General Data Protection Regulation (GDPR) and Information about you.
In order for me to be able to fulfil my responsibilities as a counsellor I will need to record relevant personal information about you. This information includes your name, address and contact details, including phone number and/or email address and your GP practice and any medication currently being taken.
Using an identifying code I will also takes notes of “assessment information” and main issues raised in each counselling session should we agree to work together. The assessment information will include relevant medical information (GP Practice & current medication being taken) and aspects of your personal, social and family history that you choose to share with me which is kept as a paper copy in a locked filing cabinet.
Personal information and client notes will be retained in separate locations (keeping your name and contact details separate from the session notes) in password protected files, on a password protected PC which is only used by me, has a security code to access it and has virus protection software installed.
Your full contact details will be kept by me on paper (stored in a lockable filing cabinet) and your phone number on my Smart Phone using digital fingerprinting to access it, your name will not be displayed, only your client code .
Agreement on how you wish to be contacted (phone/text/email/letter) will be agreed at the assessment session.
Other personal data such as your full name, address and current age will be used to verify your identify if there is a need to contact your GP, the emergency services should the very rare occasion happen where a client collapses during a session, if you as a client are at serious risk of harm to self or someone else, or a request for access to personal data from yourself or your representative or legitimate legal instrument such as a court order which can only be actioned by a Judge under a subpoena.
This personal information will be held for a period of three years after the cessation of our counselling relationship, except where there is a mutually agreed decision to retain it for longer or where I believe that it is in my best professional interests to do so.
Your contact details will only be shared in exceptional circumstances with my supervisor or other named agent in the event that I am incapacitated so that they can contact you to explain the situation. The details of this arrangement are set out in my professional will.
Information about counselling sessions and our work together:
I will record brief notes of each therapy session under an identifying client code. These notes will be handwritten and a brief factual record of the session. This set of notes will include any agreements made with regard to, for example, cancelled sessions or changes to the way the therapy is conducted. I then copy these notes and hold them in a password-protected file in my password-protected laptop within an encrypted iCloud account and I use “two-factor authentication” to access this information so it can only be accessed and displayed on my own trusted devices.
These notes may be shared under the identifying code with my supervisor, counselling professional body or similar for purposes of maintaining professional standards and aiding my professional development during supervision which is a requirement for me to work safely and Ethically with my clients.
The handwritten and computerised notes will be held for a period of three years after the cessation of counselling except where I agree with you to retain them for longer or where I believe that it is in my best professional interests to do so.
I may make information from these notes available to legitimate third parties under the following conditions:
Who do I share your data with?
Receipt of a request from you or your representative, and where the release of the notes is not judged by me as likely to cause you significant harm or harm to another person.
I understand that on the very rare occasion where there is a specific legal requirement to do so i.e. subpoena by a Judge.
Where there is an ethical duty for me to do, for example to avoid serious harm to yourself or another person, including the safeguarding of children or vulnerable adults and/or contact your GP or local CRISIS Team. This is a rare occurrence and collaboration with the client will be sought where at all possible. GP details will be asked for at the assessment session so please let me know if there are any changes with your GP Practice or medication.
In the unlikely event of a client losing consciousness or becoming seriously ill during a counselling session, or on the premises, as your counsellor I reserve the right to pass your name and address and any medication information to the relevant emergency services.
Records of contact between us:
Using a unique client code I will hold your telephone number on my mobile phone for emergency purposes until our counselling relationship ends and then I will delete it from my contact list. However, the phone will retain summary records of calls made to or from your number (date and duration) for a period of time.
If we agree to communicate by text or by email, these records may be kept for the same duration as your counselling notes. My mobile phone is a smart phone and could therefore also have your texts, and email and email address available on it. The phone is password protected and details are stored in ‘the cloud’ so they can be restored if my phone is lost or stolen (I am able to completely wipe the contents of my iPhone/laptop/iPad should either be lost or stolen).
You have the right to ask to see any information held by me about you. To do this please either ask me or submit a request by writing. You also have the right to ask for information that you believe to be incorrect to be rectified. I will endeavour to provide you with the information requested within four weeks.
If I become aware of a situation where your personal information may have accidentally or maliciously been obtained by a third party, I will notify you within three days.
If you are concerned about the way that your information is being held please discuss this with me. If you are still unhappy you have the right to complain to the Information Commissioners Office.
- Due to the new GDPR without your agreement to my holding your personal information, it will not be possible to proceed with counselling.