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.

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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:

• What purpose I am using your personal data for.

• Whether you have to provide it to me.

• How long I store it for.

• How I store your personal data.

• Whether there are other recipients of your personal information.

• 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. ‘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.

 

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My lawful basis for holding and using your personal information

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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 or your initial enquiry.

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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 consent initially. I will then retain any counselling records in case of the need to reference them in the future (the official legal basis is to defend against potential legal claims).

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How I use your information

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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 whatever personal details you offer at this stage, (usually contact details and what kind of therapy you are looking for/issues you need support with).

 

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 6 months. If you would like me to delete this information sooner, just let me know.

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While you are accessing counselling

 

Rest assured that everything you discuss with me is confidential. That confidentiality will only be broken if:

• You request that I speak to someone else.

• Where information is shared that suggests there may be safety issues for you or someone else.

• If there are child protection issues, or if disclosure of information is required by law.

• If you have divulged information about an act of terrorism, whether or not I believe it to be true.

 

I will always try to speak to you about this first, unless there are safeguarding issues that prevent this.

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I will keep a record of your personal details to help the counselling services run smoothly. These details are kept securely using a British Association of Counselling and Psychotherapy (BACP) approved electronic encrypted cloud database called Bacpac, which is specifically designed for therapists and is not shared with any third party. I will keep brief factual notes of each session, these are securely stored on Bacpac.

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If I am unable to work through illness, accident or death, I have a trusted therapist colleague, who has been given permission to access only the basic contact details of current clients on Bacpac. This is the colleague can inform clients of the current situation. Bacpac will not allow this colleague access to any client notes or other sensitive information.

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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 this onto Bacpac under your personal notes. My phone is password protected.

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Likewise, any email correspondence will be deleted after six months, if it is not important. If necessary I will attach relevant information to your client notes on Bacpac. My email is provided by ProtonMail, an encrypted password protected web-based provider, which I access through password protected devices.

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After counselling has ended

 

Once counselling has ended your records will be kept for 7 years from the end of our contact with each other and are then securely deleted. If you want me to delete your information sooner than this, please tell me.

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Third party recipients of personal data

 

I sometimes share personal data with third parties, for example, the suppliers who offer services to help me store data. In such cases I have carefully selected which partners I work with. I ensure that they do not use your information in any way other than the task for which they have been contracted.

 

Details of the services I contract are listed below:

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• My email is provided by ProtonMail, which is an encrypted web-based service.

• My computer software is provided by Microsoft 365, which is securely password protected.

• Bacpac is an encrypted database for therapists, which holds my client notes and personal details. There is a 2-stage encrypted log-in process each time I enter the database.

• As a sole trader, I am regulated by HMRC for tax purposes.

• I am regulated by the ICO for holding personal data.

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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

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If I do hold information about you I will:

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• give you a description of it and where it came from.

• tell you why I am holding it, 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, if requested.

 

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 your individual therapist, Lucy Preston at libertycounsellingyork@pm.me

Or Sarah Read at sarahlibertycounsellingyork@pm.me 

Please allow 28 days for information to be collated for you.

 

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 ico.org.uk/make-a-complaint

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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. I use encrypted devices, encrypted email and databases and a locked filing cabinet etc.

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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. 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 Wix so that I can continually improve my service to you. Like most websites I use cookies, which are small text files that are saved on your device to help the site work more efficiently – you can choose to opt out of the use of cookies on the website or through your browser settings. However, turning off cookies may affect how well my website or other websites work.

 

No user-specific data is collected by me or any third party on the website. If you fill in an enquiry form on my website, that data will be temporarily stored on the web host before being sent to me via email.

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Lucy Preston is registered with the Information Commissioner’s Office [Reference number: ZA792486].

You can search my ICO registration here Information Commissioner's Office - Register of data protection fee payers (ico.org.uk)​

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Sarah Read is registered with the Information Commissioner's Office (Reference number: ZB750816).

You can search my ICO registration here Information Commissioner's Office - Register of data protection fee payers (ico.org.uk)

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Please note that Lucy Preston and Sarah Read adhere to all of the above, but operate separate systems, so they do not share any data on individuals.  The only exception to this is in the case that Lucy or Sarah are unable to work due to illness, accident or death, in which case the other person will access basic contact information via Bacpac system to make contact with existing clients as detailed above.  

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Privacy Notice 2024