Privacy Notice for Clients

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The personal data I hold

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Personal data that I collect, use, store and share (when appropriate) about you includes:

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• Your full name

• Your address including post code

• Your telephone number(s)

• Your email address(s) 

• Some of the above details for an emergency contact person such as spouse or close relative (emergency contact data)

• Named GP surgery to which you are registered

 

I may also collect, use, store, and share (when appropriate) information about you that falls into "special categories" of more sensitive personal data. This includes information about (where applicable):

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• Date of birth

• Health history

• Additional needs

• Personal history

• Current difficulties that take you to counselling.

 

Why I use this data

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• The purpose of processing this data is to help me to offer you an effective service, including to:

• Make and sustain contact about appointments

• Make provision for an emergency

• Make provision for any safeguarding risk that emerges during the work together

• Provide a responsive service appropriate to your needs

• Undertake confidential supervision of my work as is professionally required of me, or customary.

 

My lawful basis for using this data

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I only collect, use, store and share your data and or the emergency contact’s data when the law allows me to. Most commonly, I use it to:

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• Provide you with the service you have asked for

• Comply with a legal obligation as required

 

 

Less commonly, I may also use some personal information about you when:

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• You have given me consent to use it in a certain way (e.g. to secure further funded counselling sessions)

• I need to protect your vital interests (or someone else’s interests) (e.g. safeguarding)

• Required by some other legitimate interest of my services of a third party (e.g. if it  became apparent to me that you were involved in a criminal activity , terrorism, etc.).

 

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Where you have provided me with consent to use your data, you may withdraw this consent any time.  I will make this clear when requesting consent, and explain how you can withdraw consent if you wish to do so.

 

Collecting this information

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While the majority of information I collect from you is required for service provision, there is some information that you can choose whether or not to provide to me.

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Whenever I seek to collect information from you, I make it clear what is required and the reasons for this.

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I will ask you at that time to assure me that you have or will immediately inform your emergency contact that you have provided its/ their personal information to me and that you have obtained or will immediately obtain its consent so that I may collect, use, store, and share your emergency contact’s data, along with your own, upon the terms of this policy notice. 

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How I store this data

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All information is a paper or an electronic file. When not in possession paper files are kept under lock and key.  No identifiable information is held electronically and electronic systems are password protected and regularly scanned for intrusion and back up provided on the premises.  Files of any kind when not on my person are kept in a secure office.

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When your relationship with me has ended, I may retain data of all kinds for up to 7 years principally for insurance, accounting and tax reasons and to assist should you to take up counselling with me again. I will then dispose of your data and your emergency contact’s data. 

 

Data sharing

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I will at all times hold you data and your emergency contact’s data as your confidential information.  I do not share information about you or your emergency contact’s data with any third party without your consent unless the law and our policies require me to do so, for example, with:

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• Government or local authority agencies – to meet legal obligations to share certain information with it, such as safeguarding concerns

• Police forces, courts

• Or as otherwise described above under My lawful basis for using this data

 

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Your data and the emergency contact’s data will not be used or shared for marketing by me or others through me.

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Your rights

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How to access personal information I hold about you

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Individuals have a right to make a ‘subject access request’ to personal information that I hold about them.

If you make a subject access request, and if I do hold information about you, I will:

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• Give you a description of it

• Tell you why we are holding and processing it, and how long we will keep it for

• Tell you who it (or parts of it) have been, or will be, shared with

• Give you a copy of the information in an intelligible form

 

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If you would like to make a request, please contact me. I will respond within one month – usually much sooner.

 

Your other rights regarding your data

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Under data protection law, individuals have certain rights regarding personal data usage and safety.  You have the right to:

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• Object to the use of your personal data if it would cause, or is causing, damage or distress

• Prevent your data being used to send direct marketing

• Object to the use of your personal data for decisions being taken by automated means (by a computer or machine, rather than by a person)

• In certain circumstances, have inaccurate personal data corrected, deleted or destroyed, restrict processing

• Claim compensation for damages caused by a breach of the data protection regulations

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To exercise any of these rights, please contact me on cda.drury@btinternet.com. I will respond within one month – usually much sooner.

 

Complaints

 

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I take any complaints about our collection and use of personal information very seriously.

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If you think that my collection or use of personal information is unfair, misleading or inappropriate, or have any other concern about data processing, please raise this with me in the first instance.

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To make a complaint, please contact me.

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Alternatively, you can make a complaint to the Information Commissioner’s Office:

• Report a concern online at https://ico.org.uk/concerns/

• Call 0303 123 1113

• Or write to: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF