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Under the new General Data Protection Regulation (GDPR) you have the right to know what personal information Hertford Counselling & Psychotherapy (HCP) holds about you, how your personal information is held and what HCP does with it; you have the right to consent to this or decline. You also have the right to have any personal information removed at any time even if you gave your consent before. Although HCP is not registered with the Information Commission’s Office (ICO) we do abide by their regulations.
What personal information does HCP collect about youInitial contact with HCP is by telephone, mobile or email. I will record your -
- initial contact details (email, telephone, mobile)
- how you came across HCP and
- brief reasons for seeking counselling psychotherapy
If you decide to book an initial meeting we will agree a date and time. If you decide not to book an initial meeting, I will immediately destroy your contact details using a secure document shredder.
During the initial meeting, I will make hand written notes. I will ask you for
- a postal address
- your date of birth
- a contact name and GP details (for emergency use only)
- about why you are seeking counselling psychotherapy
- the history of your relationships including family
- medical history and
- details of any other events or situations which continue to affect you
And finally having discussed our Policies, Terms & Conditions on
- Confidentiality, Data Protection and Privacy
- Governance and Supervision
- Fees, Cancellations and Non-attendance
I will ask you for written consent for HCP to hold your personal information. If you decide not to commit to weekly counselling psychotherapy or feel you are unable to give consent for HCP to hold your personal information, I will destroy all the information provided so far using a secure document shredder.
What additional personal information might be collected about you during your couneslling psychotherapy sessions
This will vary depending on what is discussed during your counselling psychotherapy sessions. My brief session notes, which are hand written after your session, are anonymous in that they do not contain any identifiable information such as your name, the names of others, organisations or locations.
HCP holds your personal information for the purposes of
- financial and accounting (invoicing and receipts of fees)
- administrative, legal and ethical
- supervision and
- to contact your named person and / or GP in emergency situations
I hold your personal information to help me
- contact you for scheduling of appointments
- aid in developing a professional therapeutic relationship
- to provide a professional service and
- freely admit I cannot remember everything ☺
Where does HCP hold your personal information
Your personal information is stored securely and confidentially.
- All the information I collect about you during first contact (phone or email), the initial meeting and counselling psychotherapy sessions is hand written on paper and stored in a secure cabinet.
- I hold your name and contact number on my business mobile. This allows me to contact you in cases of emergency. This information is not shared with any smartphone apps. The mobile is locked with a secure code.
- I hold your email and all electronic correspondence on a business laptop computer, currently using Gmail. All correspondence is transferred from the Gmail server to the computer’s C drive for safe storage. The computer is locked with a secure code and is protected with the latest version of Norton Security
How may HCP share / process your personal information
I will NOT share, sell or use for unethical reasons any of your personal information except in the following circumstances:
- Supervision - As a member of the BACP, I am required to engage in supervision to maintain a high level of professional standards, enhance the quality of work and advance learning. The supervisor is bound by the same ethical guidelines. To protect your privacy no identifiable information is revealed during these consultations.
- HMRC - I submit a simplified version of accounts to HMRC each tax year. These accounts do not contain any of your personal information. If HMRC request an audit of my accounts, I may have to provide the individual invoices and receipts.
- Legal Exceptions - Usually with prior discussion, I may disclose personal information
- with other relevant services if you reveal or I believe there is a threat of harm either to yourself or to others, including child protection
- as required by statutory legal regulations in instances such as crime, terrorism, drug money laundering, public safety or a court order for disclosure
How long does HCP keep your personal information
- After one month all electronic information will be deleted from the business computer and mobile phone
- After seven years all written and paper based information will be destroyed using a secure document shredder
Why Seven Years
There are a number of reasons for this:
- so I can reference your work should you return to counselling psychotherapy in the future
- any future legal requests
- in keeping with BACP ethical guidelines and insurance requirements and
- HMRC guidelines
What happens if I become unwell, disabled, incapacitated or die
I have a Living Will which details who (a named executor) will be responsible for contacting you, arrange referrals if applicable and managing my affairs including the continued safe storage and subsequent destruction of all your personal information. The named executor is bound by the same BACP ethical guidelines as myself.
How to make a data access request
You have the right to ask for
- a copy of your personal information free of charge
- any incorrect personal information about you to be amended or changed and
- any personal information to be erased
You also have the right to withdraw previously given consent for your personal information to be held. In all cases and when considering such requests, these rights are statutory unless there is a legal obligation to hold the information. To make a data access request or any other queries please Contact me in confidence. You also have the right to make a complaint to the ICO’s helpline on 0303 123 1113
How to make a subject access request
If you are an organisation such as a law enforcement agency or judicial body, please contact HCP in writing to request a copy of our Access Request Policy and Procedures.
Version 1.0 November 2018