Privacy Policy

This 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.

‘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 adhere to current data protection legislation, including the General Data Protection Regulation (EU/2016/679) (GDPR), the Data Protection Act 2018, and the Privacy and Electronic Communications (EC Directive) Regulations 2003. I am registered with the Information Commissioner’s Office.

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 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. 

• 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.

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).

Initial Contact

When you contact me with an enquiry about my counselling services, I will collect information to help me satisfy your enquiry. This may include your name, email address and phone number. 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 with sessions, your personal data is deleted within 3 months. If you would like me to delete this information sooner, let me know. 

While you are accessing counselling

I will keep a record of your personal details to help the counselling services run smoothly. These details are kept securely on password-protected and encrypted database. Neither your data nor the device it is stored on are shared with any third party. If I make handwritten notes during a session, these are converted to digital notes, afterwhich the original handwritten notes are destroyed. I may make brief attendance notes following our sessions. 

Everything you discuss with me is confidential. That confidentiality will only be broken under specific circumstances given below. If I feel I need to break confidentiality, I will always try to speak to you about this first, unless there are safeguarding issues that prevent this.

• Consent: With your consent, I may share your information with your GP, professional services, your emergency contact, or others whom you have agreed I should contact.

• Serious Harm: I may share your information with the relevant authorities if I have reason to believe that this may prevent serious harm being caused to you or another person. Where possible, I would always seek your consent first, but if this is not possible, my duty is to act to prevent harm.

• Compliance with Law: I may share your information where I am required to by law or by regulations and other rules to which I am subject, e.g. I may be required to pass identifiable and/or non-identifiable client information onto professional or financial organisations, which are also bound by confidentiality under GDPR, such as the BACP, the ICO, HMRC, my insurance company, solicitor, accountancy firm or bank. 

• Clinical Supervision: As part of practicing ethically, I may take session material to individual/group supervision, and/or peer groups, which are bound by the same confidentiality principles as our work. If I do share content of our sessions in such clinical spaces, I will omit any information that could identify you. 

• Therapeutic Will: In the event of circumstances that prevent me from upholding the contract between us, e.g. if I fall seriously ill or die, a trusted colleague will gain access to your data, in order to inform you of my circumstances and, where desired, support you in making alternate counselling arrangements.

After counselling has ended

After we finish our work together, I will store your personal information and any session notes I have made for 3 months after our final session. Brief attendance notes will be kept in my legal and insurance obligation for a period of 5 years following the final session of clinical work. All data will be stored securely until this period lapses after which it will be destroyed. 

I sometimes share personal data with third parties, for example, where I have contracted with a software 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. 

I use Google Workplace to provide my counselling services, including Google Meet for my video calls. Find out about Google and data protection.

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 emmasimpson.counsellor@gmail.com. 

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.

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. The information I hold on you is stored digitally on encrypted devices which require two factor authentication to access. In keeping with my Climate Pledge, I do not store physical notes.

Visitors to my website

When someone visits my website, I use a third party service, Google Analytics, 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 Google Analytics 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,  Google Sites as the content management system for this website - find out about Google and data protection.

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