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 blackcat_freya@protonmail.com.
‘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.
My phone number is: 07436113349. My email address is: blackcat_freya@protonmail.com.
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
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, telephone contact and/or email address and sometimes your age. 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 one 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 what you tell me relates to a crime that I must report by law, or if it concerns you or someone else coming to harm, especially where there is a danger to children. 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 in hardcopy format and are not shared with any third party. I will keep written notes of each session, these are kept in hardcopy format. For security reasons I do not retain text messages for more than one month. If there is relevant information contained in a text message I will enter this into your client file in hardcopy. Likewise, any email correspondence will be deleted after three months if it is not important. If necessary I will copy this into your client file in hardcopy which is kept in an alarmed building, in a locked filing cabinet.
After counselling has ended.
Once counselling has ended your contract record will be kept for six years from the end of our contact with each other and are then securely destroyed. Process notes are kept for six years at the end of contract. If you want me to delete or destroy your process notes information sooner than this, please tell me. Keeping records for six years at the end of contract was effective from 01/01/2019.
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 tasks. 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
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 blackcat_freya@protonmail.com. 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 recognise that the information you provide may be sensitive and I will respect your privacy. I keep information about you confidential. This means I store it securely and control who has access to it. I sometimes share personal data with third parties where I have contracted them to carry out specific tasks for me. In such cases I carefully select 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.
I will only share personal data with other organisations where I am satisfied that the other organisation is entitled to receive it and will keep your information secure.
I am committed to holding all digital personal data on secure systems. I keep any paper-based personal data in locked cabinets to which only appropriate staff have access. I am working to reduce the amount of paper-based information I hold as it is easier to secure data if it is only held electronically.
I use third party processors to provide email monitoring and filtering. I have invested extensively in ensuring my information systems are secure and that my staff are suitably trained.
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 an encrypted email service, a VPN, password protection where applicable, locked filing cabinet, alarmed building.
Visitors to my website and social media platforms
When someone visits my website, I use a third party service, Wix and Google Analytics, 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 Google Analytics so that I can continually improve my service to you - read the Google Analytics privacy notice. I use Wix as the content management system for my website - find out about the Wix data protection. 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. Non-members can sign up to the website in order to comment on blog posts or to book services. When doing this you will be asked for your name, email address and date of birth. Your details will be retained for as long as you regularly log into the website.
I have a presence on various social media platforms. If you engage with me via these platforms I will not collect or store any of your personal data, however you need to be aware of how those websites use your data. Currently I have a corporate presence on Facebook and Instagram. To find out about how these companies use your data and how you can control the way they use your data follow these links: Facebook; Instagram.
People who sign up to my newsletter
If you sign up to my newsletter I will use a third party (Wix) to keep your data, to distribute the newsletter and to keep track of open rates and other standard media measures. I only keep your email and name and I will renew your consent every two years. You can also unsubscribe at any time which will remove your email and name from the list hosted by Wix.
Linking to other websites / third party content
You may encounter links to external sites from my content. Where applicable any endorsements will be stated on the relevant webpage, however, I take no responsibility for the content or information contained within any linked website that is not owned or controlled by me.