Privacy Statement
This privacy statement outlines our obligations as your Counsellor and outlines your rights as a client.
Please take your time to read through the whole document and signing your consent at the end of the document.
The agreement includes our new data responsibilities under the General Data Protection Regulations which came into effect on 25th May 2018.
Psychotherapist Responsibilities
To comply with the new regulations regarding contact and consent, we need to make you (client)aware of your rights and confirm that you give consent for Clarity Thinking, and any relevant parties mentioned to collect and store your data in the way described below.
What is collected and why
Clarity Thinking will collect and store your name, date of birth and age. This is basic information that is stored for lawful and safeguarding purposes. (See confidentiality/sharing of information statement.) Your address, email address and phone numbers are recorded and stored as a means of contacting you regarding your sessions. A method of communication will be collaboratively agreed upon. These details may also be used for emergency purposed where there is an evident risk of harm to yourself (see confidentiality statement).
GP details are recorded for safeguarding purposes whereby if we have cause for concern for your wellbeing and safety, we may have to contact your GP. Where possible we will seek to obtain your consent and inform you before doing so.
Session notes,
We keep very brief anonymous notes of key themes discussed in our sessions. The purpose of doing this is for our own recollection and to monitor the work we are doing and need to be retained for lawful purposes.
Data Storage and disposal
All data that Clarity Thinking collects is recorded on paper format and will be stored in a locked filing cabinet. We keep your name and code on a password protected laptop and your contact number is stored on my phone using your initials.
The length of time we store data varies dependant on the duration of therapy. Once Therapy has terminated, we will keep your address and contact details for a maximum of 30 days after which point, they will be disposed of and / or deleted. Your session notes and client code will be kept for a further 5 years in line with our insurance policy and legal obligations.
Confidentially/sharing of information.
All information collected will not be shared with anyone else. Clarity Thinking will not sell your information and not use it for any purposes other than those related to Clinical Supervision.
There are however exceptions that may require me to share your information with a third party, details of which are outlined below. Please note that a decision to breach confidentially is not taken lightly and all due consideration to your privacy is considered.
Confidentiality may need to be breeched in the following circumstances:
- There is significant risk of harm to yourself, in this instance information may need to be shared with your GP or other professional(s).
- There is information shared that suggests a child/vulnerable adult is being harmed or is at risk of harm. In this instance information may need to be shared with relevant services.
- If there is a disclosure of terrorism, money laundering, drug dealing and human trafficking, this list is not exhaustive and is inclusive of disclosures relating to serious illegal activities. we are legally obliged to disclose any relevant information to the police.
- If we are subpoenaed by court to share any information, then we must do so upon request.
- Confidentiality will be breached as defined by the client’s Agency Policy and Ethical principles (i.e., risk of life or safety, requirements of legal process etc.)
- As a professional requirement I attend regular clinical supervision where I explore my caseload to ensure that I am working to the beneficence of my client. All information shared is anonymous to avoid any possibility of identification.
- In the event of my death or terminal injury resulting in me being unable to carry out my work my colleague, Ms. Kate Dorward who is a qualified counsellor and clinical supervisor, will have access to all my clinical records in order to inform clients in therapy, to end therapy and destroy data as required.
Your rights as a client
Under the General Data Protection Regulations, you have the following rights:
- The right to be informed about the collection and use of your personal information as described herein.
- The right to access copies of any information held about you, this can be accessed through a data subject access request and the right to receive a response to this request within a period of no more than one month.
- The right to rectification; to have inaccurate personal data rectified or completed if incomplete.
- The right to erasure; you have the right to opt out of data collection. If you wish to do so, please make this request in writing, however some data cannot be erased and will need to be retained for lawful purposes and in line with my insurance policy.
- The right to data portability. You have the right to obtain and reuse your personal data for your own purposes across different services.
- You have the right to object to any personal data being collected, this will need to be made known in advance or at the commencement of any therapy. Please note if this is the case all therapeutic work will need to be terminated as I am required to keep appropriate records in line with my insurance policy, my ethical obligation to membership bodies and above all for legal and safeguarding matters.
Accessing your data
If you wish to make a request for your data under a data subject access request, please do so in writing. I will then request you to sign a disclosure consent form. You will then expect to receive the information within 30 days of receipt of the request.
By signing this document, you certify that you have read this agreement, that you know and understand the meaning, intent, and content of this agreement and that you are entering into this agreement knowingly and voluntarily.
I have read and understood the context of this privacy statement.