Privacy Policy

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,

·       Whether I do automated decision-making or profiling, and

·       Your data protection rights

I am happy to chat through any questions you might have about my data protection policy, and you can contact me via brigitta@brigittarabtherapy.co.uk.

‘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 (ICO) (Registration number:ZB789952). My postal address is: 20 Swan Street, Manchester, M4 5JW. If you have any queries, my email address is: brigitta@brigittarabtherapy.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 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

Storage and management of personal information

My principal data management system is a Power Diary CRM system, which is maintained and developed by a third-party processor. This system enables me to efficiently store any information about my clients, former clients and other stakeholders in a way that ensures adequate security and only allows people who have the right level of authority to access personal information. It also simplifies our responsibilities for data retention and subject access requests.

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 full name, your phone number, your email address, your address, your GP’s name and address, your medication you are taking, and date of birth. We may also ask for sensitive personal information, such as ethnicity, gender sexuality, marital status, sexuality, offences, the status of your physical and mental health or religion and beliefs. 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.

We will only retain your personal information for as long as it is necessary. This is in line with guidance from the Information Commissioner’s Office.

If you decide not to proceed, I will ensure all your personal data is deleted within a month. If you would like me to delete this information sooner, just let me know.

 While you are accessing counselling.

Confidentiality is of paramount importance within the practice, and I fully appreciate that you will be trusting me with sensitive and personal information. I will maintain your confidentiality unless there is serious risk of harm to you or others, or there is a statutory obligation for me to disclose. I will always try to speak to you about this first, unless there are safeguarding issues that prevent this.

In accordance with the British Association of Counselling & Psychotherapy (BACP) guidelines I am required to have clinical supervision. From time to time, I may discuss our work with my clinical supervisor; this is standard practice and supports my work with you. My supervisor is also bound by a code of ethics, and our sessions are confidential.

Following each session, I may make brief factual notes if necessary. These will not be shared with anyone without your permission, or unless I am legally obligated to do so.

Your GP or any other health professional will not be contacted without your permission or knowledge unless I believe, in my professional opinion, that you are at serious risk of harm. If you reveal during your sessions that someone else is at risk, you will be encouraged and supported to take necessary action. If you are unable or unwilling to do so, I reserve the right to break confidentiality and contact the relevant agency.

If I see you outside of our therapy sessions, I will not approach or acknowledge you unless you signal that you would like me to do so.

For security reasons I do not retain text messages for more than a month. If there is relevant information contained in a text message, I will record it in the Power Diary CRM system and delete the message in a month. Likewise, any email correspondence will be deleted after 3 months if it is not important.

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 sometimes share personal data with third parties, for example where I have contracted with a supplier to carry out specific task. 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. This could include suppliers that process personal data on my behalf, for example the company that supports my IT, any cloud services such as Microsoft Office 365, Acuity scheduling system. I may share any data about our operations with HMRC or the ICO.

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 put the request in writing addressing it to brigitta@brigittarabtherapy.co.uk.

If you have any complaint 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. 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 secure. Your client information and a signed copy of this form will be held digitally on a password protected device. Only I have access to this information, and it is used solely for therapy-related and legal purposes.

Additional information

Visitors to my website

When someone visits my website, I use a third-party service, Squarespace, and Google Workspace 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 Squarespace 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.

The website uses cookies and Google Analytics, so that I can continually improve my service to you. Almost all websites use cookies which are small files that get put on your computer by websites as you surf them. These cookies can store lots of information which can have privacy implications. Google Analytics is a service provided by Google that gathers anonymous data on how people are using websites and then provides visitor statistics, details of page views, etc. This service is used by many website owners as the data helps website owners to improve their websites. If you wish to change your cookie settings, then you may do so through most browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them visit www.aboutcookies.org or www.allaboutcookies.org.

I use Squarespace the content management system for our website.

If you fill in a form on my website, your message will be temporarily stored on the web host (Squarespace) before being forwarded to me. No user-specific data is collected.

When you email us

I use Google Mail to manage my emails and Squarespace to host my website. Both companies comply with data protection regulations.

I also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send is within the bounds of the law.

Changes to privacy notice

This privacy notice may be updated from time to time, so please check occasionally for any updates.