I am registered with the Information Commissioner’s Office to hold records and personal data, my registration number is ZB294956. I am happy to chat through any questions you might have about my privacy notice – you can contact me via email at charlotterumpcounselling@outlook.com.
The data that I hold and why I hold it
You have a right to know what information I keep about you. I keep core data as part of my practice and process this data as necessary for the performance of our working contract. Some of the information that you may disclose to me is called ‘special category personal information’. The lawful basis for me processing any special categories of information is that it is for the provision of ‘health treatment’ – in this case, counselling.
How I use your information
Initial contact
When I am contacted about a counselling enquiry, I collect basic information from the source of the enquiry (an online directory, email etc). This will include your name and at least one contact method (e.g. email address or phone number) to be able to process your enquiry. If you decide not to proceed with an initial session, no information is stored.
While you are accessing counselling
I keep a record of your personal details to help the counselling process run smoothly. Following an initial session, and on the agreement that we intend to work together, I request further information. This includes: your date of birth, preferred pronouns, any further contact details and preferences around contact, your address and GP details, any relevant medical conditions or medication that you decide I may need to know, and an emergency contact. I keep this data in the event that I may need to contact someone on your behalf in the process of our work.
All personal data is kept securely using a cloud based service (WriteUpp). This data can only be accessed through a unique URL, and is password protected. The platform is ISO certified and GDPR compliant.
The content of our sessions will stay confidential, however, there are some limitations to confidentiality. These include:
• If I am concerned for the safety of you or someone else. In this instance, I may need to contact a third party (this may be a GP or another professional as appropriate). If this instance, I will always endeavour to speak to you first, unless any safeguarding concerns may prevent this. Any disclosure will be limited to what is strictly necessary to safeguard you or another person.
• I regularly receive clinical supervision, as required by the UKCP. This is to enhance the quality of counselling being offered and to ensure I am working ethically. During supervision sessions, all discussion is anonymised.
• There are also some legal limits to confidentiality, where in certain circumstances a counsellor may be required to disclose information to the police or courts. These include: information regarding an act of terrorism, money laundering, drug trafficking or if a child or vulnerable adult is at risk of harm or abuse.
In addition to the data I collect, I may also keep brief bullet point notes about our sessions together. These notes are not shared with anyone. Under rare circumstances, notes can be subpoenaed in a court of law. Because of this, I keep my notes to a minimum. I will keep your notes for the period to which I am obliged legally (5 years), after which they will be destroyed.
You have the right to request any information I keep about you. I would advise that we discuss your reasons for requesting them in therapy together, should you wish to request to see the information I keep. After this conversation, should you request a copy, I will type them up and you can have them within one calendar month.
Third party recipients of personal data
Emails may be vulnerable to hacking or miss-sending by human error. If you would prefer not to communicate by email, please let me know. Otherwise, it is best to use email to discuss logistics only (changing session times, etc.).
I use Quickbooks for my accounting, which means HMRC or an accountant may have access to my accounting software, in the event of a tax return query, or audit. I work with professional services who understand the nature of my role and the discretion required, however this may mean you could be identifiable as making payments into my practice. If paper records are needed in either of these processes, I will redact any identifying details before passing them on.
As part of my UKCP membership, I am required to hold a professional will. This is for use in an emergency and allows a trusted colleague to access the contact details of my current clients to contact them if I am unable to. The information would only be accessible to my colleague if a situation arises where this process is needed.
Your rights
You have the right to have the information I hold about you erased. If you would like me to delete your information, let me know. However, as above, I may need to retain your notes for a required period of time (5 years), after which they will be deleted. I will only hold the minimum of information I need about you to carry out my duties and will regularly audit and clear such data.
