Online and telephone counselling across the UK plus in-person counselling in Craven Arms and LUDLOW, Shropshire

Your privacy is important to me, and I am committed to keeping your personal information safe and secure and to using this information for the purpose it was given to me. I adhere to the 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 notice informs you what I will do with your personal information and applies to personal information that has been given from the initial contact by people to asking for information about the counselling service through to after the counselling has ended including the information given to arrange in-person, telephone, and webcam counselling appointments.

This notice includes:

• What information is collected
• How this information is used including the lawful basis
• The sharing of information
• The processing and storing of your information
• Your rights

If you have any queries about this notice, please contact me using one of the methods below:

Name: Julia Gibson

Phone Number: 07785 473785

E-mail: silverlanterc@proton.me

I am registered with the Information Commissioner’s Office (registration reference ZB3422756). I am the data controller which is the term used to describe the person or organisation that collects, stores, and has responsibility for people’s personal data.

This privacy notice is regularly reviewed and amended according to the legislation at the time, and you are advised to also review this notice regularly.

I currently collect and process the information that is provided during interactions with you in order to arrange counselling sessions including the completion of any forms:

• Contact information from the initial contact which may be a telephone number and/or email address.
• Personal identifiers including first and last name, contact information such as address, telephone number(s) and email address, and other personal information given by you in order for an initial appointment to be arranged.
• Contact information for GP and/or other medical professionals working with you in case I am concerned about your safety and may need to contact your GP. Unless this is an emergency, I will endeavour to discuss this with you and obtain your consent.
• Medical information needed to assist counselling such as any medical diagnosis that may be relevant during the counselling process or in the case of an emergency. Also, any current medication that may impact our work together.
• The client agreement that sets out our work together and is signed by you.
• The GDPR Consent form that outlines this notice and is signed by you as your consent to the collection and storage of information as outlined within this document.
• Notes taken at the initial appointment, during the period of counselling and your feedback at the end of counselling. These notes are brief, factual, taken to assist the provision of counselling within the ethical framework of the British Association of Counselling and Psychotherapy (BACP) and for clinical supervision.

I use a unique ID code in order to anonymise the client notes and this information is kept separate to the notes in a locked filing cabinet.

Most of the personal information I process is provided to me directly by you in order to arrange the initial and further counselling sessions. This is from completion of the contact details form that is emailed to you following your initial contact or may be completed by me during the initial telephone call.

I use the information that you have given me in order to proceed with the counselling sessions.

If you decide to not proceed with counselling, I will ensure all your personal data is deleted within a month. Please let me know if you would like me to delete this information sooner.

Everything you discuss with me is confidential. This confidentiality will only be broken if I am concerned about your own or someone else’s safety and I may need to contact appropriate third parties (e.g. your doctor, emergency services.) Where possible, I will discuss this with you first. Also, I am legally obliged to report any involvement in, or knowledge of, terrorism or treason, drug trafficking and money laundering.

Under the UK General Data Protection Regulation (UK GDPR), I must have a lawful basis to process your personal information. There are different lawful bases depending on which stage of the counselling it is when I am processing your data:

• If you have contacted me to consider counselling or if you are currently having counselling, I will process your personal data where it is necessary for the performance of your contract.
• If the counselling has ended, I will use legitimate interest as my lawful basis for holding and using your personal information.

Any sensitive personal information is called ‘special category personal information’ under the GDPR. The lawful basis for processing any special categories of personal information is initially consent. I will retain any counselling records for five years in case there is a need to reference them in the future (the official legal basis is to defend against potential legal claims).

I have planned with my clinical supervisor in case I am unable to continue to work with you due to illness or other unforeseen events. I will email your first name and contact information to my clinical supervisor using the encrypted email service with in Protonmail. This involves using a password that only my clinical supervisor and I know. My clinical supervisor will open this email and contact you if I am unable to continue to provide a counselling service.

You are able to remove your consent at any time. You can do this by contacting Julia Gibson using the contact information above.

Your information is securely stored in locked filing cabinets with personal identifiable information being kept separately from other counselling records such as the notes. I am the only person who has access to the filing cabinets. Every client is given a unique reference number in order to anonymise the counselling notes.

I use a separate mobile telephone for counselling work which is password protected. I may store your telephone number using your initials in order to contact you regarding counselling sessions. Any texts sent or received, the call log and contact information will be deleted when counselling has ended. Relevant information from text messages will be recorded within the counselling session notes.

I use a password protected laptop for conducting video counselling sessions. I will send the link to you using the email address you have given me. This will be sent using my Protonmail email account. My Protonmail account is password protected and is only accessed by me. I will delete any email history from my account when counselling has ended. The laptop also has virus protection software.

I may use a password protected computer or tablet to access my emails and I am the only person who has access to these. I may also use a password protected mobile telephone to access my emails and I am the only person who has access to this. The computer and my business and personal mobiles phones also have virus protection software. Relevant information from emails will be recorded within the counselling session notes. Any emails sent or received will be deleted when counselling has ended.

I keep the counselling records for 5 years after counselling has ended or after our last contact with one another. The information is stored in filing cabinets with personal identifiable details kept separately. The records are then disposed by shredding after 5 years. Client contact details are held for one year after the counselling has ended.

Under data protection law, you have rights including:

Your right of access - You have the right to ask me for a copy of your personal information and for this to be free of charge for the initial request.

Your right to rectification - You have the right to ask me to rectify personal information you think is inaccurate. You also have the right to ask me to complete information you think is incomplete.

Your right to erasure - You have the right to ask me to erase your personal information in certain circumstances such as when the counselling has ended.

Your right to restriction of processing - You have the right to ask me to restrict the processing of your personal information in certain circumstances.

Your right to object to processing - You have the the right to object to the processing of your personal information in certain circumstances.

Your right to data portability - You have the right to ask that I transfer the personal information you have given to me to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, I have one month to respond to you from the receipt of your request.

Please contact Julia Gibson, the data controller, if you would like to make a request under any of these rights. The contact details are on the first page of this document.

If you have any concerns about the use of your personal information, you can make a complaint to me using the contact information on the first page of this document.

You can also complain to the ICO if you are unhappy with how I have used your data.

The ICO’s address:

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk

I am required under data protection to expand on what happens to your information when using an internet service from another party such as an email provider. The services I currently use which you may use to access the counselling service are:

I use an email service provided by Proton for my counselling work. Their privacy policy is found at: https://proton.me/legal/privacy. Information specific to Proton mail is found at: https://proton.me/mail/privacy-policy.

If you use email to enquire about the counselling service but do not become a client, your personal information will not be stored, and any emails will be deleted within 30 days.

I use Zoom when conducting online counselling. Their privacy policy is found at: https://explore.zoom.us/en/privacy/. The counselling sessions are not recorded unless explicit consent from me and from you has been obtained. I will create the virtual meeting on Zoom and will email you the link the day before the counselling session is due to take place. This will also contain the unique meeting ID and password to access the virtual space. This will take you to a virtual waiting room where only you will be admitted.

I am a registered member of the British Association for Counselling and Psychotherapy) and have chosen the BACP Therapist Directory to advertise my counselling service. Their privacy notice is found at: https://www.bacp.co.uk/privacy-notice/. Point 2w provides details about the directory. If you complete the contact form within the therapist directory, I will be sent an email notification to my Protonmail account. The data will be contained within an encrypted attachment and will contain brief details from the contact form i.e. why a client is contacting me, contact details, and the preferred method of contact. If you do not become a client your personal information will not be stored, and the email and attachment will be deleted within 30 days.

Please note the BACP retains the data for up to one day to assist with any problems.

Psychology Today Directory

I advertise on the Psychology Today listing. Their privacy policy is found at: https://www.psychologytoday.com/gb/docs/privacy-policy. Points 1.ii) and 1.iii) relate to you sending an email or telephoning me from their website. They do not read nor retain the message. An email is sent to my Protonmail account advising me of the contact with your contact details. If you do not become a client your personal information will not be stored, and the email and attachment will be deleted within 30 days.

I am listed on the following website(s) with my contact details displayed for you to contact me either by email or telephone. Please find the links to the relevant privacy policies below:

MS-UK.org Counselling Directory https://msuk-1f835.kxcdn.com/wp-content/uploads/2024/03/MS-UK-privacy-policy-PDF-version-for-web.pdf

Hub of Hope https://hubofhope.co.uk/privacy-policy

Website (silverlanterncounselling.co.uk)

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