Data and Privacy
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 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
• Your data protection rights.
I do not carry out any automated decision-making or profiling using your personal data.
I am happy to chat through any questions you might have about my data protection policy and you can contact me via email.
‘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 ZB615307. My email address is farzana@thryvecounselling.co.uk
My lawful basis for holding and using your personal information
I rely on the following lawful bases under UK GDPR:
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Legitimate interests – to respond to enquiries and manage my practice
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Contractual necessity – to provide counselling services
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Legal obligation and vital interests – where disclosure is required (e.g. safeguarding or legal requirements)
As I process special category data (health information), I rely on Article 9(2)(h) of the UK GDPR (provision of health care) and, where appropriate, your explicit consent.
Initial contact
When you contact me with an enquiry about my counselling services I will collect informationto help me satisfy your enquiry. This will include your name, email address and phone number. If you decide not to proceed I will ensure all your personal data is deleted within 90 days. If you would like me to delete this information sooner, just let me know.#
While you are accessing counselling
I will not share what you tell me unless there is a lawful, ethical or safeguarding reason to do so, and where possible I will limit any sharing to the minimum information necessary.
There are some limits to confidentiality. I may need to share information if:
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I believe there is a serious risk of harm to you or someone else
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there is a safeguarding concern involving a child, vulnerable adult or person at risk
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I am required to do so by law, court order or legal process
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disclosure is necessary to prevent or detect a serious crime
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there is a medical emergency and information is needed to protect life
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I need to consult my clinical supervisor, while protecting your identity as far as possible
Where possible and appropriate, I would aim to discuss this with you before sharing information. However, I may not be able to do so if this would increase risk, prejudice safeguarding action, undermine the purpose of the disclosure, or would otherwise not be possible.
I will keep a record of your personal details to help the counselling services run smoothly. These details are kept securely on my laptop and are not shared with any third party. I will keep written notes of each session, these are kept 6 years. For security reasons I do not retain text messages for more than 12 months. If there is relevant information contained in a text message I will add it to your written notes. Likewise, any email correspondence will be deleted after 12 months if it is not important.
Third party recipients of personal data
I do not share personal data with any third parties, unless, on very rare occasions, this isagreed specifically within our therapeutic contract (such as if I was working alongsideanother health professional).
Data processors and third-party services
I use third-party service providers (data processors) such as Wix (website hosting) and Google (analytics services). These providers process personal data on my behalf and are required to comply with UK data protection law. I have appropriate data processing agreements in place with them to ensure your data is handled securely.
International data transfers
Some of the third-party services I use may transfer or process personal data outside the UK. Where this occurs, I ensure appropriate safeguards are in place, such as UK adequacy regulations or standard contractual clauses, to protect your personal data.
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 its, 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 addressing it to farzana@thryvecounselling.co.uk
Data protection concerns and complaints
If you have a concern about how I have handled your personal information, you can make a data protection complaint by contacting me using the details in this notice. I will acknowledge your complaint within 30 days and take appropriate steps to look into it without undue delay.
Please include:
your name
what your concern is about
what you would like me to look into
how you would prefer me to respond
I will investigate your complaint as appropriate, keep you informed where necessary, and tell you the outcome without undue delay.
If you are not satisfied with my response, or if you would prefer to contact the UK regulator directly, you can contact the Information Commissioner’s Office:
Information Commissioner’s Office
Website: www.ico.org.uk
Telephone: 0303 123 1113
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 encrypted devices as well as a locked cabinet to store any paperwork.
In the unlikely event of a data breach that poses a risk to your rights and freedoms, I will notify you and the Information Commissioner’s Office where required.
Additional information for website owners and employers
Visitors to my website
When someone visits my website, I use a third party service, Wix and Google 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 Wix and Google 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. I use Wix as the content management system for my website – details of their privacy and GDPR statements can be found here: https://support.wix.com/en/privacy-gdpr.
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.
