Dorothy Davis  MSc, MBACP (Accred) - Counselling  07941 630349

PRIVACY NOTICE
 

CONTACT DETAILS

Dorothy Davis
Queens Garden Business Centre 
31 Ironmarket 
Newcastle-under-Lyme 
Staffordshire
ST5 1RP

therapy@dorothyd.co.uk 
07941 630349

Nature of Business:  Counsellor, Therapist, Supervisor
(The term ‘therapeutic services’ will be used to include counselling, therapy and supervision.)


INTRODUCTION

Privacy Notice (March 2019)
Your privacy is important to me.  This privacy notice explains how I use your information under the General Data Protection Regulation (EU/2016/679) (the GDPR) and The Data Protection Act 2018.  

Data Controller is the term used to describe the person or organisation that collects and stores and has responsibility for people’s personal data.  The Data Controller for my business is Dorothy Davis.  

I am registered with the Information Commissioner’s Office (ZA 193725).

HOW INFORMATION IS PROVIDED TO ME

For those who enquire about therapy:  
The initial data I process is information given to me directly when a person makes an enquiry by telephone, e-mail, text, or through an online directory for therapeutic services. 
(I use the British Association for Counselling and Psychotherapy (BACP) Therapist Directory; The Counselling Directory; The Hypnotherapy Directory)

For those who attend at least one session:
  
The information I process is information given to me by the client. 

I may also receive data indirectly from a 3 party:  
For example, when information is provided to me - by a GP or other health professional when making a referral; through an Employee Assistance Programme (EAP); from an insurance company; or when a parent or trusted individual gives me details when making an enquiry on behalf of someone else.
 
WHAT TYPE OF INFORMATION DO I PROCESS?

Personal data: 
o    Contact details & basic information:  This may include your name, address, telephone / mobile number, e-mail address and date-of-birth.  You may choose to give me your emergency contact details. 
Information will be recorded in the Contract and Contact Details.

For Information processed at payment:
o    If an invoice is required, your name & address will appear on a copy invoice & retained for accounting purposes.

o    Your name, bank account details will be on any cheque payment you make; a copy is retained for my accounts.

Special category data:
Some of the information you give me may be sensitive personal information (termed ‘special category’ data under the GDPR).  It is information which relates to any of the following:  health; sex life or sexual orientation; racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetics or biometrics.

o    for example, you may give me details of your health or medical issues; your GP details.  
Information may be recorded in the Contract, Client History Form, Health Questionnaires, my notes / records.

WHAT DO I USE THE INFORMATION FOR? 

The information will be processed in order to enter into a contract with you, provide therapeutic services to you, and administer my business.  For example, to:  contact you; respond to your enquiries; make appointments; inform therapeutic decision making; maintain my notes and records; meet legal and professional obligations; safeguard.

WHEN MAY I SHARE INFORMATION?

I recognise that the information you give to me is personal and may be sensitive.  I will not share your information with any third parties unless it is for one of the following:
 
o    you have consented to this
(for example: by providing information to me after I’ve told you that I will supply the information to a third party; you have been referred to me by your GP, through an Employee Assistance Programme (EAP), your workplace, an insurer, or other organisation and you have consented that I share information, reports or attendance data; or you agree to a referral to another professional; it is a term / condition of our Contract)

o    I am required to do so by any court or law

o    it is for the prevention and detection of a serious crime

o    it is in order to protect a child, a vulnerable adult, yourself or the public

o    I consider that you are in imminent risk of causing serious harm to yourself or others

o    It is in supervision.  As a requirement of my professional organisation and in order to enhance the quality of therapy being offered, I may discuss my work with you with my therapeutic supervisor or with my peer support group / colleagues. 

o    it is for a legitimate business purpose, including:
·         for the assessment of any tax or duty
·         required by any relevant regulatory body
·         to protect the rights, property or safety of Dorothy Davis or any third parties
·         If I am unable to provide a therapeutic service, for whatever reason, my executor may access your notes and records.

WITH WHOM MAY THE INFORMATION BE SHARED? 

The people I may need to share information with, changes depending on circumstances.  If I share information it will be with relevant people, services, organisations or authorities. You may have already given your consent for me to share.  In other instances, I will always try to speak to you about this first, unless circumstances, the law or safeguarding issues prevent this.

I will not share your information with any third party for the purpose of direct marketing.
As a general rule I do not transfer your personal information outside the European Economic Area (EEA).  If I do so, I will ensure that suitable safeguards are in place. 

INFORMATION SECURITY
 
o    Client records, handwritten notes and correspondence will be kept in locked cabinets / cupboards. 

o    Any texts messages sent between us are held on my password-protected smart-phone as may be any voicemail messages you leave. 

o    E-mails are accessed on a password protected lap-top & smart-phone. 
 
Other considerations:
 
I am not in control of data (including e-mails, texts and messages which you send to me).  Please be aware that these may not be secure.  It is preferable, therefore, to limit their use to the arrangement of appointments.

The visitor book in the reception area is not part of my business.  If you decide to write in the visitor book you may want to give only first name or initials. 

HOW LONG IS INFORMATION KEPT FOR?

Information will be kept for as long as necessary in line with legal, regulatory, insurance or ethical requirements / guidance.  

For initial enquiries only:  E-mails / texts / messages may be kept for up to 3 months. 

For those who attend at least one session: 
o    E-mails / text / messages may be kept for as long as the therapeutic relationship is active, and deleted from the laptop /smartphone thereafter.  If deemed important, these may be printed, and then kept as paper-based information (see below).

o    Paper-based information relating to client notes and records will be kept for a minimum of 7 years after the last session took place. 

o    Data relating to payment transactions, accounts and taxation will be kept for a minimum of 7 years to comply with HMRC requirements. 

The need to keep your information will be re-assessed on a regular basis.   When no longer required, paper records will be shredded, text / voicemail messages and computer records deleted. 

THE LAWFUL BASES I USE FOR HOLDING AND USING YOUR INFORMATION
 
Personal data:  I rely on a combination of contract and legitimate interests as the lawful bases for processing your personal information, that is:
 
o    for the performance of a contract to which you are party, or in order to take steps at your request prior to entering into a contract.  Article 6(1)(b)
 
o    for the purpose of legitimate interests, Article 6(1)(f).  This means that I may process personal data for legitimate business purposes.
 
Special category data:  The lawful basis I rely on is:
processing is necessary for the provision of health care or treatment or pursuant to a contract with a health professional.  Article 9(2)(h)

YOUR RIGHTS

Under data protection law, you have certain rights.  You may be able to use some of these rights in relation to information I hold about you.  These rights, however, don’t apply in all circumstances.    You can read more about these rights on the Information Commissioner’s Office website at www.ico.org.uk. 

o    The right to be informed:  You have the right to be informed about how I process your information.
o    The right of access:  You have the right to ask me for copies of your personal information.  There are some exemptions to this right.
o    The right to rectification:  You have the right to ask me to rectify information if you believe it is inaccurate or incomplete.
o    The right to erasure:  You have the right to ask me to erase your personal data in certain circumstances.
o    The right to restrict processing:  You have the right to ask me to restrict the processing of your information in some circumstances.
o    The right to data portability:  This right only applies when the processing is automated.
o    The right to object:  You have the right to object to the processing of your information in some circumstances.

Please ask if you have any questions about this privacy notice. If you believe the information I hold about you is incorrect or out of date, or if you have concerns about how I am handling your personal information, please contact me, Dorothy Davis, and I will try to resolve those concerns. 

If you have any further concerns about how I handle your data, you can contact the Information Commissioner’s office at:  Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF



Dorothy Davis
Queens Garden Business Centre 
31 Ironmarket 
Newcastle-under-Lyme 
Staffordshire
ST5 1RP

therapy@dorothyd.co.uk 
07941 630349



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