your data.
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. My devices are password protected, and encrypted where necessary. Your most sensitive data such as session notes is kept in paper form in a locked filing cabinet and in a pseudonymised format where possible. 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 any company 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. Like most websites I use cookies to help the site work more efficiently - find out about my use of cookies here: https://www.squarespace.com/cookie-policy. 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.
Other
I do not use any data to drive automated decision-making or profiling.