The purpose of this notice
The processing of personal data, is governed by the General Data Protection Regulation (the GDPR). This legislation is a data privacy law, giving you rights as an individual and imposing obligations on organisations, including Chrysallis Counselling & Psychotherapy, in relation to holding your personal data.
One of the rights is a right to be informed, which means I have to give you information about the way in which I use, share and store your personal information.
You can read more about GDPR at the website of the Information Commissioner: ico.org.uk.
Chrysallis Counselling & Psychotherapy is a counselling and psychotherapy service provided by Fiona Firman. Chrysallis Counselling also offers clinical supervision and training.
Contact details: 22 Drumsheugh Gardens, Edinburgh, EH3 7RN | 07842613004 | firstname.lastname@example.org
In the terms set out in the legislation, Fiona Firman is the data controller. The data controller is the person who decides how your personal data is processed and for what purposes.
Whose information does this privacy notice apply to?
This privacy notice applies to information I collect from:
- prospective clients
- former clients
- visitors to the chrysalliscounselling.co.uk website
What is personal data?
Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. Examples of personal data I may hold about you include your contact and appointment details.
Special category data is a sub-category of personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. Examples of special category data I may hold about you include your client notes.
How do I process your personal data?
I use your contact details to arrange and re-arrange appointments and to get in touch with you if you miss an appointment. I use your client notes as reminder of what we have talked about in previous sessions and to help me think and, sometimes, plan, what might be helpful in future sessions. I use a record of sessions (dates of sessions, record of non-attendance, etc.) for accounting purposes, to log the number of hours I have worked, and to inform my understanding of my work with you.
I comply with my obligations under the GDPR by keeping personal data up to date, by storing and destroying it securely, by not collecting or retaining excessive amounts of data, by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data. I use your personal data for the purposes set out below.
Clients, prospective clients, and former clients
Contact information I use your name, address, telephone/mobile number and email address to make and rearrange appointments. If you become a counselling or psychotherapy client, you will also be asked for contact details for a GP / GP Practice and also for an emergency contact. These are for use in emergencies, for example, concern about your safety.
Client notes Client notes comprise handwritten notes, typed notes (stored on computer and/or printed out), and, on occasion, emails or letters exchanged between you and me. Paper notes are kept in a locked filing cabinet in my office. Electronic notes are only stored on a computer that uses password protection. Your client notes may include emails sent by me or sent by you. The aim of keeping client notes is to help make counselling and psychotherapy more effective by allowing me to refer back to the content of previous sessions.
Record of sessions I keep a record of sessions attended and missed. I also keep a record of session payments. I don’t share records of sessions with anyone.
Clinical Will Contact details for current clients are stored in an electronic file that can be accessed by a colleague who also works as a counsellor and psychotherapist. In the event of my sudden death or incapacitation this would allow for current clients to be contacted and, if appropriate, referred to another counsellor / psychotherapist.
When someone visits the website www.chrysalliscounselling.co.uk third party services collect standard internet log information and details of visitor behaviour patterns. I do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way, which does not identify anyone. Website cookies are used only for the purposes of helping gather these statistics enabling the website to ‘remember’ users, either for the duration of their visit – using a ‘session cookie’ – or for repeat visits – using a ‘persistent cookie’.
Note on emails
I do not work with encrypted emails so you should be aware that any emails I send or receive may not be protected in transit. Please be aware that you have a responsibility to ensure that any email you send me is within the bounds of the law.
Sharing your personal data
Your personal data will be treated as strictly confidential, and will be shared:
- with named third parties with your explicit consent, e.g. if you ask me to write a letter on your behalf;
- with the executor of my clinical will in the case of my sudden death or incapacitation, contact details – but not client notes – would be used to inform / advise current clients.
- with the relevant authority such as the police or a court, if necessary for compliance with a legal obligation to which I am subject e.g. a court order;
- with your doctor or the police if I judge there is a risk of harm to yourself or others;
- with the police or a local authority for the purpose of safeguarding a children or vulnerable adults; or
- with my regulatory body, COSCA and The United Kingdom Council for Psychotherapy (UKCP) and/or with PPS (Psychologists Protection Society) in the event of a complaint or a claim being brought against me; or
- my solicitor in the event of any investigation or legal proceedings being brought against me.
For further details about the situations when information about you might be shared please see the Information Commissioner’s website at ico.org.uk
How long do I keep your personal data?
I keep your personal data for no longer than reasonably necessary.
I keep client records for a period of three years from the last session. After this time, records are destroyed.
At any time you may request that changes are made to your contact details.
In the case of my sudden death, the executor or my “clinical will” will take steps to ensure the destruction of client notes.
Your rights and your personal data
Unless subject to an exemption under the GDPR, you have certain rights with respect to your personal data as set out below.
- The right to request a copy of your personal data, which I hold about you.
- The right to request that I correct any personal data if it is found to be inaccurate or out of date.
- The right to request your personal data is erased where it is no longer necessary for me to retain such data.
- The right to withdraw your consent to the processing at any time. This right does not apply where I am processing information using a lawful purpose other than consent.
- The right to request that I provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable)
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing.
- The right to object to the processing of personal data, (where applicable)
- The right to be informed if your data is lost. I shall also inform the Information Commissioner’s Office in accordance with the time limits in the GDPR.
- The right to lodge a complaint with the Information Commissioner’s Office.
For further details about these rights please see the Information Commissioner’s website at ico.org.uk
When I receive a complaint, I record all the information you have given to me. I use that information to resolve your complaint.
If your complaint reasonably requires me to contact some other person, I may decide to give some of the information contained in your complaint to the other person. I do this as infrequently as possible, but it is a matter for my sole discretion as to whether I do give information, and if I do, what that information is.
I may also compile statistics showing information obtained from this source to assess the level of service I provide, but not in a way that could identify you or any other person.
If you complain about any of the content on my website or in any leaflet, I shall investigate your complaint. If I feel it is justified or if I believe the law requires me to do so, I shall remove the content while I investigate.
If I think your complaint is vexatious or without any basis, I shall not correspond with you about it.
To exercise all relevant rights, queries or complaints please in the first instance contact me at email@example.com
You can contact the Information Commissioners Office on 0303 123 1113 or via the website (ico.org.uk) or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.
END OF PRIVACY NOTICE – 24th May 2018
Updated 28th July 2020