General Approach
□ I aim to work within current UK Data Protection Regulations and BACP guidelines about how I collect, store and delete your personal details & information.
□ This Privacy Policy forms part of our Counselling Agreement which you will have been given at the start (or soon after the start) of our work together. By continuing our work together we are agreeing this Privacy Policy is part of our contract.
□ I ask about two types of information;
1] Personal Data (e.g. name, address, ‘phone number, email address). I ask about this so that, for example, I may contact you about a change in session times, coordinate care with e.g. your GP or email you with an invoice.
2] Information about your Personal Life (e.g. about your work, about your relationships, about your personal experiences…) as a way to understand the issues you’re bringing into therapy with me and to help us make progress towards your therapeutic goals.
□ The way I use this information is limited to providing you with care – in a similar way to how your doctor or dentist might use it. I do not, and will never, use this information for any kind of marketing, newsletters, connection by social media or psychological reasearch.
Personal Data
□ I record the following personal data;
– Name, ‘phone number(s), email address – for all clients as an effective way to make arrangements. For on-line clients this will also include an identifier for video calling (e.g. Skype address or FaceTime ID).
– Address – for all clients as a way to send invoices and, in specific circumstances (see ‘Confidentiality’ below) to contact emergency services.
– Session times, whether session attended, payment amounts & dates – for all clients as a way to maintain accurate financial records.
– Date of Birth and contact details of others involved in your care – if we agree that I may coordinate your care with others.
□ If you are attending as a couple then I record the information above for both partners.
Information about your Personal Life
□ I sometimes (but not always) make notes about our sessions together. These will be brief and limited to what is relevant to understanding your situation and making progress towards your therapeutic goals.
□ I make these brief session notes on paper only – they are not held electronically.
Confidentiality.
□ I aim to work responsibly within the ethical code of BACP and this includes keeping in confidence whatever you tell me of your personal life.
□ This strict confidentiality is limited in the following ways;
1. Legal Obligation. Disclosure of serious crime (such as terrorism, drug trafficking or money laundering) would mean I am required to inform UK police. Also, in rare cases, a court of law may compel a therapist to break confidentiality.
2. Ethical Limitation. If I think there is an immediate and severe risk of you causing harm to yourself or others I may contact the person or service I think most able to manage this risk. This could be the emergency services or e.g. your psychiatric care coordinator.
3. Professional Obligation. To maintain my effectiveness I am required to have continuous professional supervision and may discuss our work with my supervisor. On these occasions I will not disclose any information which could be used to identify you.
4. Financial Probity. Where fees are being paid (wholly or partly) by a third party the client agrees that the third party may know details of the dates (not times) of sessions (either attended or cancelled) and payments received from the client.
5. Open Communication (couples counselling only). In the spirit of building relationship, all personal disclosures need to happen with your partner’s knowledge as part of our shared process. So I won’t ‘keep things secret’ from your partner for you.
6. Technological Limitation (on-line counselling only). It may be that the online service which we agree to use (e.g. Skype) has inbuilt insecurities. In agreeing to use any online service we each accept any limits to confidentiality that using this service creates.
In cases where these first two limitations meant that information about you was going to be disclosed I would;
a. Seek your involvement if possible and lawful.
b. Aim to strike a balance between your need for privacy and my responsibilities.
c. If time allows, seek consultative support from a counselling supervisor or other experienced practitioner before taking action.
Storage, Security and Deletion – Paper
□ The two types of information above (Personal Data & Information about your Personal Life) are both held on paper documents.
□ The two types of paper documents are stored separately in lockable cabinets at different locations.
□ Your Personal Data document gives no information about your presenting issues. Similarly, any session notes are written in a way which means you could not be identified from them (they are linked together by a reference code).
□ I (myself) destroy both sets of paper documents securely after a period of time. I retain documents for the minimum amount of time needed so this destruction is usually at the end of our work together. I sometimes do keep these notes for longer if they might need to be referenced for a legal, insurance or complaints process.
Storage, Security and Deletion – Email and ‘Phone
□ The nature of using email, ‘phones and video calling means that my devices retain contact details (part of your Personal Data) and records of our communication.
□ Access to all my devices requires a secure password which is only known by me.
□ I do not keep your full name on my ‘phone contacts – I use only your first name with an initial.
□ I delete all email, ‘phone & video contact details/messages immediately at the end of our work together.
Your Rights under UK Data Protection Law
□ You have the right to see the information I hold about you and have this explained by me.
□ You may request to have any of this information corrected or erased. However, if this impacts on my capacity to work ethically with you then I may bring our therapeutic work to a close.
□ You may also request to have the further collection of this information limited or cease altogether. However, if this impacts on my capacity to work ethically with you then I may bring our therapeutic work to a close.