How I deal with your data:
1. By data I mean any written information (manuscript or digital) that I keep about you, including your personal contact details or notes made after sessions :
2. I am legally obliged:
· To collect and store the minimum amount of information about you that is necessary;
· To store it securely, so that it does not fall in to the hands of unauthorized people, and only for as long as is necessary for professional standards to be met;
· Not to share data with third parties (except under the circumstances outlined below - ‘allowing other people to see you data’);
· Not to use it for any purpose (for example, research) that has not been explicitly agreed with you;
· To gain your written and signed consent to holding any data about you;
· To inform you of your right to review and correct any data that I hold about you;
3. I only collect data from you, and record data about you, that is necessary for our work together to be effective and safe. This is;
· The information I ask for on my ‘contact details’ sheet that you fill in at the beginning of the work; if you do not understand why I need this information please ask me.
· Minimal manuscript notes of what happens in our sessions (identified by your first name only and written so as to avoid recording information that might identify you further).
· The document recording our consent for your data to be kept.
4. Storage - while we are working together;
· Your contact details sheet will be stored manually and separately from your notes.
· Your telephone number will be stored on my smart phone identified by your initial only.
· Your email address will be stored on my computer and smart phone, without your name or any other details appearing in my address book.
· Our appointments, identified only by your first name, will be entered in my manual diary.
· My professional executor (who would be responsible for dealing with clients if I were suddenly unable to work) will be provided with a file containing your first name and your telephone number. She, like me, is bound to keep this data safe under GDPR.
· The manuscript notes I make of our sessions will be kept securely at my home office.
5. Retention - after our work has ended (or I have not had contact with you for 2 months)
· As a rule, your contact details sheet will be deleted from my records, and your details removed from my smart phone (in address book and text records), my computer (in address book and email exchanges), and from the file given to my professional executor. In rare cases I may decide, however, to keep some text or email exchanges for longer in order to protect my professional integrity.
· My manuscript session notes will be kept for 5 years and will then be shredded. Any text or email exchanges that I have decided to keep will be deleted after 5 years.
· In almost all cases, after 3 years I will remove all details of our work together from my files. In rare cases I may decide to keep some records for up to 7 years to protect my professional integrity, under the same security measures.
6. You can ask to see the information and notes that I hold about you, and to correct the information, at any time. In the case of notes about our sessions, I may decide to show them to you only whilst we are together in a session.
7. Allowing other people to see data;
· If issued with a court order, I am legally obliged to hand over any notes or records I have about our work together. If possible I will contact you to alert you to this in advance.
· Otherwise information I hold can only be passed to a third party (e.g. a solicitor, or a health agency) with your explicit written consent.
8. If you believe that I have not dealt with your data in a legal and ethical way, I would like you to tell me, so that we can reach an agreement. If for some reasons this is not possible, and you wish to pursue a complaint, you can contact;
· For legal issues - the information Commissioner’s office (ico.org.uk)
· For legal and ethical issues - my professional body, the British Association for Counselling and Psychotherapy (www.bacp.co.uk)
9. I may update this policy as and when is necessary (i.e. when there is a change to the law or my professional bodies requirements).