‍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, supervision, and/or consultation 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 discuss any questions you might have about my data protection policy and you can contact me via hello@gracehawkinscounselling.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.

‍I am registered with the Information Commissioner’s Office Registration Reference Number ZC006166.

‍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.

‍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 with me or if you are in contact with me to consider these services, 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 consent initially. I will then retain any counselling records in case of the need to reference them in the future (the official legal basis is to defend against any potential legal claims).

‍How I use your information

Initial contact

When you contact me with an enquiry about my services, I will collect information to help me respond to your enquiry. This will include your name, email address, and phone number (optional).

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

‍While you are accessing therapy

‍Rest assured that everything you discuss with me is confidential. That confidentiality will only be broken in the following instances:  

• Where you give consent for the confidence to be broken.

• Where I am compelled by a court of law.

• Where the information is of such gravity that confidentiality cannot be maintained e.g., where there is risk of serious harm to self or others, or in cases of fraud and crime.

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

‍If we proceed with therapy, I will keep a record of your personal details. This includes your name, date of birth, email address, phone number, home address, emergency contact and GP practice and address. This is to help services run smoothly, and in cases where there is a risk of serious harm. These details are kept securely in a locked cabinet and are not shared with any third party (excepting the conditions above).

‍I will keep brief notes of each session. These are stored digitally on a password-protected laptop and a password-protected backup hard drive. These notes are stored separately from your personal details and will not have any identifying details; however, they will be linked to your personal information by a client code (e.g., ‘P023’). In this way, the data will be ‘pseudonymised’.

‍I am in regular supervision and will discuss issues from my counselling and psychotherapy work with my supervisor. At such times, I will take all possible measures to preserve your anonymity.

‍After services have ended

‍Once the therapy has ended, your records will be kept for seven years from the end of our contact with each other and will then be securely destroyed. This is in line with current law and my insurance company's requirements.

‍For security reasons, I do not retain text or WhatsApp messages for more than one month after our contact has ended. If there is relevant information contained in a message, I will insert it into my notes. Likewise, any email correspondence will be deleted after one month if it is not important. If necessary, I will insert it into my notes. After one month, your telephone number will be deleted from my mobile.

‍Your rights

‍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 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 hello@gracehawkinscounselling.com.

‍If you have any complaint about how I handle your personal data, please do not hesitate to get in touch with me by emailing me at 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. Hard copy data (personal information) will be stored in a locked filing cabinet. Digital data will be kept separately on a password-protected device.

‍Visitors to my website

‍When someone visits my website, I use a third party service, Squarespace, to 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 that does not identify anyone. I do not make, and do not allow Squarespace to make any attempt to find out the identities of those visiting my website.

‍I use legitimate interests as my lawful basis for holding and using your personal information in this way when you visit my website.

‍I use Squarespace Analytics so that I can continually improve my service to you. You can read Squarespace’s privacy notice here.

‍Like most websites we use cookies to help the site work more efficiently—find out about our use of cookies here.

‍No user-specific data is collected by me or any third party. If you fill in a form on my website, that data will be temporarily stored on the web host before being sent to me.

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