Protecting Your Confidential Data

1. Scope

The General Data Protection Regulation is implemented in the UK by the Data Protection Act 2018. I take data protection seriously and I am committed to protecting your personal data. This Privacy Notice therefore explains how I collect, retain and process your personal data and the rights you have in relation to that data.

2. Information about me

I provide relationship and psychosexual therapy services. I am a registered member of the College of Sexual and Relationship Therapists (COSRT), and a registered member of the British Association for Counselling and Psychotherapy (BACP) and as such I am bound by their Codes of Ethics. You can find these Codes on the relevant websites, respectively: www.cosrt.org.uk and www.bacp.co.uk

I am registered with the ICO (Information Commissioners Office) and my reference is C1071793.

3. Your Personal Data

For the purposes of providing relationship therapy and/or psychosexual therapy services, I will ask you to provide me with personal information such as your name, address, date of birth, occupation and contact details.

During or after our sessions I may make notes which may include what is defined as sensitive personal data. This may include information about your gender, ethnicity and marital status; your religious or other cultural beliefs; your physical and mental health and condition and your sexuality.

This data is always held securely and is not shared with anyone else, except for the purposes of supervision, which is a practice requirement for all counsellors and psychotherapists, and other than as set out in paragraph 6 below.

4. Legal bases for processing any personal data

In terms of the legal bases I rely on to process your information, these are where the processing is necessary, or you have consented to such use:

for the purposes of delivering relationship therapy and/or psychosexual therapy services;
for my legitimate interest in managing, quality assuring and supervising these services; and
to comply with my legal obligations and the Codes of Ethics of COSRT and BACP.

5. Consent

By agreeing to this Privacy Notice you are consenting to my processing your personal data for the purposes outlined. You can withdraw your consent at any time by giving me notice using either the email address included in this Privacy Notice.

6. Disclosure

I will keep your personal information safe and secure. I will not disclose your Personal Information, except for the purpose of supervision as referred to above or unless I am compelled to do so in order to meet my legal or regulatory obligations. For example, I have a legal duty to disclose information under the Children Act 1998, The Children (Scotland) Act 1995, the Terrorism Act 2000 and the Drug Trafficking Act 1994 (or other such legislation which may from time to time come into force).

I may also disclose confidential information if I have reason to believe that you are at risk of causing serious harm to yourself or others; or where such disclosure is permitted by law and is required to protect my interest; or where disclosure is made at your request or with your consent.

7. Retention Policy

I will process personal data for the duration of any relationship therapy and/or psychosexual therapy. After the therapy ends, I will continue to store for seven years only the personal data needed to meet any legal or regulatory obligations.

After this period, all personal data will be deleted or destroyed, unless basic information needs to be retained by me to meet my future obligations to you, such as erasure details.

8. Data storage

All data is held securely in the United Kingdom. Data is encrypted and password/ID protected. Any physical notes are held and stored securely.

9. Your rights as a data subject

At any point whilst I am in possession of, or processing your personal data, you have the following rights:

Right of access – you have the right to request a copy of the information that I hold about you.
Right of rectification – you have a right to correct data that I hold about you that is inaccurate or incomplete.
Right to be forgotten – in certain circumstances you can ask for the data I hold about you to be erased from my records.
Right to restriction of processing – where certain conditions apply you have a right to restrict the processing of data.
Right of portability – you have the right to have the data I hold about you transferred to another individual or organisation.

Where the client is a couple, then any data remains the confidential material of the couple relationship and as such no one person may request access to personal data for disclosure to a third party.

If I refuse your request under rights of access, I will provide you with a reason as to why, which you have the right to legally challenge. At your request, I can confirm what information I hold about you and how it is processed.

10. Identification required to access personal data

I will accept the following forms of identification (ID) when information on your personal data is requested: a copy of your driving licence, passport or birth certificate, together with a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required.

All requests should be made to me at: [email protected]

11. Data Breaches

In the unlikely event of a data breach and if the breach is likely to result in a high risk of adversely affecting your rights and freedoms, then I will notify the ICO within 72 hours and inform you without undue delay.

12. Complaints

If you wish to make a complaint about how I am processing your personal data, you can contact the ICO at Wycliffe House, Water Lane, Wilmslow, SK9 5AF Telephone +44 (0) 303 123 1113 https://ico.org.uk

13. Consent

It is a requirement that you give your explicit consent to allow me to document and process your personal data. My signed contract represents your consent. Please note that you can withdraw your consent at any time.