Privacy Policy: Canoe Counselling
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 email using the ‘Contact me’ page on my website.
‘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, ZB346321. My phone number is 07396 688267. My email address is Jane.Therapy1@gmail.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, email address and phone number, as well as your GP details. It may also include brief notes about the reasons you give me for wanting to enter therapy with me. 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 48 hours. If you would like me to delete this information sooner, just let me know.
While you are accessing counselling.
I keep your information as described above for my personal records and in case you inform me during or outside a session that you are intending to end your life or your life is in danger. I use your mobile number or email address to confirm appointments, change appointments and to communicate where necessary between sessions. Please note that data transmitted via the internet (e.g. via email communication) may be subject to security breaches. Complete protection of your data from third-party access is not possible.
The information disclosed during the course of counselling is confidential. However there are legal exceptions. For example, if you reveal a threat of harm, or there is a threat of harm to self or to others, or if a court order is received and a legal obligation arises.
I will notify the ICO if my data security is breached if it is likely to result in a risk to the rights and freedoms of clients. If, for example, it could result in discrimination, damage to reputation, financial loss, loss of confidentiality or any other significant economic or social disadvantage. Where a breach is likely to result in a high risk to the rights and freedoms of individuals, you will also have to notify those concerned directly in most cases. 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 on my password-protected laptop and are not shared with any third party. I will keep notes of each session in a password-protected file on the same laptop. For security reasons I do not retain text messages for more than 1 week. If there is relevant information contained in a text message I will copy it into the session notes. Likewise, any email correspondence will be deleted after 1 week if it is not important to our work together. If necessary, I will save a copy of the email in your session notes.
After counselling has ended.
Once counselling has ended your records will be kept for 6 years from the end of our contact with each other and are then securely destroyed.
Sharing your data.
Under normal circumstances I don’t share your address or GP details with anyone else.
· One exception to this would be if I believe that your life is in danger. In this situation I would disclose your name, GP details and possibly address to the GP, a safeguarding officer or the police as appropriate.
· Another exception is if I have reason to believe that you are a sexual, physical or emotional danger to a child or vulnerable adult or if you inform me of someone else who may be a danger to a child or vulnerable adult.
· Finally if I was ordered by court to share your information or acknowledge our therapeutic relationship relationship, I would have to share that.
I have regular clinical supervision but in these sessions you remain confidential as I don’t share your name, your address or GP details. Only anonymised aspects of how we are working together are shared.
I sometimes share personal data with third parties, for example, where I have contracted with a clinical supervisor or a colleague to execute my Professional Will in the event of my death or incapacitation. 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 jane.therapy1@gmail.com. If this includes wanting a copy of your session notes, I will need 1 calendar months notice to comply.
If you have any complaint about how I handle your personal data please do not hesitate to get in touch with me by 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.
Right to be Forgotten
You have the right to ask me to erase any information that I hold about you. This includes your personal information that is no longer relevant to original purposes, or if you wish to withdraw consent. In all cases and when considering such requests, these rights are obligatory unless it’s information that I have a legal obligation to retain.
Data Portability
As the client, you have the right to receive your personal information which you previously provided, and also have the right to transfer that information to another party. For the purposes of the General Data Protection Regulations (GDPR) 2018, the data “controller” is Jane Pickersgill, Canoe Counselling, Lincolnshire.
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 keep any notes and personal information about you in a password protected file on a secure laptop which is only accessible by me.
Visitors to my website
Some data is collected when you provide it to me. This could, for example, be data you enter on a contact form. Other data are collected automatically by my IT systems when you visit the website. These data are primarily technical data such as the browser and operating system you are using or when you accessed the page. These data are collected automatically as soon as you enter my website.
When someone visits my website, I 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. I use legitimate interests as my lawful basis for holding and using your personal information in this way when you visit my website.
When visiting my website, statistical analyses may be made of your surfing behaviour. This happens primarily using cookies and analytics. The analysis of your surfing behaviour is usually anonymous, i.e. I will not be able to identify you from this data. You can object to this analysis or prevent it by not using certain tools.
Should you send me questions via the contact form, I will collect the data entered on the form, including the contact details you provide, to answer your question and any follow-up questions. I do not share this information without your permission. I will, therefore, process any data you enter onto the contact form only with your consent. You may revoke your consent at any time. An informal email making this request is sufficient. The data processed before I receive your request may still be legally processed.
I will retain the data you provide on the contact form until you request its deletion, revoke your consent for its storage, or the purpose for its storage no longer pertains (e.g. after fulfilling your request). Any mandatory statutory provisions, especially those regarding mandatory data retention periods, remain unaffected by this provision.
Google Analytics
This website uses Google Analytics, a web analytics service. It is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
Google Analytics uses so-called “cookies”. These are text files that are stored on your computer and that allow an analysis of the use of the website by you. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there.
Google Analytics cookies are stored based on Art. 6 (1) (f) DSGVO. The website operator has a legitimate interest in analysing user behaviour to optimise both its website and its advertising.
Cookies
Like most websites I use cookies to help the site work more efficiently. 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. You can prevent these cookies being stored by selecting the appropriate settings in your browser. However, I wish to point out that doing so may mean you will not be able to enjoy the full functionality of this website. You can also prevent the data generated by cookies about your use of the website (including your IP address) from being passed to Google, and the processing of these data by Google, by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en.
Objecting to the collection of data
You can prevent the collection of your data by Google Analytics by clicking on the following link. An opt-out cookie will be set to prevent your data from being collected on future visits to this site: Disable Google Analytics.
For more information about how Google Analytics handles user data, see Google’s privacy policy: https://support.google.com/analytics/answer/6004245?hl=en.
Outsourced data processing
I have entered into an agreement with Google for the outsourcing of my data processing and fully implement the strict requirements of the UK data protection authorities when using Google Analytics.