The purpose of this notice is to provide you with a clear and concise summary of how your personal data will be collected, processed and held by me (Jim Collier) and your rights to access and correct that data. I take your privacy seriously and encourage you to read this document carefully. The legal basis for processing your personal data is ‘contract’.
What data do you collect?
I hold your name, phone number, address and email address as well as your date of birth. For safety purposes, I hold details about the GP practice where you are registered. I also record brief notes from sessions.
How do you use my personal data?
I use information held about you in the following ways: To respond to queries for information or services; to administer my counselling service, including the arrangement of appointments and the handling of payments; to fulfil my administrative, legal and contractual obligations in line with my professional body, the BACP.
When do you share my personal data?
As a requirement of professional practice, I undertake regular supervision where issues from our sessions may be discussed, always under a strict confidential and professional framework. No personal information will be shared with my supervisor other than your first name. I would consider widening confidentiality if I consider you or others to be at risk of serious harm or when compliance with the law requires it. In the event of my unexpected death, your contact details will be made available to a trusted colleague who will contact you to discuss what course of action you may want to take.
Where do you store and process my personal data?
How do you secure my personal data?
Your personal data held on Cliniko is secured by a double-authentication procedure requiring both a password and a separate six-digit code provided by Google Authenticator. Your personal data held on my smartphone is protected by PIN and fingerprint scanner. My email system is password protected, and I have sole access to that system.
How long do you keep my personal data for?
Our signed counselling agreement and my session notes will be held for a period of five years following the end of our work together to comply with insurance requirements. When our work together has ended, any email correspondence and text messages between us will be deleted, and your name and phone number will be removed from my smart phone.
What are my rights in relation to personal data?
Under the General Data Protection Regulation 2018, you have the right to object to my use of your personal data, or ask me to delete, remove or stop using it if there is no need for me to keep it. This is known as your right to be forgotten. There may be legal and accountancy reasons why I will need to keep your data, but please do inform me if you think I am retaining or using your personal data incorrectly. You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO).
If you have any queries or complaints, or to exercise your rights as listed above, please contact me on 07557 871103 or email me at firstname.lastname@example.org. If you are not satisfied with my response, you may contact the ICO. You can find their contact details at www.ico.org.uk.