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
- 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 info@eleanorwarman.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 ZA441915. My postal address is: Eleanor Warman Counselling c/o Headscape, The Old Rectory, St Mary’s Hill, Chester, Cheshire CH1 2DW. My phone number is: 07577 577957. My email address is: info@eleanorwarman.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 or 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/supervision services I will collect information to help me satisfy your enquiry. This will include your name, phone number and/or email address and any details of your circumstances you feel I need to know at this stage. Alternatively, your GP or other 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/supervision.
Rest assured that everything you discuss with me is confidential. That confidentiality will only be broken if I suspect harm to yourself or those around you, if you reveal information which the I have a legal duty to disclose, i.e. information about terrorism or money laundering or if I am ever subject to a court order about the work. I will always try to speak to you about this first, unless there are safeguarding or legal issues that prevent this.
I will keep a record of your personal details to help the counselling/supervision services run smoothly. This includes GP and an emergency contact details. This is in case you are deemed to be at risk, or fall ill during a session, so I know who to contact to support you. These details are kept securely in a locked cabinet, on my password-protected work phone, or my password-protected email account, and are not shared with any third party. I will keep written notes of each session, these are kept in a locked cabinet. For security reasons I do not retain text messages for more than one month. If there is relevant information contained in a text message I will transfer it to your client information section on the contract, stored as above. Likewise, any email correspondence will be deleted after a month if it is not important.
After counselling/supervision has ended.
Once counselling/supervision has ended your records will be kept for 5 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.
I retain details of our work (anonymised using your unique client code if you accessed counselling), to analyse business performance.
Third party recipients of personal data
I sometimes share personal data with third parties, for example, where I have contracted with a supplier to carry out specific tasks. You can find details of their privacy policies as follows:
WordPress – website management
https://automattic.com/privacy/
Fasthosts – website host
https://www.fasthosts.co.uk/terms/policies/privacy-notice
Dreamhost – email service provider
https://www.dreamhost.com/legal/privacy-policy/
Apple – work phone provider