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 Regulation (EU/2016/679; the GDPR), the Data Protection Act 2018 and the Privacy and Electronic Communication (EC Directive) Regulations 2003.

The 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 at [email protected] 

‘Data controller’ is the term used to describe the person/organisation that collects, stores, and has responsibility for people’s personal data. In this instance, the controller is me.

I am registered with the Information Commissioner’s Office (ICO) and my registration details are:

ICO Reference Number - ZB562220

Please find my contact information below:

Phone: 0739 6718 308

Email: [email protected]

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.

This information may include:

• Your contact details so that I may contact you, such as phone numbers, email addresses and postal addresses.
• Notes of our sessions together as a memory aid for myself.
• Paperwork associated with your treatment such as any handouts you fill in (e.g. ‘Creating Therapy Goals’ worksheet), Problem Maps (also known as ‘formulations’), symptom diaries that you share with me, etc.
• The counselling contract that we have agreed and signed together.
• Any agreements by you, the client, for me to release information to a third party, such as your GP surgery. This agreement will stipulate the conditions under which I would release this information, for example, sending treatment summaries to update your medical records with.
• General notes made by myself regarding my attempts to contact you, advice from my supervision sessions with my supervisor. These are used as a memory aid for myself.
• Decisions to break confidentiality without your consent.
• Any consent you give me to video/audio-record our sessions together.
• Records of financial transactions (payments) for bookkeeping purposes.

The GDPR 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 psychotherapy) 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 therapy services I will collect information to help me satisfy your enquiry. This will include:

• Your full name
• Your date of birth
• Your current residential address
• Your NHS number
• Your GP surgery, GP number and GP address
• Your preferred telephone contact number, consent to leave voicemail and consent to send text messages
• Your email address and consent to send emails
• Three questionnaires that help me assess symptoms of depression (PHQ9), general anxiety (GAD7) and the impact of your current problem (WSAS)

I am extremely mindful of doing everything within my power to reduce health and wellbeing disparities that may affect people within certain groups. Furthermore, certain treatment adaptations are recommended for some groups of people to ensure the intervention is as useful as possible. As such, I give the option for people to let me know about:

• Ethnicity
• Gender Identity
• Sexual Orientation
• Physical Health Condition(s)
• Disabilities
• Neurodevelopmental Conditions (such as ADHD and Autism Spectrum Condition)
• If you are pregnant (or have been pregnant in the last 12 months)
• Any mental health diagnosis
• Any communication requirements

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 then I will ensure all your personal data is deleted within 3 months. If you would like me to delete this information sooner, just let me know.

While you are accessing therapy:

Rest assured that everything you discuss with me is confidential.

I will only discuss the information you have given me permission to share with the people you have specifically named in your ‘Authorisation for Release/Exchange of Information’ form.

There are boundaries to this confidentiality as part of my ‘duty of care’ as a therapist, meaning that I will have to break confidentiality if I become aware that:

• You have come to harm or are likely to come to harm, such as intent to act on suicidal thoughts, overdoses, etc. In this case my response may involve (though may not be limited to) contacting your GP to make them aware and/or request support, contacting 999 and requesting an ambulance, or contacting the police to request a welfare check.
• Somebody else has come to harm or is likely to come to harm, such as instances where there is danger of harm to a child or vulnerable adult. In this case my response may involve (though may not be limited to) contacting the local authority safeguarding team to seek advice for further action.
• If the law had been broken or was going to be broken, such as planning a terrorist attack. In this case my response may involve (though may not be limited to) contacting the police to seek further advice or report a crime.
• To comply with a court order or a law.
• To assist in a serious crime investigation.

I consider the circumstances under which I may be required to break confidentiality very carefully, and this is not a decision that is taken lightly. I will always try to speak to you about this first, unless there are safeguarding issues that prevent this. If a decision is made to break confidentiality then the rationale for this will be recorded. We will then make a decision together as to whether you would like to continue treatment with myself.

I will keep a record of your personal details to help the therapy service run smoothly, and you will be assigned a Unique Identifier Code. These details are kept securely on an encrypted password-protected device. I will also keep written notes of each session (case notes) in a Microsoft Word Document. These will be saved to a separate encrypted password-protected device under your Unique Identifier Code. At the end of the workday both are stored in a pin protected digital locking safe.

After therapy has ended:

Once therapy has ended your records will be kept for 7 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.

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.

In-line with best practice guidance therapists are advised to take their cases to an accredited supervisor to ensure that their clients are receiving the best possible care. As such, it is likely that during the course of your care I will verbally discuss your treatment with my supervisor. Please be reassured that they are bound by the same professional code of conduct and legal obligations as myself with regards to your confidentiality.

My accrediting body, the ‘British Association for Behavioural and Cognitive Psychotherapies’ (BABCP) require that all privately practicing therapists set up a ‘Clinical Will’ describing how our clients will be contacted in the event I am incapacitated. Under these circumstances I have appointed a ‘Professional Executor’ who is trained to the same level as myself and bound by the same professional code of conduct and legal obligations as myself with regards to your confidentiality. Their role is to contact you, inform you of my incapacitation and support you, for example, to access alternative care. They will also destroy the records I hold in-line with GDPR compliance. The ‘Professional Executor’ is the only other person who knows the password to access the encrypted password-protected external device  containing your contact information, required to facilitate contacting you. They do not know the password to access the pin protected digital locking safe, the password to access your case notes, the password to access your bank details, nor do they have a key to my place of work.

I have also appointed a ‘Financial Executor’. Their role in the event of my incapacitation is to access my financial records, work out who has paid for sessions ahead of time and refund you for any unfulfilled work. They are the only other person who knows the password to access the encrypted password-protected external device containing your banking information, required to facilitate refunds. They do not know the password to access the pin protected digital locking safe, the password to access your case notes, the password to access your contact details, nor do they have a key to my place of work.

Finally, I have a ‘Clinical Will Initiator’ whose role is to inform the ‘Professional Executor’ and ‘Financial Executor’ of my incapacitation so that the Clinical Will can be enacted. They will also support the ‘Professional Executor’ and ‘Financial Executor’ to access the records necessary to perform their duties as described above. My ‘Clinical Will Initiator’ has the key to my place of work and the pin to access the pin protected digital locking safe, however they do not have the password to access any encrypted devices stored therein, and so are not able to access your information.

Sessions are carried out together using ‘MS Teams’ app by Microsoft, a video conferencing facility. This will involve me sharing your email address in order to invite you to an appointment and create a ‘link’ where you can access your appointment. Microsoft will invite you to download the software for MS Teams however you can join as a ‘Guest’ if you would prefer. For more information, you can find Microsoft’s Privacy Statement at the following link - https://privacy.microsoft.com/en-gb/privacystatement

I am currently banking with Natwest using the Mettle facility, and as part of setting up payments, invoices or completing transfers to pay for your therapy sessions they will require your name, bank account number and sort code. You can find their Privacy Policy at the following links –

Natwest Privacy Notice - https://www.natwest.com/privacy-policy.html

Mettle Privacy Notice - https://www.mettle.co.uk/blog/mettle-privacy-notice

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 my email [email protected] 

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 kept securely on encrypted password-protected devices and is not shared with any third party. I will keep written notes of each session (case notes) in a Microsoft Word Document, which is saved to an encrypted password-protected device, and at the end of the workday is stored in a pin protected digital locking safe.

A dedicated and password protected work phone is used to make business calls and send text messages, and the phone history/messages will be deleted once I have switched the phone on and read them. Likewise, any emails you send to my dedicated email address will be password protected and stored securely by Microsoft until I log on to read them. Any emails received and sent to you will be deleted once I have read them.

If there is relevant information contained in a text message or email I will type this into your case notes before deletion.

Emails, voicemails and text messages are monitored regularly and I will endeavour to answer and delete these within 1-2 weeks. The maximum time they will be stored for will be one month in circumstances where I am on annual leave and have not had an opportunity to log in and respond.

Recording clinical sessions using audio and video

Reasons for recording therapy sessions include:

• Supervision and professional development
  
  All psychological therapists receive clinical supervision on a regular basis.  For continual professional development and accreditation purposes therapists are required to record therapy sessions using video or audio so that they can reflect upon and improve their therapy with the people they see.   
  
  The video/audio recordings are used to study exactly how the therapy is provided to you. The recordings are viewed by your therapist and their clinical supervisor with the goal of ensuring the quality of the therapy you are receiving. All professionals are required to maintain confidentiality concerning the content of the recordings, in keeping with their accrediting body policies on confidentiality.
  
  
• Your own use 
  
  Additionally, it is common practice for therapists to encourage you to listen to a recording of your sessions yourself so you can remember, reflect and learn between sessions. If it is recorded you may borrow or have a copy of the recording upon request. 

All recordings will be made on the MS Teams platform and stored confidentially on the Microsoft Teams OneDrive. The recording is available for you to observe in the chat for a period of 28 days before being deleted permanently from this platform.

Recordings will be permanently destroyed in a secure way when no longer required for the above purposes. This would be as soon as possible following viewing this in supervision unless this has been discussed and agreed otherwise with you. 

You may withdraw your consent at any time without giving a reason and continue to receive treatment.  You may also ask for the video or tape to be turned off at any point if you do not want part of the session to be recorded.

Visitors to my website

When someone visits my website, I use a third-party service, Unlimited Web Hosting 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 processed in a way that does not identify anyone. I do not make, and do not allow Unlimited Web Hosting 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 Cloudflare so that I can continually improve my service to you. You can read Cloudflare’s privacy notice here https://www.cloudflare.com/en-gb/trust-hub/gdpr/

I use SiteHub via CPanel as the content management system for our website.

No user-specific data is collected by me or any third party.

If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.