Introduction
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 info@clydemindsmatter.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 me.
I am registered with the Information Commissioner’s Office No. ZB937504. My email address is info@clydemindsmatter.com.
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).
Initial contact
When you contact me with an enquiry about my counselling services via my website at https://clydemindsmatter.com, I will collect information to help me satisfy your enquiry. This will include your name, address, phone number, email address, opt-in checkbox for an SMS reminder, emergency contact name and phone number, your GP name and number, whether you’ve had previous therapy, a brief description of your issues, whether you’ve had a diagnosis and a question regarding your personal safety and numbers to phone or text if your personal safety is at risk. As my services are not emergency services, then it is your responsibility or a family member/friend to contact emergency services unless we are in a session together and collaboratively agree or at such point, that you are at risk or a child is at risk under 16.
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 7 days. 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 during our session, you disclose that a child under 16 is at risk or is being harmed, or that you will harm yourself or others. I will always try to speak to you about this first, unless there are safeguarding issues that prevent this.
I will keep a record of your personal details to help the counselling services run smoothly. These details are kept securely under a password protected folder and are not shared with any third party. I will keep written notes after each session, these are kept under a password protected folder. For security reasons I do not retain text messages for more than 7 days. If there is relevant information contained in a text message I will screenshot it and keep it in your password protected folder. Likewise, any email correspondence will be deleted after 7 days if it is not important. If necessary I will screenshot it and keep it under your password protected folder.
After counselling has ended
Once counselling has ended your records will be kept for 10 years from the end of our contact with each other and are then securely destroyed. If you want me to delete your information sooner than this, please tell me. However, from time to time notes are required by legal systems like the Courts and can be requested by legal entities. However, your notes will be brief.
Third party recipients of personal data
As mentioned previously, I hold your records under a password protected folder via One Drive or Google Drive. Other legal or healthcare bodies may request this information via Court order or I may have to disclose your details to your GP or other healthcare body if you are at risk or a child under 16 is at risk. Also, all counsellors are required by their governing body must have a Supervisor and at times, points of your therapy may be discussed, however, your name and contact details will be anonymised so as not to identify you.
Your rights
I try 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 writing addressing it to info@clydemindsmatter.com.
If you have any complaint about how I handle your personal data please do not hesitate to get in touch with me by writing or emailing to the contact details given above. 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. Your information is held on a secure system via Acuity Scheduling via Squarespace. All other data is kept secure via Google Drive or One Drive in a password protected folder.
Visitors to my website
When someone visits my website, I use a third party service, Google analytics to collect standard internet log information and details of visitor behaviour patterns. I do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way that does not identify anyone. I do not make, and do not allow Google Analytics to make any attempt to find out the identities of those visiting my website. I use legitimate interests as my lawful basis for holding and using your personal information in this way when you visit my website. I use Google Analytics so that I can continually improve my service to you, You can read Google Analytics privacy notice here https://policies.google.com/privacy?hl=en-US . I use Acuity Scheduling via Squarespace as the content management system for my website – find out about https://www.squarespace.com/privacy and data protection. Like most websites I use cookies to help the site work more efficiently. No user-specific data is collected by me or any third party. If you fill in a form on my website, that data will be temporarily stored on the web host before being sent to me.