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 data protection legislation, including the General Data Protection Regulation (EU/2016/679) (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 can process your information and what purpose I am processing it for

• Whether you must 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 questions you might have about my data protection policy and you can contact me via email at breadandrosescounselling@gmail.com 

‘Data controller’ is the term used to describe the person/ organisation that collects and stores and has responsibility for people’s personal data. In this instance, the data controller is me. When I use I or me within this document, this relates to me – Victoria Mary Richardson (known as Vicky).

I am registered with the Information Commissioner’s Office ZA779720 in the name Victoria Mary Richardson.

My contact details are:

Name: Victoria Richardson trading as Bread and Roses Counselling

Address: The Loft Wellbeing Space, High St, Uppermill

E-mail:breadandrosescounselling@gmail.com

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 of 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 that it is for provision of health treatment (in this case counselling) and necessary for a contract with a health professional (in this case, a contract between me and you).

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, phone number and email, as well as any information you give me about why you are seeking counselling.

·         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.

·         If you decide not to proceed, I will ensure all your personal data is deleted within three months.    

·         If you would like me to delete this information sooner, just let me know.

While you are accessing counselling.

Rest assured that everything you discuss with me is confidential.

That confidentiality will only be broken if:

a)    I have a safeguarding concern I may need to contact your GP, another medical practitioner or emergency services. Where possible this would be discussed with you beforehand, although this may not always be possible if I believe there is an urgent risk to welfare or speaking with you may present a safeguarding risk.

b)    I have a legal obligation to disclose acts/intent of terrorism, money laundering, drug trafficking.

·         I will keep a record of your personal details to help the counselling services run smoothly.  These details are kept securely in coded paper files in a locked cabinet/password protected digital files on my home computer and are not shared with any third party.

·         I will keep written notes of each session, these are kept in a coded and password protected excel file, with a back-up copy being retained on a memory stick which is held in a locked filing cabinet.

·         For security reasons I do not retain text messages for more than three months. If there is relevant information contained in a text message, I will retain this within your coded notes to comply with the needs of my insurer.

·         Likewise, any email correspondence will be deleted after 12 months if it is not important (i.e. confirming attendance at a session).  I will retain a copy of any enquiry or correspondence thread for a minimum of seven years, to comply with the needs of my insurer.

After counselling has ended.

·         Once counselling has ended your records will be kept for seven years from the end of our contact with each other and are then securely destroyed.

·         If you want me to delete your information sooner than this, please contact me to discuss this.

Third Party Recipients of Data

I sometimes share personal data with third parties, for example, where I have contracted with a supplier to carry out specific tasks (i.e. if you are attending group therapy which is delivered with other therapists).  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 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 its, 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 to: breadandrosescounselling@gmail.com.  I will respond within a month.

·         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 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.

·         Once we have contracted to work together, I use an encrypted email service to send information about your appointments and any resources we have agreed to share, which will only be sent with your consent.

·         Paper files are minimised and coded.  They are kept in a locked filing cabinet. I use password protected digital files. I use devices that which are password protected and for my sole use.  I regularly update my anti-virus and security software.

About my website

Visitors to my website

My website is hosted by Squarespace.  When someone visits my website, I use a third-party service (Squarespace) to collect standard internet log information and details of visitor behaviour patterns.  

Squarespace collects personal data when you visit this website, including:

·         Information about your browser, network and device

·         Web pages you visited prior to coming to this website

·         Your IP address

Squarespace needs the data to run this website, and to protect and improve its platform and services. Squarespace analyses the data in a de-personalized form. The information may also include details about your use of this website, including:

·         Clicks

·         Internal links

·         Pages visited

·         Scrolling

·         Searches

·         Timestamps

The website shares this information with Squarespace, our website analytics provider, to learn about site traffic and activity.

You can read Squarespace’s privacy notice here https://www.squarespace.com/privacy

I use legitimate interests as my lawful basis for holding and using your personal information in this way when you visit my website. If you fill in a form on my website, that data will be temporarily stored on the web host before being sent to me. I use Squarespace Analytics so that I can continually improve my service to you.

Like most websites, Squarespace sites use cookies to help the site work more efficiently - find out about their use of cookies and the retention schedule (which is a minimum of 30 minutes and a maximum of two years) here: [https://support.squarespace.com/hc/en-us/articles/360001264507]. 

About my use of banking apps

I use the Tide Business Banking app.  In contracting with me, you consent to your name appearing on my business banking statements and my company name showing up on your own statements.

Information will be retained within the Tide banking App indefinitely, to support record keeping required by HMRC.  Tide does not share your bank details with me.  If you require a refund at any point, you may need to provide me with your bank details, which I will need to add into the Tide App to facilitate a refund.  At the end of working together, I will delete your bank details from the Tide App.  I use performance of contract as my lawful basis for holding and using your personal information within the banking app.

You can read Tide’s Privacy Notice here:  https://www.tide.co/privacy/

Working Online

·         There are some occasions where we may contract to meet using Zoom, which is one of the video platforms which is supported by the BACP for the delivery of remote counselling services. 

·         Prior to beginning online therapy, I will send you additional information about risk management online and the potential limitations to confidentiality in using online platforms.

Working Face to Face during the current C-19 Pandemic

·         Prior to contracting to work face to face I will send you additional information about arrangements for sharing information with NHS Track and Trace, in case you, I, or another person using The Loft becomes unwell with Covid symptoms.

·         29/07/2021 – Version 3 – supercedes and replaces version 2