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 denisespinney.therapyworks@gmail.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.
I am registered with the Information Commissioner’s Office registration number

ZA427198
My postal address is: 15 Bowbridge Wharf, Stroud, Gloucestershire GL5 2LD. My phone number is: 07414 202298. My email address is: denisespinney.therapyworks@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 may include your name, age, email address and/or phone number and a brief outline of the reason for your enquiry. 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.

I do not share your personal information with anyone else unless in pursuit of counselling on your behalf and only then if I have your permission to do so. In exceptional circumstances I may be required by law and my ethical responsibilities to break my confidentiality with you.

I would discuss this with you first wherever possible but if you do not give consent I may still have to disclose information.  This relates to situations where you may be at risk of harm, there is a risk of harm to others, for the safeguarding of children, young people and adults at risk, acts of terrorism and unreported road traffic accidents where I am under legal obligations. 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 digitally and password protected, separately from any session notes and are not shared with any third party.

I will keep computerised notes of each session using only your first name. These notes are password protected

For security reasons I do not retain text or email messages for more than one month. If there is relevant information contained in a text or email message I will transcribe it into the session notes.

 

Online counselling

I also work online using Zoom video or audio calling. This is an end to end encrypted service and access to sessions is by personalised invitation only. I do not record audio or visual information of sessions and no transcript is saved by me other than the notes I make after the session. You can read more about Zoom here https://zoom.us/privacy. Please be aware that there is always a risk that online services can be ‘hacked’ and that I cannot guarantee the security of data online.

 

After counselling has ended.

Once counselling has ended your records will be kept for 7 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.

 

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 denisespinney.therapyworks@gmail.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 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 password protected devices, encrypted cloud storage services and have a locked fire safe filing cabinet for any hard copy information from our work together
 

Additional information for website owners and employers

Visitors to my website

When someone visits my website, I use a third party service, 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 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, You can read Google Analytics’ privacy notice here (https://policies.google.com/technologies/partner-sites?hl=en-GB&gl=uk)

 

I use Wix.com as the online platform that allows me to market my services to you. Your data may be stored through Wix.com’s data storage, databases and the general Wix.com applications. They store your data on secure servers behind a firewall. You can read their privacy policy here (www.wix.com/about/privacy)

Like most websites I use cookies to help the site work more efficiently. Some of the cookies I use are essential for the site to work. The cookies collect information in an anonymous form. To control third party cookies, you can also adjust your browser settings.

 

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.

 

Revised May 2023