Privacy Notice

Introduction

Your privacy is very important to me and you can be confident that your personal information will be kept safe and secure and will only be used for the purpose it was given to me. I adhere to current date protection legislation, including the General Data Protection Regulation (EU/2016/670) (the GDPR), the Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2003.

This privacy 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
   

I am happy to chat through any question you might have about my data protection policy and you can contact me via email if you have any questions.
 

‘Data controller’ is the term used to describe the person/organization that collects and stores and has responsibility for people’s personal data. In this instance, the data controller is me.
 

I am registered with the Information Commissioner's Office (Registration number: ZB538605).
 

My postal address is: The Crescent, Shrewsbury, SY4 1DE.
My phone number is 07462 580539.
My email address is: nancy.cerritelli@proton.me.
 

My lawful basis for holding and using your personal information

The 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 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.
 

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 our contract.
 

The 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 consent initially. I will then retain any counselling records in case of the need to reference in the future (the official legal basis is to defend against potential legal claims).
 

How I use your information

Initial Contact

When you contact me with an enquiry about my counselling services I will collect information to help me satisfy your enquiry. This will include your name, contact details and brief notes about your reasons for seeking therapy. 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.

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

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While you are accessing counselling

Rest assured that everything you discuss with me is confidential. That confidentiality will only be broken if:

 

• I believe that you or someone else might be at risk of harm

• you disclose that a crime has been or is going to be committed under certain legislation (see client agreement)

• I believe that a child or vulnerable adult is at risk of harm

• I am required by a court to disclose information about you

• you ask for confidence to be broken under the General Data Protection Regulations (GDPR) and Data Protection Act 2018

 

I will always try to speak to you about this first, unless there are safeguarding issues that prevent this.

 

I will keep a record of your personal details to help the counselling services run smoothly. These details are kept securely in a locked box and/or on an encrypted and password protected computer and are not shared with any third party.

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I will keep written notes of each session, these are kept separately to your personal details on an encrypted and password protected computer and are anonymised using a client code in place of a name.

 

For security reasons I do not retain text messages for more than a month. If there is relevant information contained in a text message I will transfer it to your personal details or session notes as appropriate. Likewise, any email correspondence will be deleted after a month if it is not important. If necessary I will save emails on an encrypted, password protected computer along with your personal details.

 

After counselling has ended

Once counselling has ended your records will be kept for 7 years from the date of your last therapy session if you are over 18 and are then securely destroyed. If you are under 18, I will keep your records for 7 years from your 18th birthday. This is in line with the requirements of my insurer. If you want me to delete your information sooner than this, please tell me.

 

Third party recipients of personal data

I sometimes share personal data with third parties, for example, where I have contracted with a supplier to carry out specific tasks such as an encrypted email service (proton.me) and practice management software (wearekiku). 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.

 

Your rights

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 www.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 it, 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 nancy.cerritelli@pm.me.

 

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 www.ico.org.uk/make-a-complaint.

 

Data security

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. I use encrypted, password or biometrics protected devices and a locked filing cabinet. Should I need to take paper copies of your data out of the office, I transport it in the boot of my car or in a bag that stays with me.