Data Controller
Amy Garrett
Collected Personal Data
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 email amygarrettcounselling@gmail.com
‘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
myself Amy Garrett.
I am registered with the Information Commissioner’s Office, registration number C1132340.
0303 123 1113.
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) 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
services I will collect information to help me satisfy your enquiry. This will include name, address, contact phone number and date of birth, email address and the contact information of a next of kin and your GP. Also, for your treatment I will need to document what issues you would like to address in counselling, previous counselling experience, information on relevant medication or medical diagnosis, the location and method of counselling you require, any accessibility issues or physical impairments which may impact the location of counselling, your preferred method of contact and your availability.
Alternatively, your 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 2 weeks. If you would like me to
delete this information sooner, just let me know.
While you are accessing counselling.
Rest assured that everything you discuss with me is confidential.
That confidentiality will only be broken if I feel that there is a serious risk of harm to yourself or to someone else, a safeguarding concern or for legal reasons such as drug trafficking, money laundering, terrorism or if it has been ordered by court. I will always try to speak to you about this first unless there are legal reasons that prevent this.
I will keep a record of your personal details to help the
counselling services run smoothly. These details are kept
securely on a password protected laptop and are filed in a locked case/cabinet. They are not shared with any third party.
I will keep written notes of each session, these are kept in a separate locked case/ cabinet.
For security reasons I do not retain text messages for more
than 1 week. If there is relevant information
contained in a text message, I will transfer the details to a password protected document and store in a file on my secure laptop or with my written notes. Likewise, any email correspondence will be
deleted after 1 week if it is not important. If
necessary I will transfer the information to a password protected document and stored on a file on my secure laptop or with the written notes.
After counselling has ended
Once counselling has ended your records will be kept as required by my insurance policy, for minimum of 5 years from the end of our contact with each other and in the case of minors, the records will be stored for a minimum of 5 years from when they turn18. They
are then securely destroyed according to the GDPR regulations.
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. In such cases I have carefully selected which partners I
work with. I take great care to ensure that I have a contract with
the third party that states what they are allowed to do with
the data I share with them. I ensure that they do not use your
information in any way other than the task for which they have
been contracted. Currently the companies include Microsoft office360 for storing data and sending/receiving emails, ICO (information commissioner’s office) for regulating and monitoring GDPR, HMRC for tax and self/employment monitoring purposes, Starling bank for processing payments, O2 for making and receiving phone calls and texts.
Therapy@amygarrettcounselling.co.uk
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