Privacy Policy

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My lawful basis for holding and using your personal information

It is very important to us that our clients are kept aware and informed regarding how their information is kept secure and we follow relevant legislation. We are happy to supply a written copy of this any any policy that a client may wish to have. We will explain any of the processes and/or information which is contained in this policy to ensure that our clients are satisfied they understand how we hold their information. 

The GDPR states that I must have a lawful basis for processing your personal data. There are different lawful bases depending on the stage at which I am processing your data. I have explained these below:

·  If you have had therapy with me and it has now ended, I will use legitimate interest as my lawful basis for holding and using your personal information.

·  If you are currently having therapy or if you are in contact with me to consider therapy, I will process your personal data where it is necessary for the performance of our contract. 

Intuitive counselling website does not hold, store or collect any or your personal information. The only time we have any access to your information is when you choose to contact us, via email providing your personal data for us to reply to you to follow up on your request for information. It will only be used to send information relating to our services and products. We will never send third parties client information. Personal information will only be communicated with the client on their verified email, that has been agreed beforehand. 

How we use your personal data

The following ways is how we use your personal data as a company:

·  To maintain client records in a manner that fulfils ethical and legal standards in accordance with the British association of Counsellors and Psychotherapist (BACP) framework

·  To ensure that all insurance requirements are maintained

·  In the event of  insurance claims, or police enquires are made, session notes may  be requested by a third party (police, solicitors etc) this will only be granted with full authority and process with my insurance company and their processes

·  In, the event your notes are required to be viewed by a third party, you will be  kept fully informed of the process and how this will happen and counselled through this action. My insurance company is Holistic Insurance. 

·  To ensure payments are made and processed as required, and ensuring no acts of fraud have occurred whilst you have any interaction with Intuitive Counselling

·  On no occasion will your information be used for marketing, or be passed to a third party for this action. 

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Initial contact.

When you contact me with an enquiry about my counselling services I will collect information to help me satisfy your enquiry. This will include:

·  Name

·  Address

·  Email address

·  Phone number

·  GP details

·  Outline of issues that you bring to your session

Alternatively, your GP or other health professional may send me your details when making a referral or a parent or trusted individual may give me your details when making an enquiry on your behalf.

If you decide not to proceed I will ensure all your personal data is deleted within [one year)If you would like me to delete this information sooner, just let me know.

While you are accessing counselling.

Rest assured that everything you discuss with me is confidential. That confidentiality will only be broken if:

·  There has been a crime and it is deemed necessary that I need to disclose your information

·  In some situations, clients’ needs or the public interest in a specific situation may potentially outweigh the general duty of confidentiality

·  Prevention of harm to self or others

·  Prevention or detection of crime

·  The Terrorism Act (2000): any information which s/he either knows or believes might help prevent another person carrying out an act of terrorism or might help in bringing a terrorist to the UK and radicalisation

·  It is thought there may be a possibility is drug trafficking  and money laundering

·  Under s.21 of the Road Traffic Act 1991 (which imports new wording into s.172 of the Road Traffic Act 1988), if the police require information about the driver of a vehicle at the time of an offence, it must be disclosed, and failure to do so is a criminal offence

·  In the context of working with children and young people, the family court can make a recovery order under s.50 of the Children Act 1989 in relation to a child who is in care, under police protection or subject to an emergency protection order, and who has been abducted, has run away or is otherwise missing. The court may require any person who has information as to the child’s whereabouts to disclose that information, if asked to do so, by a constable or the court, see section 51(3)(c). Failure to comply with the order may constitute the offence of contempt of court. I will always try to speak to you about this first, unless there are safeguarding issues that prevent this.

·  Under the Serious Crime Act 2007, parts of which are now implemented, the courts can make a Serious Crime Disclosure Order requiring a person in possession of information or documents relevant to an enquiry about a serious crime to disclose them to a nominated person, usually a police officer, or to the court.

·  Under the Serious Crime Act 2007, parts of which are now implemented, the courts can make a Serious Crime Disclosure Order requiring a person in possession of information or documents relevant to an enquiry about a serious crime to disclose them to a nominated person, usually a police officer, or to the court.

·  The Female Genital Mutilation Act 2003 (as amended by section 74 of the Serious Crime Act 2015) introduced a mandatory reporting duty for all regulated health and social care professionals and teachers in England and Wales. Professionals must make a report to the police, if, in the course of their duties:

·  • they are informed by a girl under the age of 18 that  she has undergone an act of FGM; or

·  • they observe physical signs that an act of FGM may have been carried out on a girl under the age of 18.

GoDaddy.com

Our website is hosted by GoDaddy.com. it provides an online platform that ensures Intuitive Counselling can sell our services to you. GoDaddy provides a storage facility, database and general application to provide a website for you to email us, see our services and location. They store all data on secure servers behind various security systems and firewalls.

For more information relating to GoDaddy’s terms and conditions and services please visit their website https://aboutus.godaddy.net/about-us/overview/default.aspx

And read their privacy statement at https://www.godaddy.com/en-uk/legal/agreements/privacy-policy

How we protect your data

GoDaddy.com has a secure platform ensuring all personal data on its website is accessed and add on applications through “http” technology. Our website is password protected and has end-to-end encryption. You can tell whether a page is secure as 'https' will replace the 'http' at the front of the www.intuitivecounseeling.co.uk  in your browser address window. A small locked padlock will also appear in the bottom bar of your browser window. Using an unsecured network in a public place can be risky as unauthorised people may try to intercept anything you're doing online. It’s imperative that you use a trusted network, for all of your internet access. By using a secured server, it will protect you from “pop up” cookies/hackers and ensure you have a safe network. 

Your records, such as counselling notes, personal data and contact data once you enter the counselling process will be kept in a locked filing cabinet, away from public view. All counselling notes will be anonymised and will be allotted a number. This number will be kept in a book next to your name and address, and another personal information, along with your initial counselling contract. This is kept in a different place from your counselling notes, ensuring that, in the event of a break in or loss of either notes or personal data, your information will be safe and kept confidential, and the two will not be able to be bought together. 

I am registered with the information commissioner to hold personal data and follow their strict policies and procedures.I also meet the necessary criteria for the GDPR 

How Long will we keep your personal data?

All of your personal information will be kept safe and secure for the length of time that you are receiving services from Intuitive counselling, plus what is stated by my insurance company and governing body. This will be reviewed on an annual basis and kept up to date in accordance with information received by them and ither responsible bodies. The retention time is dependent upon the type of information and the purpose that is has been collected. If it is creative items, such as art work, clay, pottery or drawings etc, the client will be asked if they wish to take them with them when finished with. A picture will be taken, downloaded, printed off and added to paper notes. The digital image will be destroyed immediately. If the client does not wish to keep any creative work, it. Will be immediately destroyed by the appropriate means such as shredding, breaking up or being reused. All data and sources of client information will be maintained under the applicable regulations.

Who do we share your data with?

We do not share your data with any third parties, except in those cases as described in this privacy policy. Under the new rules, to foster openness and transparency of process, the Coroner must, on request, normally disclose information received (e.g., reports and other relevant documents) to ‘interested persons’ defined

in the legislation. Under Rule 14 of the Coroners (Inquests) Rules 2013, documents may be redacted where appropriate.

Confidentiality and privacy of client information may be breached and disclosed in the event of:

·  To comply with and applicable law, legal process, or government request.

·  Investigations of those as mentioned in the privacy policy

·  Investigation, detection, prevention or action regarding illegal activates, suspected fraud or security of the state

·  Suspected threat of terrorism of self or others, including radicalisation

·  Prevention of harm to self and others and property

·  To defend legal claims

Do we  intend to transfer it to another country?

Intuitive Counselling do not intend to transfer your information to another country unless you specifically ask us to do so. In this event we will ensure this is done safely and securely and in accordance with all legal requirements. I will take advice from the relevant bodies when doing this. 

Third-Party sites and Links

We are not responsible for any links that may be seen whilst visiting our website. We cannot be held responsible for their content, or further links that they may hold. Once you leave our website, we advise that you do your own due diligence and take into account each and every privacy policy and statement to ensure

Your Rights

Intuitive counselling tries to be as open as we can in terms of giving people access to their personal information, to limit how we use your personal information or to stop processing your personal information. You also have a right to ask for a copy of any information that Intuitive Counselling holds about you and to object to the use of your personal data in some circumstances. You can also read more about your rights at ico.org.uk/your-data-matters .

If I hold information about you I will:

·  Give you a description of it and where it came from:

·  Tell you why I am holding it, tell you how long I will store your data and how I made this decision;

·  Tell you who it could be disclosed to;

·  Let you have a copy of the information in an intelligible form.

You can also ask me at any time to correct any mistakes there may be in the personal information I hold about you.

To make a request for any personal information I may hold about you, please put the request in writing addressing it to chloe.finn@intuitivecounselling.co.uk.

If you have any complaint about how I handle your personal information, please do not hesitate to get in touch with me in writing or emailing me to the contact details given above. I would welcome any suggestions for improving my data protection procedures.

If you wish to make a formal complaint about the way I have processed you personal information, you can contact the ICO, which is the statutory body that oversees data protection law in the UK. For more information go to: ico.org.uk/make-a-complaint. 

Author: C Finn

Written: July 2022  Review Date: July 2023