The purpose of this notice
The processing of personal data, is governed by the General Data Protection Regulation (the GDPR). This legislation is a data privacy law, giving you rights as an individual and imposing obligations on organisations, including Extra Help Counselling & Psychotherapy, in relation holding your personal data.
One of the rights is a right to be informed, which means I have to give you information about the way in which I use, share and store your personal information.
You can read more about GDPR at the website of the Information Commissioner: ico.org.uk.
Extra Help Counselling & Psychotherapy is a counselling and therapy service provided by Matthew Elton. Extra Help also offers writing coach and some consultancy services.
In the terms set out in the legislation, Matthew Elton is the data controller. The data controller is the person who decides how your personal data is processed and for what purposes. I only process data so that I can provide clients with counselling, psychotherapy and other services. To do this effectively I need contact details, record of sessions, and client notes. The lawful basis, under GDPR, under which I hold process personal data is “legitimate interest”.
Whose information does this privacy notice apply to?
This privacy notice applies to information I collect from:
- prospective clients
- former clients
- visitors to the www.extra-help.org.ukwebsite.
What is personal data?
Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. Examples of personal data I may hold about you include your contact and appointment details.
Special category data is a sub-category of personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. Your client notes may include some special category data.
How do I process your personal data?
I use your contact details to arrange and re-arrange appointments and to get in touch with you if you miss an appointment. I use your client notes as reminder of what we have talked about in previous sessions and to help me think and, sometimes, plan, what might be helpful in future sessions. I use record of sessions (dates of sessions, record of non-attendance, etc.) for accounting purposes, to log the number of hours I have worked, and to inform my understanding of my work with you.
I comply with my obligations under the GDPR by keeping personal data up to date, by storing and destroying it securely, by not collecting or retaining excessive amounts of data, by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data. I use your personal data for the purposes set out below.
Clients, prospective clients, and former clients
Contact information I use your name, address, telephone / mobile number and email address to make and rearrange appointments. If you become a counselling / psychotherapy client you will also be asked for contact details for a GP / GP Practice and also for an emergency contact. These are for use only in emergencies, such as a strong and urgent concern about your safety.
Client notes Client notes comprise handwritten notes, typed notes (stored on computer and/or printed out), and, on occasion, emails or letters exchanged between you and me. In such notes I refer to you only through your first name or through initials. Paper notes are normally kept in a locked filing cabinet in my office or stored at my home. Electronic notes are only stored on a computer that uses password protection. Your client notes may include emails sent by me or sent by you. The aim of keeping client notes is to help make counselling and psychotherapy more effective by allowing me to refer back to the content of previous sessions.
Records of sessions I keep a record of sessions attended and missed. I also keep a record of session payments. I don’t share records of sessions with anyone.
Contact details for current clients are stored in an electronic file that can be accessed by a colleague who also works as a counsellor and psychotherapist. In the event of my sudden death or incapacitation this would allow for current clients to be contacted and, if appropriate, referred to another counsellor / psychotherapist. The executor of my clinical will would also ensure that client notes were destroyed.
When someone visits the website www.extra-help.org.uk third party services collect standard internet log information and details of visitor behaviour patterns. I do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way, which does not identify anyone. Website cookies are used only for the purposes of helping gather these statistics enabling the website to ‘remember’ users, either for the duration of their visit – using a ‘session cookie’ – or for repeat visits – using a ‘persistent cookie’.
Note on emails
I do not work with encrypted emails so you should be aware that any emails I send or receive may not be protected in transit. Please be aware that you have a responsibility to ensure that any email you send me is within the bounds of the law.
Sharing your personal data
The data I hold on your – contact details, client notes, record of sessions – is solely. I do not share it with other people and I do not use it for any marketing purposes. Limited circumstances in which information might be shared include:
- if you explicitly ask me to share information, e.g. to write a letter for you relating to attendance and/work we have done;
- with the executor of my clinical will in the case of mysudden death or incapacitation, contact details – but not client notes – would be used to inform / advise current clients.
- with the relevant authority such as the police or a court, if necessary for compliance with a legal obligation to which I are subject e.g. a court order;
- with your doctor or the police if I judge there is a risk of harm to yourself or others;
- with the police or a local authority for the purpose of safeguarding a children or vulnerable adults; or
- with my regulatory body, the British Association of Counselling & Psychotherapy and/or with PPS (Psychologists Protection Society) in the event of a complaint or a claim being brought against me; or
- my solicitor in the event of any investigation or legal proceedings being brought against me.
For further details about the situations when information about you might be shared please see the Information Commissioner’s website at ico.org.uk
How long do I keep your personal data?
I keep client notes and contact details for around three years after the end of the last session after which time the information is erased or destroyed.
In the case of mysudden death or permanent incapacitation, the executor or my “clinical will” will take steps to ensure the destruction of client notes.
Your rights and your personal data
Unless subject to an exemption under the GDPR, you have certain rights with respect to your personal data as set out below.
- the right to access your personal information
- the right to require me to change any factual mistakes in the information I hold.
- the right to request the deletion/destruction of your personal information
- the right to lodge a complaint with the Information Commissioner’s Office.
For further details about these rights please see the Information Commissioner’s website at ico.org.uk
To exercise all relevant rights, queries of complaints please in the first instance contact me at Extra Help Counselling & Psychotherapy, 26 Forth Street, Edinburgh, EH1 3LH.
You can contact the Information Commissioners Office on 0303 123 1113 or via the website (ico.org.uk) or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.
END OF PRIVACY NOTICE – last updated May 24thMay 2018