1. Purpose
I respect the privacy of all clients and am committed to protecting personal information. I handle personal data in accordance with the UK General Data Protection Regulation (UK GDPR), Data Protection Act 2018, and relevant professional and ethical requirements.
This policy explains what personal information I collect, why I collect it, how it is stored and protected, and the rights clients have regarding their information.
2. Information I Collect
Depending on the counselling service provided, I may collect:
Name and contact details.
Date of birth, where necessary.
Emergency contact details, where appropriate.
Information relevant to counselling and wellbeing.
Counselling session notes and records.
Correspondence relating to appointments and counselling.
Payment and invoicing information.
Information required for safeguarding or legal purposes.
I will only collect information that is relevant and necessary for providing a safe and appropriate counselling service.
3. How I Use Personal Information
Personal information may be used to:
Provide counselling services.
Arrange and manage appointments.
Maintain appropriate professional records.
Communicate with clients.
Manage payments and administration.
Meet professional, legal and safeguarding responsibilities.
Respond to legitimate requests for information.
Personal information will not normally be used for purposes unrelated to the counselling service.
4. Special Category Information
Counselling may involve information concerning a person's physical or mental health, wellbeing or other sensitive personal circumstances.
Such information is treated as special category data under UK data protection law and will be processed only where there is an appropriate lawful basis and condition under the UK GDPR.
5. Confidentiality
Information shared during counselling is treated as confidential.
There are limited circumstances in which information may need to be disclosed, including where:
There is a serious risk of harm to the client or another person.
There is a safeguarding concern.
Disclosure is required by law or a court order.
Disclosure is otherwise necessary to meet a legal or professional obligation.
Where appropriate and safe to do so, I will discuss disclosure with the client beforehand.
Please refer to my Confidentiality Policy for further information.
6. Storage and Security
I take reasonable and appropriate steps to protect personal information against:
Unauthorised access.
Loss or theft.
Accidental disclosure.
Unauthorised alteration.
Unnecessary or inappropriate use.
Electronic information will be stored using appropriate security measures, including passwords and device security where applicable.
Paper records will be stored securely and access will be restricted.
7. Email, Telephone and Online Communication
I may use email, telephone, text messaging and online counselling platforms to communicate with clients.
I will take reasonable steps to protect confidentiality, but electronic communication carries inherent privacy and security risks.
Clients are encouraged to avoid sending sensitive therapeutic information by text or email unless specifically agreed.
8. Sharing Information
I will not normally share personal information with third parties without the client's consent.
Information may be shared without consent where there is a lawful basis to do so, including circumstances involving serious risk, safeguarding, legal requirements or court orders.
Where information is shared, I will aim to disclose only information that is necessary and proportionate.
9. Professional Supervision
As an NCPS counsellor, I undertake regular professional supervision.
Relevant client material may be discussed with my supervisor for the purposes of safe, ethical and effective practice. Identifying information will be minimised wherever possible.
10. Data Retention
Client records will be retained only for as long as necessary for legitimate professional, legal, insurance or regulatory purposes.
At the end of the applicable retention period, records will be securely destroyed or permanently deleted.
My current record-retention period is: [Insert period]
11. Client Rights
Subject to applicable legal requirements and exemptions, clients have rights regarding their personal data, including the right to:
Request access to personal information held about them.
Request correction of inaccurate information.
Request deletion of information in certain circumstances.
Request restriction of processing in certain circumstances.
Object to certain processing.
Make a complaint regarding the handling of their personal information.
Requests should be made in writing to:
Email: lindagwatkin@btinternet.com
Address: 2 Pentre View Miller road, Brymbo LL11 5FH
12. Data Breaches
If I become aware of a personal data breach, I will assess the incident and take appropriate steps to contain and resolve it.
Where required by law, I will notify the Information Commissioner's Office (ICO) and/or affected individuals within the applicable timescales.
13. Cookies and Website Information
If I operate a website, information about cookies and website data collection will be provided through the relevant website privacy and cookie notices.
14. Data Protection Contact
For questions or concerns regarding the handling of personal information, please contact:
Counsellor: Linda Gwatkin
Email: lindagwatkin@btinternet.com
Telephone: 07709935424
Clients may also contact the Information Commissioner's Office (ICO) if they have concerns about how their personal data has been handled.
15. Policy Review
This policy will be reviewed regularly and updated where necessary to reflect changes in legislation, professional guidance and NCPS requirements.
Policy Owner: Linda Gwatkin
Date: October 26______________________
Review Date: October 27______________________