Privacy Notice

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, and the ethical guidelines of BACP.

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 susan@scbilingualcounselling.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 (Registration number: ZB871240).

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 and confidentiality

Initial Consultation
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 and contact details
The brief nature of your therapy seeking needs (could include mental health and/or physical health condition)

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 and enquiry on your behalf. If you decide not to proceed I will ensure all your personal data is deleted within 7 days. If you would like me to delete this information sooner, please inform me by email, by post, or by phone call/SMS message.

While you are accessing counselling - Confidentiality
Everything you discuss with me is confidential. That confidentiality will only be broken if any of the followings are involved:

Crime
Prevention of serious harm to you or to others
Statutory obligations to disclose (under The Terrorism Act 2000)
Court orders
Requirements to produce counselling records
Disclosures to enhance the quality of service provided (e.g. in counselling supervision)
Child protection
Clients at risk of suicide or serious self-harm

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 my counselling services run smoothly. These details are kept securely on password-protected folder stored on my password-protected business electronic devices. The physical copies are kept in a locked filing cabinet.

I discuss my work with my supervisor to ensure I could provide the best possible counselling services to my clients. These conversations are bound by confidentiality and I will only refer you in your first name or simply "Client (Your initial)".

I will keep written notes of each session, these anonymised information are kept electronically on the password-protected file on my password-protected computer device and in written format, which is stored in a locked filing cabinet. For security reasons I do not retain text messages for more than 7 days. If there is relevant information I will kept such information in your personal password-protected folder on my password-protected computer device. Likewise, any email correspondence will be deleted 1 calendar month after your counselling has ended.

After counselling has ended
Once counselling has ended your records will be kept for one year 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 inform me via email or by post.

Please be advised that I will need to keep your name and client reference number for seven years after your counselling sessions with me has ended so that I could respond effectively to any necessary requests regarding your therapy notes and treatment.

Third party recipients of personal data

I might require to share personal data with third parties, to improve my counselling services to clients, to protect client welfare, or to comply with legal requirements. For examples:

• Professional or legal advisors
• Emergency services
• Organisations we’re legally obliged to share personal information with
• Police, Court, and Social Services

Your rights

I try to be as open as I can be in terms of giving clients 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/for-the-public/.

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 susan@scbilingualcounselling.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/for-the-public/how-to-make-a-data-protection-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, up-to-date antivirus protection software, and encrypted devices for storing electronic information. My emails are required biometrics and password, and my mobile phone requires a PIN to be accessed to. Physical copies of all documents are locked in filing cabinets in a secured office.

Visitors to my website

Our website is hosted on the Wix.com platform. Wix.com provides us with the online platform that allows us to promote the counselling services to you. When you visit our website, 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.

Wix.com might collect standard internet log information and details of visitor behaviour patterns. I use Google Analytics so that I can continually improve my service to you. 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.com 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 our website.

My website may contain links to other websites or services. I am not responsible for such websites’ or services’ privacy practices. I encourage you to be aware when you leave my services and to read the privacy statements of each and every website and service you visit before providing your Personal Information. This Privacy Policy does not apply to such linked third party websites and services.

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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.

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