.png)
Privacy Notice
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 the initial point of contact through to after your therapy has ended, including:
· Why I am able to process your information and what purpose 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 emma.mason.counselling@gmail.com
‘Data controller’ is the term used to describe the person/organization 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, my registration number is ZA518281
My phone number is 07743034177 My email address is: emma.mason.counselling@gmail.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, email address, phone number and a general overview about what you would like to bring to counselling. Alternatively, your GP or another 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 3 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 I believe that you (the client) are at serious risk of harm to yourself or others if you tell me that you are involved in an act of terrorism, drugs trafficking, money laundering or if I believe a child or vulnerable adult is a risk of harm. I also discuss client work with my supervisor who I see on a monthly basis, you will remain anonymous throughout and supervision sessions are confidential. 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 in a locked cabinet at my home and are not shared with any third party.
I will keep written notes of each session; these are kept in a locked cabinet at my home.
For security reasons, I do not retain text messages for more than one month. If there is relevant information contained in a text message I will transfer the information onto your counselling notes and keep them locked away securely at my home. Likewise, any email correspondence will be deleted after one month if it is not important. If necessary I will make a paper record and keep this locked away securely at my home.
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, this is for insurance purposes. 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 email that I use is provided by Google, while I am assured that this service is secure, there may be times when Google can acquire some data such as an IP address which is needed to send the email in the first place. Google also have a privacy notice in place and are committed to keeping any data secure. Google's privacy notice can be found here My phone network is through Giffgaff who does have access to phone numbers, texts, emails and other communications received by me. This is data that Giffgaff collect automatically in order to provide me with a phone bill and to measure my data usage. Giffgaff also has a privacy notice in place and are committed to keeping any data secure, their privacy policy can be found here. My website is hosted by Wix while I am assured that this service is secure, there may be times when Wix can acquire some data such as an IP address, your name, enquiry and email address when you fill out a contact form on my website. Wix also has a privacy notice in place and are committed to keeping any data secure, this privacy policy can be found here. You may choose to book a session using Calendly and while I am assured that this service is secure there may be times that Calendly can acquire some data such as your name, phone number, email address and IP address. Calendly has a privacy notice which can be found here.
​
Sharing Information
​
I will not share your personal information unless there is a clear reason to do so. Depending on the circumstances, I may share limited information with the following people or organisations where this is necessary, proportionate and lawful:
• my clinical supervisor
• professional advisers, such as an accountant, insurer or legal adviser
• my professional body, if required in relation to a complaint or ethical matter
• safeguarding services, emergency services or your GP, where there is serious risk or safeguarding concern
• a court or legal authority, if required by law
• an appointed clinical executor if I die or become unable to contact clients myself
• trusted digital service providers who process data on my behalf
​
Where I share information, I aim to share only what is relevant and necessary for that purpose. If I or one of my providers transfers personal information outside the UK to a separate organisation, I will only do so where the law allows it and an appropriate transfer mechanism or other safeguard is in place where required.
​
Clinical Will​
​
I aim to have arrangements in place so that clients can be contacted if I die or become seriously incapacitated.
This may involve a trusted professional colleague or clinical executor having access to the minimum information needed to contact current clients and manage records appropriately. That person would be bound by confidentiality, would only access information if necessary, and would not take on an ongoing therapeutic role unless separately agreed and appropriate.
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:
-
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 emma.mason.counselling@gmail.com.
​
If you have a concern about how I have handled your personal information, you can make a data protection complaint by contacting me using the details in this notice. I will acknowledge your complaint within 30 days and take appropriate steps to look into it without undue delay.
Please include:
• your name
• what your concern is about
• what you would like me to look into
• how you would prefer me to respond
​
I will investigate your complaint as appropriate, keep you informed where necessary, and tell you the outcome without undue delay.
If you are not satisfied with my response, or if you would prefer to contact the UK regulator directly, you can contact the Information Commissioner’s Office:
Website: www.ico.org.uk Telephone: 0303 123 1113
Data security
I take the security of the data I hold about you very seriously and as such, I make every effort to make sure it is kept secure. Your client contract, notes and any worksheets from our sessions are kept in a locked filing cabinet in my home. I am the only person with access to the keys. Although I have listed the third party services I use for email, phone, text and my website, I am assured that these services are secure and safe to use in terms of data. My phone is password locked at all times when I am not using it and I am the only person who knows the password. I also do not save any passwords on any devices, therefore, your data is kept secure.
Visitors to my website
When someone visits my website, I use a third-party service, Wix, to collect standard internet log information and details of visitor behaviour patterns. I do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way that does not identify anyone. I do not make and do not allow Wix to make any attempt to find out the identities of those visiting my website.
I use legitimate interests as my lawful basis for holding and using your personal information in this way when you visit my website.
I use Google Analytics so that I can continually improve my service to you. You can read Google’s privacy notice here
I use Wix as the content management system for our website - find out about Wix’s data protection here:
Like most websites we use cookies to help the site work more efficiently - find out about our use of cookies.
No user-specific data is collected by me or any third party. If you fill in a form on my website, that data will be temporarily stored on the web host before being sent to me.
​
I may update this privacy notice from time to time to reflect changes in my practice, legal requirements, professional guidance or the systems I use.