Counselling Privacy Policy
This document sets out what happens to your data when you have counselling with me. (You can also see the main privacy policy for details of how your data is handled when you visit the Shame-Free Community and use its services).
The information that I collect and store about you (your data)
The information that I collect and store about you includes:
- Information that you give me in your initial contact form such as name, contact details and contact preferences
- The details you give me during our initial session – including GP details, presenting issues, medical information and personal history
- Notes from our sessions
- Emails or text messages that you send me
- The signed contract and any request/consent forms that you sign
- Information from reviews, such as working agreements, assessments, counselling preferences
- Any other information that is necessary to keep you safe and provide a counselling service to you
Please note, this is not an exhaustive list.
How the information is used
I use your data to:
- Contact you
- Make referrals if required
- Contact your GP if needed
- Assess risk
- Determine what support you need and whether I’m the right person to support you
- Keep a legal record of what was discussed in sessions
- I use any request forms, consent forms and the signed contract as a legal record of what you’ve agreed to or requested
- Monitor how the counselling is going
Please note, this is not an exhaustive list.
How the information is stored
I store your information electronically using a split notes system, with your session notes stored separately to your other information. The notes themselves are completely anonymised so that if someone did manage to access them, they wouldn’t know who the notes referred to.
Both your notes and other details about you are stored on secure, encrypted systems, accessed via a password-protected computer which can’t be accessed by anyone else.
I use a secure email provider for email counselling, and all the information is securely encrypted.
When you contact me via text message or email, I access your messages on a password-protected device and no one else has access to this.
How long the information is stored for
I store client records for seven years from when you finish therapy with me, or for under-18s, I store the information for seven years from when they turn 18. This is required by my insurance company so that you would have enough time to bring a lawsuit if needed.
Who processes the information
The organisations that process your data are:
- Stripe (Stripe’s privacy policy)
- Surecart (Surecart’s privacy policy)
- Monzo (Monzo’s privacy policy)
- ClinicalWill.App (privacy policy) – you can also find their data security information here
- Proton (Proton’s privacy policy) – I use Mail, Drive and Meet
- Signable (Signable’s privacy policy)
- Kiku (Kiku’s privacy policy)
Who has access to counselling records
Your counselling records are stored securely and can only be accessed by:
- Me (the counsellor)
- You (the client) – if you request access to your counselling records, I will have 30 days to get your records to you. This is called a subject access request and it’s your right under data protection law.
- A court can request access to your counselling records ONLY with a court order
- A coroner can request access to your counselling records after your death in certain circumstances.
No one else can access your counselling records without your written consent.
Your rights
Under the GDPR (General Data Protection Regulation) law, you have several rights to do with how I deal with information I hold about you (called your data):
- The right to be informed – you have a right to be told about how the information about you will be used and stored.
- The right of access – you have a right to request access to all the data that I store about you, and I have 30 days to provide you with this data.
- The right to rectification – if some information about you that I’ve collected is wrong, you have the right to ask me to correct it and I have to comply.
- The right to erasure – you can ask me to delete any information about you that I have stored. I have to comply with this but there are situations where I have to keep information for a good reason, for example I must keep your counselling records for seven years.
- The right to restrict processing – you can ask me not to use some or all of your data, though I can still store this data without using it.
- The right to data portability – you have the right to ask me to transfer your data to another person or organisation, for example if you want me to give your counselling notes to another counsellor. Again, I will still need to keep a copy of your data for seven years after you finish counselling with me.
- The right to object – you can ask me not to use your data for a certain use, for example for marketing.
You can request that I carry out any of the above rights in writing or verbally, however I may need to verify your identity to make sure it’s really you making the request.
The process for requesting your data to be shared
If you want me to share your data with another person or organisation, you will need to request this in writing – just ask me for the data sharing consent form.
Online counselling disclaimer
I will always take steps to ensure that our online sessions, our contact between sessions and the storage of your data are as secure and private as possible, and I will always use the most secure methods possible. However, there are always risks when using third-party software, for example the software provider may have a data breach, and I am unable to prevent these. I can never guarantee that it will be 100% secure because this is outside my control.
Complaints
If you’re not happy with the way I’ve handled your data and you believe that I have broken data protection law, you can make a complaint against me to the ICO (Information Commissioner’s Office). There are details on their website about how to make a complaint at ico.org.uk.
You can also contact the ICO by phone: 0303 123 1113.
