General Data Protection Regulation (GDPR) Policy.
Information about Personal Information collected, stored and processed. Plus your rights.
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The General Data Protection Regulation (GDPR) is concerned with your personal data that I collect, store, and share.
This page details my GDPR policy.
Personal Data I will Collect.
- Gender (birth gender, or your corrected identity, whichever you prefer).
- Date of Birth.
- Relationships & Progeny.
- Telephone/SMS number (plus permission to send SMS & leave voice message).
- Email address.
- Counselling History.
- Medical conditions relevant to counselling.
- Prescribed medication, relevant to counselling.
How I will store your Personal Data.
- Paper: written notes (described below).
- Smartphone: I will store your contact data (Name, mobile #, email address) in a plain-text note app that backs up to my private Google Drive. This allows me to contact you in case of emergencies, but keeps from revealing this data to other applications (i.e. not using a Contacts app).
- Email/SMS/WhatsApp: your email address and correspondence will be stored in my email account (currently GMail) by nature of you contacting me. Your telephone number may be stored in my SMS or WhatsApp app should we exchange messages this way. Electronic correspondence will also be held by the corresponding app (Gmail, Phone's SMS, WhatsApp).
- Website: none of your personal data is stored on my website, other than to momentarily collect & send it to my Gmail account for the purposes of our initial contact, after which is automatically erased.
A note about GMail (Outlook etc) and Electronic Messaging Systems - free electronic email & messaging services (Gmail, Outlook, Facebook, WhatsApp etc) regularly read incoming & outgoing messages electronically. One of the reasons for this is that the service gains knowledge about the messaging user for the purposes of selling advertising to other companies. To put it plainly: if you email me about the topic of, say, your sexuality using your GMail address it's very likely sexuality will be associated with your email account... which will possibly attract associated advertising topics wherever you're logged in with that same account (eg Google.com).
Best advice I can give is (a) to read the terms of service your free messaging provider and (b) to be cautious in what data you include when communicating electronically.
- Contact Sheet
- Assessment Record
- GDPR Agreement
- Client Code (linking documents)
- Brief Session Notes*
- Contact name & telephone
How I may Process/Share your Personal Data.
I seek a monthly consultation with another therapist qualified in this process. The consultation process is for my practice (rather than seeking instruction on working with you). In order to protect your privacy, my consultant will not know you personally nor professionally. I will refer to you by your first name, and I may refer to your data verbally when it's helpful to my professional processes.
*Session summaries are my aide mťmoire to assist me in my consultation processes; they are my property.
Your name and contact details will be shared with my Therapeutic Executor. This is so that you will be contacted on the event of my death, should you still be in therapy with me.
If your health is in jeopardy (provided I have your consent) I may share your contact data with an emergency healthcare service (e.g. Mental Health Crisis Team).
If I have become aware of your intent to cause harm to another person/organisation (e.g. terrorism), the law may require that I inform an authority without seeking your permission. In such a situation, the law may require that I share your personal data without your knowledge (known as: whistle-blowing).
Erasing your Data.
When we have finished working together, I will erase electronic copies of your data & correspondence within one month.
I will hold onto your written/printed data for up to seven years past the end of our working together. This is so that I have a reference of our work in situations such as you returning to counselling in the future. After this time has passed, I will destroy the written/printed data.
You have the following rights...
- To be informed about what data you are giving me which I will record / have recorded (i.e. to be given this document).
- To see the data you have given me about yourself** (free of charge for the initial request only).
- To rectify any inaccurate or incomplete personal data about you**.
- To withdraw consent to me using your personal data about you**.
- To request your personal data be erased** (though I may decline the request whilst the data is needed for me to practice lawfully & competently).
** With individual counselling "you/your" refers to yourself alone. With couple and group counselling "you/your" refers to you as an individual and therefore you may only make a GDPR Data Request for data held about you as an individual; you may not request data held on your partner (couples) and you may not request data held on any other member of the therapy group (groups). *With respect to my session notes they reference either the individual (individual counselling), the couple's relationship (couple counselling) or the group dynamic (group counselling) depending on the counselling service contracted. Therefore, to request a copy of my notes under GDPR: as a couple both your permissions will be required (and a copy will be sent to both partners simultaneously), and for a group every group member's permission will be required (and a copy will be sent to all group members simultaneously).
NB: A printed copy of this statement will be given to you when we first meet for counselling. If we agree to continue working together, we will both sign the printed copy of this statement to indicate our agreement.
If you’re a counsellor or other therapist, you may use this page as a reference to forming your own policy. Please think… don’t just copy!
Policy formulated from Karen Emery’s website: Counselling in Notts –¬†GDPR Made Easy for Counsellors:-¬†http://www.counsellinginnotts.co.uk/gdpr-made-easy-for-counsellors-part-1 which references the ICO’s pages on GDPR.
PDF Version:¬†GDPR Compliance Statement for Havant Counselling
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