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 policy tells you what I will do with your personal information from initial point of contact through to after your coaching, therapy or supervision has ended, including:
- Why I 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 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 mycontact formon my website or find my contact details in my email to you.
‘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.
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 coaching, therapy or supervision 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 coaching, therapy or supervision, or if you are in contact with me to consider coaching, therapy or supervision, 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 for my coaching work is that we have a contract for services (a contract between me and you, or a contract between me, you and a third party e.g. your employer) and that you have provided your consent for me to process your data for the purposes of providing coaching services. The lawful basis for me processing any special categories of personal information for my therapy work is that it is for provision of health treatment (in this case counselling or the supervision of counselling) and necessary for a contract with a health professional (in this case, a contract between me and you) and that you have provided your consent for me to do so for the purposes of providing counselling or the supervision of counselling.
How I use your information
Initial contact
When you contact me with an enquiry about my coaching, counselling or supervision services I will collect information to help me satisfy your enquiry. This will include your name, email address, and a brief reason for why you are seeking coaching, counselling or supervision. It is possible your line manager or other stakeholder at your place of employment may make a coaching referral on your behalf via my website, or your GP, another health professional or a relative or trusted individual may provide your details when making a therapy enquiry on your behalf.
If you decide not to proceed I will delete the electronic copy of your contact form within 12 months. If you would like me to remove this from my email system sooner, please let me know.
While you are accessing coaching, counselling or supervision
Everything you discuss with me in our intial/discovery call or in our coaching, counselling or supervision sessions is strictly confidential. That confidentiality will only be broken in the circumstances detailed in our Coaching Agreement,Counselling Agreement or Supervision Agreement under Confidentiality.
Before commencing sessions I will collect information including your name, the address where you are likely to access our online or telephone sessions, your emergency contact details, GP details and you may choose to provide me with information about any medication you are taking. I collect and hold this information while we are working together for use in case of emergency.
I will keep a record of your personal details to help my coaching, counselling and supervision services run smoothly. I keep brief notes of each session. These are kept electronically in a secure, password-protected system, and are not shared with any third party.
For security reasons I do not retain text messages for more than 90 days. If there is important information relevant to our coaching, counselling or supervision work contained in a text message or email I may transfer it to your secure, password protected electronic notes. If I consider it necessary I will retain email or text correspondence for up to 7 years in line with my business insurance policy details.
After coaching, counselling or supervision has ended
Once our coaching, counselling or supervision agreement has ended your records will be kept for up to 7 years from the end of our contact with each other in line with my business insurance policy and they are then deleted. If you want me to delete your information sooner than this, please tell me.
Third party recipients of personal data
I may be required to share personal data with third parties, for example, where I have contracted with a supplier to carry out specific tasks such as automated administration processes. 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 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 via the contact form on my website themenopausetherapist.com.
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 toico.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. I use encrypted devices and password-protected systems. Any hard copy paperwork that includes your data is kept in a locked filing cabinet.
Online coaching, counselling or supervision sessions are usually held on the Zoom platform, which states it is UK GDPR compliant. Whilst I make every effort to ensure the data integrity of any platform I use for online sessions, I cannot guarantee that it is 100% secure. Likewise, I cannot guarantee that telephone coaching, counselling or supervision will be 100% secure.
Additional information for website owners and employers
Visitors to 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.
If you fill in a form on my website, that data will be temporarily stored on the web host before being sent to me and treated in accordance with the above.