What is personal information?
The Data Protection Act 1998 (DPA) defines personal information as any information used to identify a living individual, including their name, address, telephone number or email address.
How will you collect your personal information?
I will collect your personal information through my website: www.wellbeingwholenesscounselling.co.uk, over the telephone, in writing, through email and in-person during our meetings
Why do I process your personal information?
I process your personal information to fulfil my contractual requirements to you as a psychotherapist, such as assessing whether I can offer you counselling and then deliver effective counselling to you if therapy begins. Your personal information helps guide both my assessment process and my clinical decision-making. My contractual obligations to you as a psychotherapist are the lawful basis for my processing of your personal information.
What are the laws that protect your personal information?
The DPA and the General Data Protection Regulation (GDPR) require that all organisations that store personal information about people may only do so provided that the information is: processed lawfully, fairly and transparently; collected for specified, explicit and legitimate purposes; adequate, relevant and limited to what is necessary; accurate and, where necessary, kept up to date; kept in a form that permits identification of information subjects for no longer than is required for the purposes for which the personal information are processed, and processed in a manner that ensures appropriate security of the personal data.
How I treat your personal information?
I will treat your personal information in a way that complies with the DPA and the GDPR.
How will I store your personal information?
I will store your personal information both electronically and physically. Personal information is stored electronically on a password, or a pin or a fingerprint protected device. Furthermore, I save it in files that are also password protected and only accessible by me. Names and contact details are stored separately from other personal information. I keep very little information on paper, and all information is stored using paper records held securely in locked cabinet or room in an anonymised format. These records are also only accessible by me.
How will I store your personal information?
Following the GDPR policy, I will not store your personal information for longer than is necessary. In practical terms, I will usually hold your information for a maximum of 7 years following the termination of your treatment. However, I may need to store your data for longer than this, for instance, to comply with my insurance terms and conditions.
What types of information will I gather about you?
I will collect several types of information about you and in several different ways:
a. If you request a call-back via the web form on www.wellbeingwholnesscounselling.co.uk, I will collect the following information: name, telephone number, date, and time.
b. Before committing to provide you with counselling services, I will send you a form to provide me with the following information: name, telephone number, address, DOB, age, email address, occupation, name & address of GP, prescribed medication and ethnic origin.
c. Once we have agreed that counselling with me is suitable for you and your therapy commences, I will collect further information from you that may include: goals for counselling, previous mental health interventions, previous criminal convictions, network of support, financial and employment circumstances, health and physical issues, alcohol and drug use, appetite and sleep, family structure, relationships, an overview of your family situation, and early memories of caregivers.
‘Special category’ information.
GDPR defines ‘Special category’ information as being more sensitive than other personal information, therefore requiring higher levels of protection. Examples of this type of information could include information about your health, race, sexuality, sex life, or religion. To lawfully process special category information, I am obliged to identify a specific condition for processing it under Article 9 of the GDPR and communicate this to you. With this in mind, the requirement of the GDPR that I apply to the processing of your special category information is that it is ‘pursuant to contract with a health professional’. This means that if you begin counselling with me, or ask me to assess whether or not you are eligible for me to offer counselling to you, then I will likely need to process some special category information about you. Usually, this is information about your mental health, and I need to process it to fulfil my contractual obligations to you in delivering safe, effective counselling.
The GDPR defines a ‘data controller’ as the person in an organisation who: ‘determines the purposes and means of personal processing data.
Who is the ‘data controller’ for wellbeingwholenesscounselling?
For the purposes of GDPR, the ‘data controller’ in wellbeingwholenesscounselling is Tony Oleh of 1 Wyndham Road, Kingston upon Thames, KT2 5JR. (ICO registration A8744864).
With whom will I share your personal information?
I may share your personal information with your GP, or other healthcare professionals, under certain exceptional circumstances. These include the requirements of a court of law, the threat of severe physical harm to you or others, or during regular consultations with my professional supervisor. Some of your personal information, such as website visits, telephone call data, or payment information, is shared with the website provider, mobile phone operator, or card payment provider, respectively. These providers operate under their privacy policies, and these can be provided upon request.
Can you ask for a copy of the personal information that I store about you?
Yes. The DPA gives you the right to find out what information I store about you by requesting a copy. Any request you make to obtain a copy of the personal data I hold about you is called a ‘Subject Access Request’. You can write to me and ask for a copy of the information that I hold about you. Address your letter to: Tony Oleh, WellbeingWholenessCounselling, 1 Wyndham Road, Kingston upon Thames, KT2 5JR. I must respond to your request without delay, and usually within one month at the latest. I may charge a fee for providing this information based on the administrative costs involved.
Can you request that I delete your personal information?
Yes. This is known in the new legislation as the Right to Erasure. You can request for your personal information to be deleted either verbally or in writing. You can address this request to: Tony Oleh, WellbeingWholenessCounselling, 1 Wyndham Road, Kingston upon Thames, KT2 5JR. There may be an administrative charge for this. I may also have the right to refuse to comply with your request, for example, to fulfil my insurance terms and conditions, and I will let you know my response to your request within one month of receiving it.
Whilst I hope that the policy outlined above will be sufficient to reassure you of the security of your personal information, if you have any complaint about the way that I am handling your personal data , then do please feel free to communicate this to me at the earliest possible opportunity. I will do my best to address your concerns and take steps to try and resolve whatever issues you may raise. You can write to me at Tony Oleh, WellbeingWholenessCounselling, 1 Wyndham Road, Kingston upon Thames, KT2 5JR. Should you wish to take the matter further, please contact the Information Commissioner’s Office on 0303 123 1123, or visit https://ico.org.uk/concerns/ for more information.
© All rights reserved