Privacy Policy

Privacy & Your Data

Comments

When visitors leave comments on this site, it collects the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Media

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Cookies

If you leave a comment on the site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

Who we share your data with

If you request a password reset, your IP address will be included in the reset email.
This site also uses Google Analytics to track performance and if you submit a form it is stored on the WordPress Dash Board as well as being emailed to me at [email protected]

How long we retain your data

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

What rights you have over your data

If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

Where your data is sent

Visitor comments may be checked through an automated spam detection service.

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 protected]

077 498 70502

‘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 as Mr Simon John Hughes, ref no ZA771472.

My lawful basis for holding and processing your personal data

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 personal information

When you contact me with an enquiry about my counselling services I will collect information to help me satisfy your enquiry. This will include contact details and availability for therapy.
Alternatively; a referral agency, 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 a calendar month. If you would like me to delete this information sooner, just let me know.

Whilst you are accessing counselling

Rest assured that everything you discuss with me is confidential. That confidentiality will only be broken in the event of severe risk of harm to yourself or others. In which case I will always try to speak to you about this first, unless there are safeguarding issues that prevent this. There are some legal reasons I also may need to break confidentiality such as a court order, the Terrorism Act, money laundering, or child protection. Finally, I have supervision in which I speak about my process with the clients I work with, but your information will be kept anonymous and confidential.

I will keep a record of your personal details to help the counselling services run smoothly. These details are kept securely in paper form in a locked filing cabinet, and not shared with any third parties. I will keep hand-written notes of each session; these are kept in a locked filing cabinet. I also keep a log of sessions which are stored electronically on a password protected device.
For security reasons I do not retain text messages for more than a month. If there is relevant information contained within a text message, I will copy it onto your paper file. Likewise, any email correspondence will be deleted after one month if it is not important or, if necessary, kept for six years from the date we end counselling.

After counselling has ended

Once counselling has ended, your records will be kept for six years (over 18) 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 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. The third parties are as follows, and each third party has a link to their data processing agreements:

> Zoom – I use Zoom for video messaging to conduct therapy sessions. They are an extremely safe and confidential provider.
> Vodaphone – provide the telephone network I use for first contacts or telephone counselling
> Protonmail – are the email provider I use. They are renown for being one of the most confidential providers with easy access to encryption.
> Elementor Pro/Google Analystics/Wordpress – are plug ins used in the maintenance and hosting of this website.
> Supervisors – I have supervision to ensure the quality, ethics, and safety of my clinical work which is an ethical requirement of my accrediting body. I do not disclose identifiable details of my clients in supervision other than first name, and mostly use supervision to focus on my process with clients. My supervisors uphold the same level of confidentiality as me and have their own data processing agreements.
> Psychologists Protection Society – provide my personal indemnity and public liability insurance. I need to contact them if a claim is brought against me with details of the claim.
> Microsoft 365 –MS Word and Excel which I use for monitoring, logs, and invoicing.
> Information Commissioning Office – I will notify them if I breach confidential information but not pass across your information
> HMRC and Quickbooks – I use these for filing my taxes which includes receipts or invoices
>Referral Agencies – If you have been referred by an agency, they may require me to send certain information to them according to their individual privacy policy. I am happy to discuss this in more detail. For example, Hope require invoices for sessions and details in the event of a complaint
> Further Training – If I am undertaking further training, they sometimes require information for course completion. If this arises, I will discuss this with you and seek consent. Likewise, I am working towards accreditation with the British Association for Counselling and Psychotherapy which requires client and supervision logs as well as some information on my learnings.


Clinical will

In the event of my death or incapacity, I have appointed a clinical executor who will contact you to let you know I am unable to continue counselling and talk you through options such as referral. They will have access to your records and session notes to make this contact. I have also appointed a technical executor to destroy all hand-written and digital records in this event.

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 www.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 to [email protected]

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 www.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 using lockable filing cabinet, encrypted emails, encrypted files, password protection, pseudonymisation, and deletion of records from email/texts.

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