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GENERAL INFORMATION

After consulting with the Information Commissioners Office (ICO), insurers (Howdens), and the ethical guidelines of the British Association of Counselling and Psychotherapy (BACP), Headspace Counselling Ltd is letting you know about the use of your personal data. This is in line with requirements set out by the General Data Protection Regulation coming into effect on May 25th 2018, and the Data Protection Act 2018. This will be updated as needed.

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ABOUT YOUR PERSONAL INFORMATION


Headspace Counselling Ltd processes personal information and data for the purposes of carrying out counselling, supervision and training services. Processing your data is necessary to offer these services and your privacy is respected. We discuss this further if you chose to use Headspace Counselling’s services, and can discuss any questions you may have.

Personal information is collected to: communicate with you, book sessions, inform you about changes to session times etc., and to maintain records of our sessions.

Personal information is used to communicate with you: via phone, text, email and letter. If you contact Headspace Counselling Ltd through the website and email, this is hosted by GoDaddy. The website is supported by an SSL certificate.

The personal information collected includes your: names, addresses, phone numbers, email addresses, date of birth, GP details, other professionals involved in the supporting you, personal details relevant to session content.

Personal information is collected and stored securely to: enable the provision of counselling services, in relation to safeguarding processes agreed and discussed in our counselling contract and agreement on safeguarding, confidentiality and information sharing.  (Also, see below)

Personal information and data is held on paper format and stored securely in locked filing cabinet: this is held for 6 years after the end of our work together, as recommended by insurers; this will be securely destroyed by shredding after this date.  Emails and phone communications are deleted, at the latest, when our work together has finished.

Records of our session content are coded to respect your privacy and anonymity, and will be stored in a separate locked filing cabinet to names and addresses.
These notes are of factual information and key themes discussed in our sessions. This may include personal and sensitive information. This is for my recollection of our work (clients, supervisees and training participants), to use for the supervision of my work, and for lawful obligations. These are kept for 6 years before being securely destroyed by shredding.

All work at Headspace Counselling is supervised by an external supervisor, to monitor practice and in line with BACP ethical guidelines. Any discussions of casework in supervision respect your privacy and anonymity.

Personal information and data is not used for marketing.


YOUR RIGHTS

Under GDPR you have the following rights:

  • To access copies of any information held about you, through a data subject access request. To be responded to within 1 month.
  • To have inaccuracies rectified, or completed if they haven’t been.
  • Data portability – to obtain and reuse personal data for own purposes across different services.
  • To opt out of data collection.
  • To object to personal data being collected.


If you do not want to have information collected, stored or would like to opt out – Headspace Counselling would not be able to offer its services as the information collected and stored is required to offer its services.

 
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SAFEGUARDING/CONFIDENTIALITY/SHARING INFORMATION


Your personal information is respected and not shared without consent, though there are exceptions to this. If this becomes an issue during our work together, I endeavour to discuss any sharing of information with you unless required not to do so by law.

The following are exceptions to confidentiality:

  • Legal (terrorism, money laundering, serious crime, court subpoena of notes).
  • Risk of significant harm to self or others – this information may need to be shared.
  • Risk of harm to child/vulnerable adult  - this information may need to be shared.



LEGITIMATE BASIS FOR PROCESSING YOUR DATA

  • The GDPR requires Headspace Counselling Ltd to identify the lawful basis to process your information under Article 6, and Article 9 (for special category or more sensitive information). After consulting with the ICO:


  • The lawful basis for processing personal information required by Article 6 in of the GDPR is “legitimate interest”.


  • The lawful basis for processing ‘special categories of personal data’ required in Article 9 of the GDPR comes under the Data Protection Act 2018 (c. 12) Part 2 – General processing – Chapter 2 – The GDPR; Section 10.


  • Article 8(1) of the GDPR: requires parental consent for processing children’s personal information for Under 16s,  with reference to “information society services”: The Data Protection Act 2018 (c.12) Part 2 — General processing - Chapter 2 — The GDPR,  Section 9 (a) and (b) provides 'lawfulness of processing' for this information with children 13 and over able to consent in the UK, and states, “… the reference to “information society services” does not include preventative or counselling services.”




Headspace Counselling Ltd - MAY/2018

        Headspace Counselling