PRIVACY NOTICE
This privacy policy outlines your rights and my obligations to you regarding the recording and storing of your personal information. I will let you know what information I need to collect from you before we begin counselling and what information I need to collect from you during counselling. I will set out how I will look after your personal information, how long I will store it for, and who I will share it with. I will also let you know what you can request from me about this information.
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Why do you want to process my personal information?
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My contractual obligations to you as a counsellor are the lawful basis for my processing of your personal information. I need to process your personal information to fulfil my obligations to you as a counsellor, for example, to assess whether I can offer you counselling in the first place and then deliver effective counselling if therapy commences. Your personal information helps guide this process. 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. I will also use the information I collect about you to develop a better counselling website service.
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What are the laws that protect my personal information?
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The DPA and the General Data Protection Regulation (GDPR) require that all organisations that store personal information about people may only do so provided that the information is: processed lawfully, fairly and transparently; collected for specified, explicit and legitimate purposes; adequate, relevant and limited to what is necessary; accurate and, where necessary, kept up to date; kept in a form that permits identification of information subjects for no longer than is required for the purposes for which the personal information are processed; and processed in a manner that ensures appropriate security of the personal data.
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How will you collect my personal information?
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I will collect your personal information in the following ways: via my website: www.ourtherapyspace.co.uk, speaking to you on video chat, over the telephone, via email, text message, in writing, and in person during our meetings.
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How will you treat my personal information?
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I will treat your personal information with utmost care in a way that complies with the DPA and the GDPR. The lawful and proper treatment of your personal information is essential to maintain your confidence in me and my private practice. The email I use for client correspondence is a paid for Gmail account (part of Google Workspace) that is HIPAA compliant.
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How will you store my personal information?
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I will store your personal information both electronically and physically. Personal information is stored electronically on devices that are password protected and in files that are password protected and only accessible by me. Names and contact details are stored separately from additional personal information to increase security. Information is stored physically using paper records held securely in locked storage in an anonymised form. These records are only accessible to me.
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What types of information will you collect about me?
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I will collect several types of information about you in several different ways. For instance, when you visit www.ourtherapyspace.co.uk, I will collect the following information about your visit: I.P. address, location, search engine, date, time, web pages visited, operating system, and device.
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On initial contact:
If you contact me via the web form on www.ourtherapyspace.co.uk, I will collect the following information: name, email, date, and time. When you contact me via any format with an enquiry about my counselling services I will collect information to help me satisfy your enquiry. This will include name, contact details and a brief overview of your request. If you decide not to proceed I will ensure all your personal data is deleted within 12 months. If you would like me to delete this information sooner, just let me know. Before committing to provide you with a counselling service, I will ask you to provide me with the additional following information: address, availability, difficulties that you would like to address and any relevant medical history.
While you are accessing counselling:
Once we have agreed that counselling with me is suitable for you and therapy commences, I will collect further information about you on a personal details form that may include: goals for treatment, G.P. contact details, previous therapy, current medication and your network of support including NOK and emergency contact details. I will keep brief session notes to assist us during the therapy process which are stored securely. What we talk about during our sessions is confidential. This confidentiality will only be broken if I believe you or someone else are at serious risk of harm. In this instance, I will speak to you about breaking confidentiality first unless doing so would result in a safeguarding risk.
After counselling has ended:
Once counselling has ended I will keep your notes for a minimum of 7 years from the end of our contact with each other and after that they will securely destroyed.
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What is ‘special category’ information, and why must you process this too?
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Special category information is defined by the GDPR as being more sensitive than other personal information and therefore requiring higher levels of protection. Examples of this type of information could include information about your race, religion, sexuality, sex life, or health. To lawfully process special category information, I am obliged to identify a specific condition for processing it under Article 9 of the GDPR and communicate this to you. With this in mind, the state of the GDPR that I apply to process your special category information is ‘pursuant to a contract with a health professional’. This means that if you begin counselling with me, or ask me to assess whether or not counselling with me is appropriate for you, then I will likely need to process some special category information about you.
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What is a ‘data controller’, and who is the ‘data controller’ for Our Therapy Space?
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The GDPR defines a ‘data controller’ as the person in an organisation who: ‘determines the purposes and means of processing personal data’. For the GDPR, the ‘data controller’ in Our Therapy Space is Nicola De Maine. You can contact me in the following ways:
T: 07812119214
E: nicola@ourtherapyspace.co.uk
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Who will my personal information be shared with?
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Some of your personal information may be shared with your G.P. or another healthcare professional under certain exceptional circumstances. These include the requirements of a court of law, the threat of severe harm to you or others, or during regular consultations with my professional clinical supervisor. Some of your personal information, such as website visits, telephone call data, or payment information, is shared with the website provider, mobile phone operator, or card payment provider, respectively. These providers operate under their privacy policies, which can be provided upon request.
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Can I ask for a copy of the personal information that you store about me?
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Yes. Any request you make to obtain a copy of the personal information I hold about you is called a ‘Subject Access Request’. You can ask for a copy of the information I hold about you. I will usually respond to your request within one month. I may charge a fee for providing this information based on the administrative costs involved.
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Can I request that you delete my personal information?
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Yes. This is known in the new legislation as the 'Right to Erasure'. You can request that your personal information be deleted. I may have the right to refuse to comply with your request, for example, to comply with my insurance terms and conditions. I will let you know my response to your request within one month of receiving it.
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Can I object to or complain about the processing of my personal information by Our Therapy Space?
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Yes. Should you wish to object or complain about how I am handling your personal information, please feel free to communicate this to me. I will do my best to address your concerns and to resolve any issues you raise. Should you wish to take the matter further, please contact the Information Commissioner’s Office at 0303 123 1123, or visit https://ico.org.uk/concerns/ for more information.