GDPR Privacy Notice

 
As from 25th May 2018 under the General Data Protection Regulations (GDPR) I (Compass Counselling Cornwall) am required by law to inform you (as my current therapy client or potential therapy client) about how I process and keep safe the data that I hold that pertains to you.


As I keep some personal data I am registered with the ICO (information Commissioners Office). This notice outlines what information I keep, why I keep it and what I will do with it.
 

What data do I keep and why do I need it?
Name and dob – these are used as an identifier if I need to speak to your GP or if you request a letter or report.


Address, email address & phone number – these are kept so that I can make contact with you.    They may also be used as identifiers if I need to speak to your GP or if you request a letter or report


GP details – these are kept for if you disclose information that makes me concerned for your welfare.  As discussed in the confidentiality policy I will only contact your GP after discussing it with you wherever possible. 


The lawful basis that I use for storing and processing your personal date is Contract.  This is because I am providing you with a service and I require further information to be able to provide you with that service.


When may your data be shared?

I will not sell your data on or use it for unethical reasons.

I may have to share your data if my notes are subpoenaed by court.

If you disclose information that that raises safeguarding concerns including serious risk of harm to yourself or others; or abuse or neglect of a child or vulnerable adult, I have a duty of care to disclose that to the appropriate authorities.


If you disclose information that indicates that you are at substantial risk of suicide, I will release that information to your GP.  If there is an immediate risk I will contact the emergency services.


If you disclose anything to do with terrorism, drug trafficking or money laundering I am legally required to inform the police and it is a criminal offence for me to inform you that I have done so.


I have appointed a clinical executor.  This means that in the unfortunate event that I can no longer work with you due to my unexpected death the clinical executor will have access to your details and will contact you to inform you of this.


If I do share information about you I will always aim to discuss it with you first unless the situation requires an immediate response.  

If I am required to release information before discussing it with you, I will inform you at the earliest opportunity except in the case of information relating to terrorism, drug trafficking or money laundering.  I will never share your data for any reason other than the reasons stated above.


How will I store your data?
The data on paper which includes a paper copy of the privacy consent, contact details and counselling agreement is kept in a locked metal filing cabinet that only I have access to.


Computerised session notes are kept on a password protected pc, all client files are password protected under an identifying code, not your name.  In the future event that that I am unable to access the pc I also keep a copy of the computerised session notes on a usb, all client files are password protected under an identifying code, not your name, the usb is kept in a locked metal filing cabinet.


Your phone number will be kept on my mobile phone under an identifying code, not your name. My phone is locked with a password when I am not using it.


How long will I store your data and how will I dispose of it?
Your session notes and signed privacy consent will be kept for 5 years from the date of our last session.  This is a requirement of my professional insurance company.


I will shred the paper contact details and counselling agreement containing your personal data one month after our work has ended.


All emails from you will be deleted as soon as they are no longer relevant and this will be at least within one month of us ending working together.


Your phone number will be deleted from my phone 7 days after your final session.


If you wish to remove your agreement to my use of your data at any point please let me know by phone 07999 598045 or email Compasscounsellingcornwal@gmail.com


If you are not happy with the way I use your data you can complain to ICO at www.ico.org.uk or on 0303 123 1113.

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