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 mark@markgr.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 ZB338288.
My postal address is: Sophia House (Room 33), 28 Cathedral Rd, Pontcanna, Cardiff, CF11 9LJ
My phone number is: 07534 599 233
My email address is: mark@markgr.co.uk
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 / psychotherapy / pastoral supervision) 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 / psychotherapeutic services I will collect information to help me satisfy your enquiry. This will include your:
- Name
- Known as name
- Date of birth
- Address
- Telephone
- Email address
- Preferred mode of communication
- Availability for communication
Alternatively, your Employee Assistance Programme, 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 three months. If you would like me to delete this information sooner, just let me know.
While you are accessing counselling
Your sessions are confidential, but with limitations.
I work within the British Association for Counselling and Psychotherapy (BACP) Ethical Framework for good practice and seek to offer the highest level of confidentiality consistent with the Law and BACP codes.
An important part of the code of ethics is that counsellors have a supervisor with whom they discuss their work. The focus of supervision is to help a counsellor look after the best interests of their clients. I may use examples of my casework in which the identity of the client will be anonymised. The therapist – supervisor relationship is confidential.
Exceptionally, I will involve outside agencies when harm to a client, or others, is considered a serious risk. In these circumstances, if possible, I will first discuss the situation with you and then agree a course of action.
There are circumstances, however, where the law requires me to break confidentiality without informing you, or gaining your consent. These relate to the Terrorism Act (2000), the Children Act (1989/2004), the Drug Trafficking Offences Act (1986- amended by Criminal Justice Act 1993), and court orders.
If you have any concerns, or queries, about these limitations to confidentiality you can discuss them with me at any time.
I will keep a record of your personal details to help the counselling / psychotherapy services run smoothly. These details are kept securely on a password protected document, and are accessed via password protected desktop, laptop, and smart phones and are not shared with any third party.
I will keep notes of each session, these are kept digitally they are anonymised and are kept securely on a password protected document, and are accessed via password protected desktop, laptop, and smart phones.
For security reasons I do not retain text messages once the therapeutic contract has ended. If there is relevant information contained in a text message I will transfer this to the written notes file which is anonymised and password protected. Likewise, any email correspondence will be deleted once the therapeutic contract has ended. If necessary I will transfer any key correspondence to the written notes file which is anonymised and password protected.
After counselling has ended
Once counselling / psychotherapy has ended your records will be kept for 3 years, as required by my insurer, 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 mark@markgr.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/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.
All the data I hold about you is in digital format only.
Each digital file is password protected and is accessed via devices which are each password protected.
Client notes are assigned a code and contain no identifiable information.
Additional information for website owners and employers
Visitors to my website
When someone visits my website, I use a third party service, Therapy Webgenie 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 Therapy Webgenie 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 Word Press as the content management system for our website – find out about Word Press and 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.