Privacy Statement

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On 25th May 2018 it became a legal requirement under the GDPR (General Data Protection Regulation) for your counsellor/psychotherapist/supervisor to make clear their data processing procedure to you. Most importantly the GDPR made it a legal requirement for you to actively opt in and consent to these arrangements which include the handling of your data. 

I hereby declare that I abide by the General Data Protection Regulation (GDPR) and am the data controller and processor for Sarah Nelson Counselling. You can find out more about the GDPR from the ICO (Information Commissioner’s Office - https://ico.org.uk/ ) 

Under the GDPR the practitioner needs to make clients and supervisees aware of the following:
 
Reason for collecting personal data/information

 

I wish to state clearly that I collect relevant personal information from clients and supervisees only to enable a working record of contact information, in case of emergencies (explained below) and for the ongoing work in the therapeutic or supervisory relationship. 

 

Confidentiality: will my counsellor/psychotherapist or supervisor share my data? 

 

I am bound by the UKCP Ethical Principles and Code of Professional Conduct. I subscribe to their code of ethics, and act in accordance with their code of practice, and provide confidentiality within these guidelines. My sessions with clients are strictly confidential, and the contents will not be disclosed beyond good practice guidelines. These guidelines include the following exceptions to the confidentiality rule:

 

• I am required by the UKCP to engage in regular supervision. You may be discussed during the supervision, however your identity will remain anonymous. Clinical supervision is in place to ensure that your counsellor/psychotherapist/supervisor is working ethically and safely, and to ensure that you receive the best practice. I abide by UKCP guidelines and Supervision Policy. 

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• Counsellors/psychotherapists/supervisors are required to break confidentiality if they assess you are a risk to yourself or to others. If at all possible they would always discuss a potential breach of confidentiality with you in advance. They would break confidentiality only to the relevant persons or authorities for the purpose of assisting your wellbeing or the safety of others. If at any point during the counselling you are in need of emergency, medical, or additional support, I may ask for your consent to contact your GP or other appropriate services. If at any point during the counselling you reveal an intent to cause harm to others, all counsellors are then legally bound to disclose this to authorities. 

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• Under the GDPR the counsellor/psychotherapist/supervisor also has a legal requirement to disclose data if you are involved in money laundering, planning terrorist offences, or if a Court Order has been made.

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• With regard to online counselling via email, text/message, and webcam, the police and other authorities can ask for access to an individual’s email account or synchronous messaging account where there is a suspicion of illegal or terrorist activities. They can also ask counsellors/psychotherapists for access to stored records. Counsellors/psychotherapists are not able to guarantee confidentiality in these circumstances. 

 

How will my counsellor/psychotherapist or supervisor store personal data and for how long? 

 

Personal data pertaining to our sessions and work together will be as minimal as is possible and will be stored with a coded client ID which shall be password protected and encrypted. Any handwritten information will be coded and stored under lock and key. Personal data/records of our sessions will be kept for no longer than is necessary in accordance with any legitimate purpose they might serve. 

 

• Your personal data will be disposed of by wiping any electronic files and shredding any handwritten information. You can also request (in writing) that all data be destroyed; during our contact; once our work together ends; or at any time thereafter. 

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• Your telephone number ID will be coded by initials and ID numbers/letters plus an icon to indicate purpose of contact (i.e., client, supervisee). Your telephone number will be stored only for contact purposes, until such time as our contact ceases. It will then be permanently deleted. 

 

Your rights under GDPR 

 

• You have the right to request access to your client record and receive an explanation of what is held within it. 

 

• You have the right to withdraw consent, to request erasure or correction of your client record, to request portability, or to object to/or restrict collection and processing of your data. 

 

• You have the right to know the source/s of personal data not originating directly from yourself, and the right to not receive unsolicited marketing. 

 

• You have the right to be made aware of any automatic decision-making processes (e.g., profiling) which may have any significance or consequence to yourself. 

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• To the fullest of our ability, you will be made aware of any data breaches within 72 hours. We will consider any claim for compensation for any damage or distress caused by the data breach. 

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• You have the right to complain to the ICO (Information Commissioners Office) if you are unhappy with the data processing arrangements, and to engage representation from a not-for-profit body in doing so. 

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To summarise: 

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• I collect, store and process personal information about you to enable me to run my counselling/psychotherapy practice. This information can include contact information, as well as information about your age, health (mental and physical), sexuality (where relevant to the therapeutic work), domestic and financial arrangements (where relevant) and other special category data. I am able to collect this information upon the legal basis of "Legitimate Interests", as per GDPR regulations. 

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• Your information is stored anonymously, under lock and key, and is also password/encryption protected. I may use this information to track the progress of our work together or to receive guidance from my supervisor. I will keep this information for no longer than is necessary. As stated previously, electronic files will be wiped and handwritten information will be shredded. 

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• You have the right to have information about you deleted; the right to have inaccuracies corrected; the right to access information about you - free of charge - within 1 month; the right not to receive any unsolicited marketing; the right to determine how information about you is processed, and the right to complain if you are unhappy about any of the above by contacting the Information Commissioners Office at: https://ico.org.uk/concerns/. Please note that prior to taking any such action, you are welcome to discuss your concerns with me first.

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• Should anything take place that prevents me from attending a session and from communicating with you directly - such as illness or death - then I have appointed a Therapeutic Executor who would be able to access your contact details to inform you should this situation arise. 

 

Your signed consent of the Privacy Statement & Personal Information form will acknowledge that you fully understand and accept the policy for records held, and also gives your consent to use of personal and sensitive personal data for the stated purposes.

A note about external factors

Please protect your confidentiality when identifying yourself as the sender of payment. Your privacy within bank records is beyond my control, apart from the secure account password details I hold.

Links to other websites 

 

My website may contain links to other websites of interest or additional support. However, once you have used these links to leave this site, you should note that I do not have any control over those other websites or the privacy and protection of information you are provided with whilst visiting those websites. Other sites may or may not have their own privacy policy and are not governed by this privacy policy.