Pause and Process Counselling 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: • 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 jo@pauseandprocess-counselling.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 ZB493890 My postal address is: 15 Launds Green South Witham Lincolnshire NG33 5PX . My email address is: jo@pauseandprocess-counselling.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 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 your name and email address. 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 2 weeks. 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: You show intent to seriously harm yourself or others. You disclose, during session, something that leads me to believe that you are being harmed or that a child or a vulnerable adult is being harmed or at serious risk of being harmed. You disclose that you committed a serious crime or show intent to commit serious crime. You reveal intent to commit an act of terrorism or disclose involvement or information regarding drug trafficking or money laundering. If notes are requested by a Court of Law. 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 an encrypted device and are not shared with any third party. I will keep anonymised written notes of each session, these are kept in secure locked cabinet. For security reasons I do not retain text messages for more than 2 weeks. If there is relevant information contained in a text message, I will record this and store safely in the relevant area; either with client detail or within client’s notes. Likewise, any email correspondence will be deleted after 2 weeks if it is not important. If necessary, I will record and store this safely within the relevant area. After counselling has ended. Once counselling has ended your records will be kept for 5 Years from the end of our contact with each other and are then securely destroyed. If you want me to delete your personal contact 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
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