This privacy policy concerns the information I collect from you and my reasons for doing so.

 

In order to provide a therapy service to you, I need to ask for your basic personal information (legally termed ‘personal data’) such as your name and contact details, as well as sensitive information (‘special category data’) relating to your mental health and other aspects of you and your life that can provide context for your experiences as a human being (e.g. sexual orientation, ethnicity etc).

 

I am required under the General Data Protection Regulation (GDPR) to have a lawful basis for processing your personal data. The most appropriate lawful reason in this case is 'legitimate interest,' which means that I need to know personal information about you to enable me to provide you with my service. As such I am a ‘Data Controller’, and by law I am required to be registered with the Information Commissioner's Office (ICO).

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The personal information I collect typically includes:

Your first name and last name, your date of birth, your gender/preferred identity, your address and other contact details such as your phone number or email address, your next of kin/emergency contact, your GP contact details, prescribed medication, your family relationships including any children, your occupation and any other personal details that may be relevant to your circumstances and reasons for seeking therapy. As you would expect, I will also ask about your psychological history and current difficulties. 

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I collect data from you in a variety of ways including via electronic forms, therapy notes and records, letters, reports, diagrams and outcome measures. It is also typical of my practice to video record sessions to review later for the purposes of improving the therapy I provide to you. This is not mandatory, however, and you are able to opt out if you are not comfortable with this. I typically erase all video recordings after you have completed therapy unless you express a wish to return at a later date, in which case I may continue to store existing videos as part of your ongoing therapy record, unless you prefer otherwise. 

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If you are referred to me by your health insurance provider, GP or any other third party service or organisation, I will also collect and process personal data provided by them. This will likely include basic contact information, referral information, your health insurance details and authorisation for treatment, copies of reports, letters and emails relating to your care.

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How I store your personal information:

I am committed to protecting your privacy. I take all reasonable steps to keep client personal information confidential and store it in accordance with General Data Protection Regulation (GDPR) rules. Personal information is stored on encrypted external devices and on a password-protected office computer with protection against malware, spyware, ransomware and viruses installed. Mobile phones and other portable devices are protected with a passcode as well as security and antivirus software. Information may also be stored in GDPR-compliant secure cloud services. I anonymize information where possible so that individual clients cannot be identified. You may be asked to use your initials instead of your name at times for this purpose.

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How long I store your information for:

I store your personal information in line with the recommendations of my regulatory body the Health and Care Professions Council (HCPC) and the NHS, which is currently a minimum of 7 years after the last treatment or discharge for adults and until their 25th birthday for children (26th if the patient was 17 when treatment ended). After this time, your data will be carefully disposed of. Some records may be held indefinitely if there were any issues of concern that could lead to a police investigation in the future.

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Accessing personal information I hold:

You have rights around your personal data and how I handle it. You have a right to access the information held about you by making a ‘subject access request.’ I will usually share this with you within 30 days of receiving a request. There may be an administration fee for supplying the information to you and I may ask for further evidence to check your identity. 

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You have a right to correct your personal information if it is factually inaccurate. I try to meet the highest standards when collecting and using personal information and encourage clients to bring any concerns to my attention. You can also make a complaint to the Information Commissioner’s Office if you would like to escalate any concerns about my handing of your data. I reserve the right to refuse a request to delete a client’s personal information where this relates to their therapy records for reasons including indemnity insurance, defence against possible complaints and/or for safeguarding purposes.

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Circumstances where I may have to share your personal data:

Your information will be kept confidential at all times and only shared with others where absolutely necessary and with your consent. However, I may have to break confidentiality under special circumstances where I am legally required to do so. For example, if I become concerned about your safety, my duty of care to you may require that I discuss your care with other services or organisations such as your GP or a mental health crisis team. I will always try to do this with your consent, but may have to act even if you refuse. In addition, if I believe that you intend to cause harm to another person/group/organization, the law may require that I inform an authority without your knowledge and without seeking your permission. Similarly, when disclosure is in the public interest, such as to prevent a miscarriage of justice or where there is a legal duty, for example a court order, I may have to share your information. Generally, I will endeavour to discuss any potential disclosure with you unless I believe that to do so could increase the level of risk to you or to someone else.

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If you are referred by your health insurance provider, or are otherwise claiming through a health insurance policy to fund therapy, then I will share appointment schedules with that organisation for the purposes of invoicing. I may also share information with that organisation to provide treatment updates if required. Similarly, in cases where treatment has been instructed by another service or organisation, relevant clinical information from therapy records will be shared with these services as required and with your consent. I will share appointment schedules with such organisations for the purposes of invoicing. I may also share information with such organisations to provide treatment updates if required.

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I might need to share personal information with other relevant health providers, such as your GP, on a need-to-know basis. 

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I will never use your personal information for marketing purposes or send you marketing materials without your explicit consent.

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Website collection of information and cookies:

I collect your personal information when you voluntarily complete the contact form on this website. The website also uses cookies, which are small pieces of data stored on your browser. My website uses essential cookies which are necessary for the website to function properly and enable you to use its features. They do not require your consent. My website also uses analytical/performance cookies, which help me collect information about, for example, how often people visit the website, and which pages are visited most often. This information helps me improve the website's performance and user experience. Functionality cookies allow the website to remember your preferences and settings while targeting/advertising cookies are used to deliver relevant ads to you, track your website activity, and personalize your browsing experience. Third-party cookies may be used to provide certain features or services and are set by third-party services, such as analytics platforms or advertising networks. I do not control the use of these third-party cookies and are not responsible for their practices. You can manage your cookie preferences by adjusting your browser settings. You can choose to disable cookies entirely, but please note that this may affect the functionality of the website. You can also use various browser add-ons or tools to control and manage your cookie preferences and you can opt-out of certain types of cookies, such as targeting/advertising cookies, by visiting the privacy settings of relevant third-party service providers.

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I reserve the right to modify this privacy policy at any time. Changes and clarifications will take effect immediately upon their posting on the website. If I make material changes to this policy, I will make this clear. 

 

In the event of my death or incapacity, arrangements have been made for records to continue to be held in accordance with the recommendations outlined above.

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