Privacy Policy - General Data Protection Policy

 

This Privacy Policy governs the manner in which Sandy Howard trading as Sandy Howard Counselling uses, maintains, and discloses information collected from clients using Sandy Howard Counselling. It applies to the practice, website and services offered by Sandy Howard Counselling online, by telephone or within my private practice.

 

For the purposes of the GDPR 2018, the data “controller” is Sandy Howard, Sandy Howard Counselling. Tel: 01522 820357 - Mobile: 07788 144232 - sandyjane4@hotmail.co.uk

 

I am registered with the ICO (Information Commissioner’s Office). The General Data Protection Regulation (GDPR) is concerned with the personal information about you that I collect, store and share.

 

Clients seeking therapy will be issued with a paper copy of this Privacy Policy at the initial assessment or, where possible, emailed a copy prior to meeting. They will be asked to sign to confirm that they understand and agree with how information is collected, stored and held before therapy can commence.

 

This policy covers all the principles under the Data Protection Act (‘DPA) 2018. These are known as the “data protection principles” and ensures information is:

 

    • Used fairly and lawfully
    • Used for limited, specifically stated purposes
    • Used in a way that is adequate, relevant and not excessive
    • Kept for no longer than is necessary
    • Kept safe and secure
    • Not transferred outside the European Economic Area with adequate protection

 

What Data do I collect?

 

    • Name and address
    • Gender (or preferred identity)
    • Email and telephone number
    • Date of birth
    • Emergency contact
    • GP name
    • Medications and medical conditions relevant to counselling
    • Counselling history
    • Use of alcohol and any illegal substances
    • Occupation
    • Expectations from counselling
    • Session notes 2

 

Documents Held

 

    • Signed copy of our counselling contract
    • Signed copy of the Privacy Statement
    • Assessment Form
    • Client code (allocated against Name and Address separately)
    • Client Notes anonymised

 

Why I need the information I hold about an individual

 

    • I need to request and store your details in order to administer and deliver the service you have requested and we have contracted to and to comply with any legal or professional body responsibilities that ensure the delivering of that service.

 

What I am going to use it for?

 

    • To make contact with you, to record the relevant personal contact details you give consent for me to hold, to record emergency contact information, where applicable to make clinical assessments and record clinical notes.

 

How will I store your data, is it being held securely?

 

Digitally:-

 

    • Your personal information is stored securely and confidentially. It is used in a safe and ethical manner. It is not shared with other people without your consent.
    • Telephone numbers, and email addresses are kept in my mobile phone / tablet and computer. I only use a first name in my electronic bookings calendar and paper diary.
    • Client notes showing a date and a brief outline of the session are recorded electronically only on my computer in a file format which has an anonymised code system.
    • Anonymised client codes are used to identify income source in my accounts for HMRC tax return purposes.
    • Anonymised information only is backed up to a separate drive which is kept securely.
    • My mobile phone and tablet are password protected, my computer is password protected and has antivirus software.

 

In Paper Format:-

 

    • Names only in a book where the anonymized code is allocated. This information is stored in a locked filing cabinet.
    • Paper contracts and Privacy Policy which have been signed by you and hand written assessment sheets from the first session are kept in a locked filing cabinet.

 

Website:-

 

    • Any personal information sent via my website will only be used to contact you with details of the service you have requested. Your personal details will not be retained for any other purpose nor will they be shared with any other organisation.
    • During contact via email, texts and phone calls please be mindful of the information you communicate as digital communication is not necessarily secure.
    • My website does not use cookies or other device identifiers.

     

How will I share your data?

 

    • The anonymized client notes are used only for my own clinical supervision (to comply with my professional body and good ethical practice). I share details about the client case but not the clients personal details unless a legal or safeguarding requirement requires me to do so.
    • My supervisor will be handed all of my counselling related paperwork should I become indisposed and will contact you and then destroy my notes.
    • Where I need to comply with a legal requirement to do so, but not without your knowledge (a court order for example).
    • To get in touch with your emergency contact if necessary.
    • Your data will not be transferred outside the EU.

 

EAP Clients

 

    • Your EAP may have given me more information than I would normally collect i.e. where you work and registration number. Each EAP is different but I do need additional information from them for referencing when I invoice them as a way of recognising your case. Information is sent via email which will be deleted as soon as I have been reimbursed for our work together.

 

How up to date is the information that I hold about you?

 

    • The personal information stored is as given to me on initial contact and only updated as and when you inform me of any changes.
    • Notes will be up to date usually on the day and no more than within 7 days of delivery of such service.

 

How long will I store your data?

 

When we have finished working together I will erase electronic communication, copies of your written information / assessment and correspondence within three months. Please note, for technical reasons electronic information cannot be entirely erased and could therefore remain accessible until the storage device is destroyed, wiped clean or formatted.

 

I will delete completely by electronic means the anonymized notes and destroy paper records including the Counselling Contract and Privacy Policy and the paper record where the anonymised code is added by shredding seven years after the end of our last contact. This is in line with legal and professional requirements of my governing body the BACP and insurance.

 

Your rights

 

You have the right to be informed, right to access, to ask me to erase or update any information that I hold about you. This includes your personal information that is no longer relevant to original purposes or if you wish to withdraw consent. In all cases and when considering such requests, these rights are obligatory unless its information that I have a legal obligation to retain.

 

Full details of your rights can be found at https://ico.org.uk.

 

Data Portability

 

As the client you have the right to receive your personal information which you have previously provided and have the right transfer to another party. If you are happy with the way your personal information is being collected, stored and used, please sign below. Thank you.

 

   
Sandy Howard Counsellor Lincoln Lincolnshire Sandy Howard Registered MBACP (Accred) | find us on Counselling Pages
     
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