My lawful basis for holding and using 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 your name, address, phone number, email address and doctor's details. 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 a month. 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:

• if I think there is a risk of harm to yourself or others, or if I feel that a child or vulnerable adult is at risk,

• if you share information about a proposed act of terrorism or an express intention to break the law,

• if I am compelled to do so by law,

• to discuss aspects of our work together with my supervisor to further develop my practice and to ensure that I continue to work ethically in your best interests. On these occasions your identity will remain anonymous.

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 in a locked filing cabinet and are not shared with any third party.

I will keep brief written notes of each session and these are anonymised and kept separate to your personal details in a locked filing cabinet.

For security reasons I do not retain text messages for longer than they are needed and will usually delete them immediately. If there is relevant information contained in a text message I will add this by hand to my anonymised notes before deleting it. Likewise, any email correspondence will be deleted immediately if it is not important. If necessary I will add relevant information by hand to my anonymised notes before deleting it.

After counselling has ended

I will shred this privacy consent document and your registration/contact form with your personal information, and I will delete your phone number from my mobile phone one month after our work finishes. I will keep your session notes, your name, and your unique code for 6 years. These will be securely destroyed six years after our final contact. If you want me to delete your information sooner than this, please tell me.

Third party recipients of personal data

It is very unlikely that I will share your data and I will not sell it on or use it for unethical reasons. I may have to share it if my notes are requested by a court of law or if you tell me that you or someone else is at serious risk of harm, I might have to share it with your doctor or the police. I have appointed a Clinical Executor who, in the unfortunate event that I can no longer work with you, will have access to your details and will get in touch with 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 www.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 its, 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 insideoutsidetherapy@icloud.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 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 www.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 including using encrypted devices and a locked filing cabinet in a secure office.

Visitors to my website

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