Privacy Policy
Introduction
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 legislation, including the General Data Protection Regulation (EU/2016/679) (the GDPR), the Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
This 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:
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Why I am able to process your information and what purpose I am processing it for
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Whether you have to provide it to me
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How long I store it for
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Whether there are other recipients of your personal information
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Whether I intend to transfer it to another country,
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Whether I do automated decision-making or profiling, and
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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 annachannoncounselling@outlook.com.
‘Data controller’ is the term used to describe the person/ organisation that collects and stores and has responsibility for people’s personal data. In this instance, the data controller is me. I am registered with the Information Commissioner’s Office (registration reference: ZB317226).
My postal address is: 2 Walton Road, Marholm PE6 7JD. My phone number is: 07591454912. My email address is: annachannoncounselling@outlook.com.
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.
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 legitimate interests so that I can keep accurate records to provide safe, effective therapy. I will then retain any counselling records in case of the need to reference them in the future (the official legal basis is to defend against potential legal claims).
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 name, contact details, brief overview of reasons for wanting to attend counselling.
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 six months. 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:
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There is a serious risk of harm
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There is a legal or safeguarding obligation
This includes situations where risk is assessed as significant, and the individual may no longer be able to keep themselves safe.
All therapists assess risk as part of ongoing clinical work. Where clients are identified as higher risk, formal risk assessments are completed and recorded in secure client notes.
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 on my password protected laptop in and are not shared with any third party unless my Clinical Will is actioned (see ‘Third party recipients of personal data below).
I will keep written notes of each session, these are kept on my laptop. For security reasons I do not retain text or WhatsApp messages for long periods. If there is relevant information contained in a message, I will transfer this to your session notes.
Likewise, any email correspondence will be deleted after counselling has ended. Email is not always a completely secure method of communication. While I take appropriate steps to protect your personal data, you should be aware that there is some inherent risk when communicating by email.
Once counselling has ended your records will be kept for seven 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 use carefully selected third-party service providers to support my practice. These providers process personal data on my behalf where necessary and are required to protect your information in accordance with data protection law. These include:
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Microsoft – to provide secure email communications (Outlook) and secure storage and backup of electronic records (OneDrive).
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Wix – to host my website and process information submitted through my website contact form.
If agencies such as the police request your information, we will discuss this together and agree how to proceed in your best interests. The only situation in which I am required to share your information is if ordered by a court whiteness summons or subpoena.
A Clinical Will is a plan for if I were to be unexpectedly incapacitated. In this situation, a trusted colleague would access your information to contact you on my behalf. They would then process your information appropriately, in line with this 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:
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give you a description of it and where it came from;
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tell you why I am holding it, tell you how long I will store your data and how I made this decision;
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tell you who it could be disclosed to;
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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 annachannoncounselling@outlook.com.
Data Protection Complaints Procedure
If you have any concerns about how I handle your personal data, I encourage you to contact me directly in the first instance. I am committed to resolving any concerns promptly and transparently.
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How to make a complaint: You can submit a complaint by emailing annachannoncounselling@outlook.com. You can also complain by post - my address is available on request.
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What to expect: I will acknowledge your complaint within 30 days and keep you informed of progress throughout. I will provide a clear outcome once my investigation is complete.
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Complaints to the ICO: You also have the right to complain directly to the Information Commissioner's Office (ICO) at any time at 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. However, no method of transmission over the internet is completely secure.
I use two factor authentication to access my Microsoft account to increase security on my laptop.
Any paper forms/documents are shredded once I have uploaded them to my laptop. Any ongoing work on paper is locked in my cupboard after sessions and destroyed once counselling has ended.
