Data Protection and Privacy Policy
Your privacy is very important to me therefore 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 (GDPR), the Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
This privacy policy tells you what I will do with your personal information from 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 registered with the Information Commissioner’s Office[Insert registration number]
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
· When you contact me with an enquiry about my counselling service I will collect information to help me satisfy your enquiry. This will include your name, address, email address and telephone number. 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 31 days. If you would like me to delete this information sooner, please notify me by email at hello.mintmind@outlook.com .
· While you are accessing counselling everything you discuss with me is confidential. That confidentiality will only be broken in the events outlined in the Client and Counsellor contract. I will always try to speak to you about this first unless there are safeguarding or legal 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 and are not shared with any third party.
· I will keep written notes of each session that may be both written and electronic. These are kept securely either on an encrypted device or in locked cabinet and only I have access to them.
· For security reasons I do not retain text messages for more than 31 days unless is relevant information contained in a text message, I will keep this securely for as long as required. Likewise, any email correspondence will be deleted after 31 days if it is not important. If necessary, I will this securely for as long as reasonably required.
· After 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 would like
me to delete this information sooner, please notify me by email at hello.mintmind@outlook.com .
Third party recipients of personal data
I sometimes may share personal data with third parties, for example, where I have contracted with a supplier to carry out specific tasks. Third parties include GoDaddy and Microsoft for IT support. In such cases I have carefully selected which partners I
work with. I take great care to ensure that I have a contract with the third party that states what they are allowed to do with the data I share with them. I ensure that they do not use your information in any way other than the task for which they have been contracted.
Your rights
Under the Data Protection Act you have the right to see records that are kept about you. If anything in the record is unclear, I am happy to explain it. You have the right to correct anything in a record that you believe is wrong. You also have the right to be forgotten and your records destroyed.
There are two exceptional circumstances in which access may be refused to any part of your record. These are:
• Where I believe that to do so could be seriously harmful to you,
• Where information has been supplied confidentially by a third party. (Consent must be obtained from that person before any disclosure can be made.) If you disagree with my decision to refuse access, you can raise your concerns with my clinical supervisor or with my professional body, BACP.
To make a request for any personal information I may hold about you, please put the request in writing addressing it to Andrea Dhillon at hello.mintmind@outlook.com
If you have any complaints 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. You can read more about your rights at ico.org.uk/your-data-matters
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 such as using encrypted devices and locked filing cabinets.
Visitors to my website
When someone visits my website, I may use a third-party service, GoDaddy, 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 GoDaddy to make, any attempt to find out the identities of those visiting my website. 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.
I use legitimate interests as my lawful basis for holding and using your personal information in this way when you visit my website.