Privacy Notice
Overview
Your privacy is very important to me and you can be confident that your personal information will be kept safe and secure and will only be used for the purpose it was given to me.
I adhere to current data protection legislation, including the General Data Protection Regulation (EU/2016/679) (the GDPR), the Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
This policy explains when and why I collect personal information, how I use it and how I keep it secure from the first enquiry you make through to when you finish your therapy with me.
I review this policy regularly and where necessary make updates to ensure it accurately reflects how I use your data. I will notify you if there are changes which affect how your data is processed.
I am happy to chat through any questions you might have about my data protection policy and you can contact me via email at privacy@rebeccarosetherapy.com or by telephone on 07447 301 612.
‘Data controller’ is the term used to describe the person/ organisation that collects and stores and has responsibility for people’s personal data. In this instance, the data controller is me. I am registered with the Information Commissioner’s Office, my registration number is ZA211053.
1. My lawful basis for holding information about you
I work independently in private practice offering psychodynamic psychotherapy to adults.
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. The GDPR also makes sure that I look after any sensitive personal information that you may disclose to me appropriately. This type of information is called ‘special category personal information’. The lawful basis for me processing any special categories of personal information is that it is for provision of health treatment (in this case psychotherapy) and necessary for a contract with a health professional (in this case, a contract between me and you).
2. How I use information about you
When you visit this website
When someone visits this website, Wix (the Website provider) collects standard internet log information and details of visitor behaviour patterns, we do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way that does not identify anyone. I do not make, and do not allow Wix to make, any attempt to find out the identities of those visiting the website. I use legitimate interests as my lawful basis for holding and using your personal information in this way when you visit the website.
Like most websites I use cookies to help the site work more efficiently these do not identify you as an individual. No user-specific data is collected by me or any third party. If you complete a contact form on the website, that data will be stored on my web hosting account with Wix as well as sent to me.
When you first make contact with me
When you contact me with an enquiry about my services I will collect information to help me satisfy your enquiry.
This will include your name, and the contact details you provide, usually an email address and/or telephone number. You might also have included details about why you wish to access therapy. I store personal data in email form and on my mobile telephone in the form of emails, text messages, voicemails and call logs. I do not store your contact details in my mobile phone.
If you decide not to proceed I will ensure all your personal data is deleted within one month. If you would like me to delete this information sooner, just let me know.
At your therapy sessions
Rest assured that everything you discuss with me is confidential. I will not disclose information about you to a third party without your agreement, except in situations where there was significant concern about harm to you or someone else and this would normally be discussed with you beforehand. Unless the requesting party has a basis in law for demanding disclosure, my duty of confidentiality and your rights as the data subject may outweigh the reason behind the disclosure request.
I will keep a record of your personal details to help the sessions run smoothly. These details are kept securely on my computer and are not shared with any third party.
I keep brief session notes describing the content of what we discussed and in particular any risk issues or changes in circumstances that you disclose to me. These are stored in an encrypted file on my computer.
When we correspond during treatment
Where applicable, I will usually retain correspondence between you and me. This is stored securely.
If we conduct sessions remotely
I occasionally provide sessions remotely when face to face work is not possible. This would be discussed between us to ensure it is appropriate for your needs. I offer remote sessions using Microsoft Teams, Zoom or the telephone.
Telephone is generally considered a private means of communication. If you prefer Microsoft Teams or Zoom please satisfy yourself that you are happy with Microsoft’s and Zoom’s privacy statements.
When you pay your fees
I usually ask clients to pay by BACS or using a card payment machine. This means your name will appear on my bank statement as it appears on your bank account. If you would like to avoid this, there is the option to pay with cash.
After counselling has ended
Once counselling has ended your records will be kept for 6 years from the end of our contact with each other and are then securely destroyed.
3. Who do I share your information with?
Marketing
I will not share information with, or sell your data to, any third parties for the purposes of direct marketing.
Third-party data processors
I use third-party data processors to provide elements of services for me, for example Microsoft Office 365 and Zoom. I do not share ‘special category’ data with them. These third-parties have their own GDPR privacy policies on how they handle personal data.
Legal
Under some circumstances I am legally obliged to share information (eg a court order). I will always satisfy myself that I have a lawful basis on which to share the information, and document my decision-making.
Emergency-contact colleagues
In line with standard therapeutic practice and ethical requirements, I share patient names and contact information with two colleagues known as ‘professional executors’ in the event of an emergency. I provide these colleagues with access to a password-protected spreadsheet which contains your name, contact number and the date on which you commenced treatment.
4. Keeping your data secure
Access to your personal data is restricted so that it is only accessed by myself or my authorised clinical executors.
5. Your rights
The GDPR gives you certain rights in relation to the data I hold about you. You can exercise these rights by contacting me at privacy@rebeccarosetherapy.com
6. Under the GDPR you can:
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Find out what information I hold about you
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Access a copy of the information I hold about you
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Rectify any inaccurate or incomplete personal data
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Have the right to object to my processing of your personal information
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Ask me to delete or restrict how I use your personal information, but this right is determined by applicable law
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Have your contact information sent to another provider
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Have the right to appropriate decision making (I do not use automated profiling or decision making)
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Complain to a regulator if you think I have not complied with data protection laws. You can lodge a complaint with the Information Commissioners Office.
7. Review of this policy
I keep this policy under regular review. This policy was last updated on 23 July 2024.