Privacy Statement

Surely, 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.

My lawful basis for holding and using your personal information

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 therapy) and necessary for a contract with a health professional (in this case, a contract between us).

How I use your information

Initial contact: Prior to your first session of therapy, I’ll ask you complete an electronic questionnaire. The information that I’ll collect will include:

Your name, age, and date of birth (this is to identify you)
Your home address, phone number, email address (this is to contact you)
An emergency contact name and number (this is to support you in the event of a medical emergency or a situation where there is a significant risk of harm)
If you have a disability or mental health issue (this forms part of my assessment process and helps me to understand your situation)
What medication you may be taking for a mental health issue (this forms part of my assessment process and helps me to understand your situation)
The name of your doctor’s surgery and its address (this is in case I need to contact your GP as part of my duty of care towards you)
Some brief information about the reasons that you are seeking therapy (this forms part of my assessment process and helps me to understand your situation).

If you decide not to proceed with therapy, I will ensure that all of your personal data is deleted within 6 weeks. If you would like me to delete this information sooner, just let me know.

While you are accessing therapy: Rest assured that everything you discuss with me is confidential. That confidentiality will only be broken:

if I have a reason to believe that you pose any risk to others and particularly to children
if I have reason to believe that your life may be at risk
to comply with legal requirements

I will always try to speak to you about this first, unless there are safeguarding issues that prevent me from doing this.

I will keep a record of your personal details to help the counselling services I provide to you run smoothly. I store these details securely using password protected documents and practice management software. I will also keep written notes made after each of your sessions; these are kept in the same way as your details. For security reasons I do not retain text messages or voicemails for more than 2 weeks. Likewise, any email correspondence will be deleted after 2 weeks unless it’s important.

After therapy has ended: Once counselling has ended your records will be kept for 2 years from the end of our contact with each other and are then securely destroyed.

Third party recipients of personal data

Your data could be shared with a third party in the following circumstances:

Supervision: It is a requirement of the BACP that therapists receive a minimum of 1.5 hours of supervision each month. This ensures that I am working safely, ethically and in the best interests of my clients. It’s possible that I will discuss the work we are doing together at some point during your therapy with my supervisor however, your identity will not be shared. Supervisors also adhere to a strict code of confidentiality.

Safeguarding: If you disclose something in a session that leads me to believe that there is an imminent risk of significant harm to yourself or to others, it’s likely that disclosures may have to be made to the appropriate agencies. This is usually done in consultation with you and only information concerning the risk would be disclosed.

Legal requirements: Information about you may be requested via a coroner, court order, legal proceedings, or statutory law. This could affect you if you are the perpetrator of a crime (e.g. if you are involved in drug trafficking or terrorism) or if you are involved in an active police investigation as a victim. With regards to the latter, the police can make a request to see your therapy notes but only if it is a ‘reasonable line of inquiry.’ They cannot make unfocused requests to browse your notes. In such a situation, before anything was sent on, I would ask for your consent and give you the opportunity to review the information that I had been asked to share about you. If you were not in agreement with your notes being shared, it would be possible for the court to subpoena them.

Therapeutic Wills: If death, disability, or other unexpected circumstances prevent us from continuing to engage in therapy with you, your name and contact details will be shared with the Therapeutic Executor. The Therapeutic Executor would contact you to make you aware of the event, and depending on your circumstance, may signpost you to alternative support.

Third Party Reports: I would only share a report with a third party at your request, with your consent and only if you have pre-agreed this with the third-party.

Telephone Messages: When you leave a voice message or send me a text, they are logged and stored on an encrypted digital cloud system within the European Union. The company that hosts this has a GDPR policy in place which meets expected security and privacy standards. Please me for information about the company that I use.

Emails: When you send an email to me, it is stored on an encrypted digital cloud system within the UK. The company that hosts this has a GDPR policy in place which meets expected security and privacy standards. Please contact me for information about the company that I use.

Website: When you use the contact form on this website or fill out the pre-assessment questionnaire, the data that you enter will be temporarily stored on the web host’s servers before being sent to me. Please contact me for details of the web hosting company that I use.

Your Rights

I insist 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 an email and send it to janetwsp@gmail.com. If you have any complaint about how I handle your personal data, please do not hesitate to get in touch with me. 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. My computer is password protected and not used by anyone else. I have anti-virus software installed which I keep regularly updated. I do not keep paper copies of your notes or personal details.