PRIVACY POLICY
This privacy policy outlines your rights and my obligations to you regarding recording and storing your personal information. It details what I will do with any personal information from initial point of contact through to after counselling has ended. All personal information will be kept safe and secure and will only be used for the purpose it was shared.
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. I also adhere to the ethical guidelines regarding protecting client privacy and confidentiality set by the British Association for Counselling and Psychotherapy (BACP).
Personal information collected
I currently collect and process the following information:
· Personal identifiers; name, address, phone number, email address, date of birth
· Special category information;
o Gender, marital status, employment status and occupation
o Emergency contact details/next of kin contact details
o Medical background: past diagnoses, prescribed medication and GP contact details
o Counselling history and difficulties/challenges currently facing
o Brief session notes
All of the personal information collected is provided directly by the client verbally, via my website www.joannahillcounselling.com, email or via the New Client Information Form. I will never use the client’s personal data for any purposes other than the administration of the counselling service i.e. to arrange, cancel and rearrange appointments. Additional information provided by the client gives introductory information to their situation prior to counselling. This allows me to assess whether I can offer you counselling in the first place and then deliver effective service to you. Your personal information helps guide my assessment process and clinical decision-making during counselling.
Sharing (processing) of information
Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing this information are below. At least one of these must apply whenever personal data is processed:
(a) Consent: the client has given clear consent to process their personal data for a specific purpose. The client is able to remove their consent at any time by contacting Joanna Hill (info@joannahillconsulting.com)
(b) Contract: the processing is necessary for a contract between counsellor and client, or because the client has have asked to take specific steps before entering into a contract.
(c) Legal obligation: the processing is necessary to comply with the law (not including contractual obligations). Confidentiality will be breached in compliance with a court order, concerns over child protection and information or knowledge regarding fraud/money laundering, drug trafficking or acts of terrorism.
(d) Vital interests: the processing is necessary to protect someone’s life. For example, information may be shared with the client’s GP or other healthcare professionals if it is necessary to protect the client’s safety or health or if someone close to the client is at risk of serious harm. This would usually be in the event of an emergency only and disclosure would be in collaboration with the client where possible.
(e) Public task: the processing is necessary to perform a task in the public interest or for official functions, and the task or function has a clear basis in law.
(f) Legitimate interests: the processing is necessary for the clients legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.
Secure storage
· Electronic;
o Client’s personal information is securely and confidentially stored on devices electronically with password protection.
o Brief session notes are kept electronically for the purpose of assisting the work together. The notes help to keep track of the issues that are being worked on and are for my use only. The notes do not include any personal details that could identify the client and they are stored securely on a password secured computer that only I have access to. Counselling session notes (contain a code) are stored separately to the personal details form (personal information) so cannot be linked.
· Email/Texting;
o Email addresses will be stored in my email account and correspondence will be held by the corresponding app (password protected). Any email correspondence will be deleted within one month if it is not necessary to keep it.
· Paper records/information;
o I do not tend to work with hard copies but any paper records are stored in a locked cabinet and are securely, confidentially disposed of when not needed anymore.
Deletion of information
I will only retain personal information for as long as is necessary. This is in line with guidance from the Information Commissioner’s Office and this time frame adheres with current industry guidelines.
· Personal information (name, address, date of birth, contact details, marital status, employment status, emergency contact details/Next of kin contact details, medical background: past diagnoses, medication and GP contact details) as well as counselling session records are kept for 7 years after termination of therapy and then destroyed.
· In the case of clients under 18, records are kept for 7 years after the child turns 18.
· Personal information and counselling records will be destroyed by deleting all electronic records and destroying any hard copies (if they exist).
· I may need to store your data for longer than this, for instance, to defend myself in a claim situation or comply with my insurance terms and conditions.
Data protection rights
Under data protection law, you have rights including:
· Your right of access - You have the right to ask us for copies of your personal information.
· Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
· Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.
· Your right to restriction of processing - You have the right to ask us 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 we transfer the personal information you gave us 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, we have one month to respond to you.
Please contact Joanna Hill at info@joannahillcounselling.com or 07424 634504 if you wish to make a request.
Website
This website is hosted by Squarespace. Squarespace collects personal data when you visit this website, including:
Information about your browser, network and device
Web pages you visited prior to coming to this website
Web pages you view while on this website
Your IP address
Squarespace needs the data to run this website, and to protect and improve its platform and services. Squarespace analyzes the data in a de-personalized form.
Cookies
This website uses cookies and similar technologies, which are small files or pieces of text that download to a device when a visitor accesses a website or app. For information about viewing the cookies dropped on your device, visit The cookies Squarespace uses. These functional and required cookies are always used, which allow Squarespace, our hosting platform, to securely serve this website to you.
By accessing the website, you are consenting to the information collection and use practices described in this privacy notice. Should you choose to make contact using the contact form on the website none of the data that you supply will be stored by the website or passed to any third party data processors. The data will be collated into an email and sent to me via the Simple Mail Transfer Protocol (SMTP). SMTP servers are protected by TLS (sometimes known as SSL) meaning that the email content is encrypted before being sent across the internet. The email content is then decrypted by local computers and devices.
The website uses cookies and Google Analytics. Google Analytics is a service provided by Google that gathers anonymous data on how people are using websites and then provides visitor statistics, details of page views etc. This service is used by many website owners to help improve their websites. Some page elements may be embedded from trusted third parties in order to provide services such as Interactive Maps e.g. Google Maps. This makes the website more helpful to you as a site visitor however most of these come with their own cookies which I do not control. In many cases the cookies are used to generate identical information to Google Analytics and indeed use Google Analytics, so opting-out of Google Analytics will also opt you out of these cookies too. You can opt out of Google analytics and other Google services here – http://tools.google.com/dlpage/gaoptout and https://www.google.com/dashboard/.
Complaints
If you have any concerns about our use of your personal information, please feel free to communicate this to me at the earliest possible opportunity. I will do my best to address your concerns and take steps to resolve any issues you may raise. Should you wish to take the matter further, you can also contact the ICO.
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
Changes to privacy notice
Date of privacy policy created/updated: September 2023. This privacy notice may be updated from time to time, so please check the website occasionally for any updates.