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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 [add personal information you record at this stage]. 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 6 months. If you would like me to delete this information sooner, just let me know.
If you book an appointment through the website I receive your name, email address and phone number if you've added it, I use this information only to facilitate your appointment and if necessary contact you about your appointment (re-scheduling, contact if missed appointment etc.) I have access to the last four digits of your payment card only, any further payment information is handled and processed externally by the payment facilitator Squareup International Ltd., Fumbally Square, Fumbally Lane, Dublin 8, Ireland.
While you are accessing counselling. Rest assured that everything you discuss with me is confidential. This confidentiality agreement will be extended to include other relevant people if you indicate some serious harm or potential harm to yourself or someone else, and in particular a child . I will speak to you about this first, unless there are serious 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 locked fling cabinet and on locked mobile phone, and are not shared with any third party. I will keep written notes of each session, these are kept in a locked filing cabinet only. For security reasons I do not retain text messages for 6 months. If there is relevant information contained in a text message I will make a note of it in your clinical notes. Likewise, any email correspondence will be deleted after 6 months. Contracts and basic client information sheets are shredded no more than a year after therapy.
Once counselling has ended your non-identifiable notes will be kept for 7 years in locked filing cabinet, and separately your name & date of birth with client number will be stored on locked computer file. All information within your notes shall be used by Robert Brown CBT solely to facilitate your therapy, to comply with a legal request, or in defence of a complaint brought by you.
Contracts and basic client information sheets are shredded no more than a year after therapy.
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.
I use Microsoft cloud computing and Squareup Intl. process payments.
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 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 email@example.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
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.