What is GDPR?
The General Data Protection Regulation (EU) 2016/679 (GDPR) is a regulation in EU law on data protection and privacy for all individual citizens of the European Union (EU) and the European Economic Area (EEA). It also addresses the transfer of personal data outside the EU and EEA areas. The GDPR aims primarily to give control to individuals over their personal data and to simplify the regulatory environment for international business by unifying the regulation within the EU.
In order to comply with GDPR regulations, Third Space Counselling collects and processes personal data of people we work with to carry out its functions. This ‘Privacy Notice’ details our commitment to being transparent about how we collect and use your data and to meeting our GDPR obligations.
Who are we?
The ‘Data Controller’ in our organisation is Alison Marley.
What information do we collect?
When you make an enquiry or online booking we ask for your name and contact details which are known as ‘personal data’. If you undertake therapy sessions with us, we will make a note of what we have talked about during your session(s). This may contain other ‘personal data’ you share such as age, marital status, children, date of birth, gender or occupation and ‘special category data’ such as race, ethnic origin, politics, religion, health, sex life or sexual orientation.
Why do we collect personal data?
What is the ‘lawful basis’ on which we use this information?
To collect and use data you share, we must show the ICO that we have a lawful basis to do this. We also need to tell you what this lawful basis is.
We have determined that ‘legitimate interests’ is the most appropriate lawful basis for both personal (article 6) and special category data (article 9). Click here for further details.
How do we store your data?
Your data will be stored in a lockable cabinet, on a password protected laptop and/or on a mobile phone (Touch ID enabled and password protected). We also use a cloud-based client management system (CMS), which is encrypted to stringent standards. Any data written or printed on paper will be shredded by a cross-shredder when it needs to be destroyed.
How long will we keep your data?
Your data will be kept for the duration of our work together. When our work together has finished, all data except for session notes (which we are professionally obliged to store for up to 7 years) will be deleted or securely disposed of.
How might your information be shared?
We would only share data in line with ethical and legal obligations. These are:
- during the clinical supervision sessions we are required to have by our accrediting organisations, we may talk about our work together. However, only your initials or a pseudonym would be used.
- if we receive a Court Order for the release of our notes.
- if you disclose you are at risk of serious harm to yourself or another.
- if you share information about a proposed act of terrorism/money laundering/drug trafficking.
- if there is a request by the Police for information regarding a road traffic accident.
- any Child Protection issues.
What are your rights?
You have the right:
- to be informed about what information we hold – a link to this ‘Privacy Notice’ will either be emailed to you during our initial communications or we will provide you with a copy at your first session.
- to access the information we hold – you can request this in writing at any time. We will provide you with the information within one month.
- to have any incorrect information rectified – you can request this verbally or in writing.
- to have your records erased (in the defence of any legal claims, we may decline to do this citing the lawful basis of legitimate interests)
- to restrict processing (we may decline to do this citing the lawful basis of legitimate interests)
- to data portability – e.g. you can request your notes be transferred to another counsellor.
- to object to processing of your data (we may decline to do this citing the lawful basis of legitimate interests)
If you have any concerns about how we will use your data please contact the Information Commissioner’s Office (ICO), Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF – Tel: 0303 123 1113 (local rate) or 01625 545 745 (national rate).
If you would like to discuss anything in this Privacy Notice, please contact Alison Marley via email firstname.lastname@example.org.