Judy Field Counselling is committed to complying with the terms of the General Data Protection Regulation (GDPR) made on 25th May 2018, and to the responsible and secure use of your personal data. As a counsellor, I have a legitimate interest in processing personal data to provide counselling services. As part of my commitment to the privacy of existing and future clients, this policy is intended to give insight into the data I collect about you, how I use it, how I store it, and how it is shared.

Please note, my website contains links to other websites that may be of interest. However, I have no control over other websites. Therefore, I cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at their privacy policies.

What are the reasons for collecting information?

I am only allowed to collect personal information for proper and lawful reasons. At every stage of my relationship with you, your information will only be processed if it meets at least one of the following conditions:

• To fulfill my counselling agreement with you. This includes the collection of information before we enter into an explicit or implicit counselling agreement, during your counselling and after the counselling has ended.
• To ensure I am giving you a professional and ethical service that complies with the Ethical Framework of the British Association for Counselling and Psychotherapy (BACP), which I am a member of, and the requirements of my insurers.
• When it is my legal duty to collect, store, use or transfer information to comply with legislation or the instructions of a court of law
• When it is required to maintain your safety, the safety of third parties, or my own safety.
• To monitor the effectiveness of my website, and/or other marketing activity
• To enable financial transactions between us

How is information collected?

The personal identifiable information I collect, store and use come entirely from our conversations, emails, texts and phone calls.

The information others may hold comes from financial transactions between us

What information will you hold about me?

Whether or not you become a client of my counselling service, I will use your personal data for the purposes of initiating counselling for you. I collect the majority of this information during first contact and at the initial appointment. I will advise you if any of this data is optional.

Enquiries via my website contact form

Enquiries submitted through the Contact Form on my website collects your name, email and a brief description on what your enquiry is about, so that I can arrange to contact you to discuss counselling and/or arrange an initial appointment. Enquiries submitted via my website contact form are sent to me directly by email and once they are successfully delivered are then deleted from the website systems.

At first contact (face to face or telephone call)

I will collect the following information in order to establish if I can provide you with counselling:

• Your name
• Contact information including your email address
• At first contact you may also choose whether or not to share with me a brief description of what is bringing you for counselling now

At the first face-to-face / telephone appointment (Assessment)

At your initial appointment you will be asked for your consent to give me permission to process your data and also hold information about your healthcare professionals (e.g. GP). I will also collect the following information:

• Name
• Date of birth
• Contact information, including your email address
• Geographic information from your postcode
• Other information relevant to you engaging in counselling with me, e.g. the name of your GP practice
• Information about any disability or communication difficulty you may have

All clients will be allocated a code identifier within my personal filing system and the details listed above will be kept separate from any therapeutic information (counselling notes).

During counselling

• Following each counselling session, I record short factual anonymised notes. These are stored in a locked filing cabinet separately and securely from any personal contact details. Your identity is protected, and these notes are not shared with anyone unless I am legally required to do so. Private therapeutic information, such as counselling contract, assessment information, background information, therapeutic information and any email correspondence that’s relevant to your counselling process (this is usually correspondence that you have sent to me) will be filed under an allocated code identifier, separate from your personal contact details.
• Communication Information from letters, emails, texts, and phone calls. If you contact me directly in between sessions, I will acknowledge your email but discuss the content with you at the next session, this is to safeguard your personal information.
• Information about Agreements & Consent such as signed letters of consent.
• Information about financial transactions between us

What do you do with the information you gather?

I collect this information to understand your needs and provide you with a service, and in particular for the following reason:

• Internal record-keeping

How do you store information about me?

I store information in two forms.

Digitally:

• Contact information - Held on Phone, Laptop and backed up in the cloud and locally
• Emails - These are held on a laptop, phone and backed up on local devices.SMS Texts -These are held on a phone and backed up in cloud storage.My mobile phone is is password protected and details are stored in cloud storage so they can be restored if my phone is lost or stolen.

In paper form:

• I store all client details in a locked filing cabinet, I separate personal contact details from your counselling notes. The counselling notes are identified by a unique code identifier so that the personal details can’t be connected.
• Letters; signed consents and agreements, socio-demographic information. This is held separately to the case notes also in a locked cabinet
• Information about financial transactions (bank statements). This is held separately to the above in a file in an unlocked cupboard.
• Third Parties may hold information in any form.

Do you share information about me?

Who I may share personally identifiable information with:

• Statutory bodies when required to by law or instruction of a court of law
• Your emergency contacts in case of an emergency
• Statutory bodies when required to avoid harm to you, me or others
• For reasons of public interest in the area of public health
• Coronavirus contingency clause: confidentiality will be broken if I contract the virus and am obliged to inform the NHS of people I have been in contact with. In this case, I may need to share your name and contact details but not the context in which I know you. However, you may be contacted by the NHS.
• My accrediting/ethical membership body, insurers and professional advisers in the case of you making a complaint against me
• A lawyer - If your information is requested by a court or you raise a legal action against me I may take legal advice, in order to clarify whether the court has jurisdiction, and whether the request meets the strict legal criteria required in such cases. In this situation, I may consult a lawyer to help me make an informed decision about whether to release some or all the information I hold to the court. Personal information pertinent to the decision will be made available to the lawyer, who will be bound by a Professional Code of Conduct.

Who I may share anonymised personal information with:

• Professional counselling supervisor/s in order to ensure I am practicing effectively, safely and ethically
• Other counsellors who are members of a professional counselling and psychotherapy body (for example British Association for Counselling and Psychotherapy (BACP)) in order to gain insight and information from others who may be more experienced than me.

With your written permission I may share anonymised information with:

• Other counsellors when attending workshops, or other Continuous Professional Development events
• Counselling tutors and examiners to gain additional qualifications and accreditation.

How long will you keep my information?

I will keep your information for a variety of lengths of time depending on how it is held.

Digital Information:

Basic contact information - contact information, emails, texts, messages and calendar appointments. For technical reasons this information cannot be entirely erased and could therefore remain accessible to a technically competent person until the storage device is destroyed or securely wiped and reformatted.

I will hold your name and telephone number on my mobile phone until our counselling relationship ends and then I will delete it from my contact list. I only hold texts whilst they are relevant e.g. sent by either of us in connection with your appointments.

Paper information:

Notes and paper copies of contact information, emails, created media. These will be shredded 7 years after counselling ends. Paper information gathered during the introductory session will be shredded after 14 days if you have not contacted me to arrange paid sessions.

Marketing

I will never use your information for marketing, or contact you to market a service to you unless you have specifically given consent in writing

Sending of information outside the EU

I will not knowingly send your personal information outside the EU unless:

• I am required to in order to comply with the instructions of a Court of Law
• I have to do so in order to defend myself against a legal action or a complaint brought by you.

Your rights

Unless subject to an exemption under the General Data Protection Regulation (GDPR), you have the following rights with respect to your personal data:

• the right to access your personal information
• the right to require me to change any factual mistakes in the information I hold
• the right to withdraw your consent to the non-essential processing of information*
• the right to request the deletion/destruction of your personal information*
• the right to lodge a complaint with the Information Commissioners Office (see below)

* You can withdraw consent to the use of your personal information and/or request its destruction however there are limits to this right laid down in the legislation. For example, you cannot demand the destruction of records of financial transactions.

Concerns and Complaints

If you are concerned about the way that your information is being held please contact me

I am registered with the Information Commissioner’s Office (ICO), registration reference: A8243454

If you are still unhappy you have the right to complain to the Information Commissioner’s Office.

Changes to this policy

If I have to make changes to this policy that are inconsistent with the original purposes for which your data was collected I will notify you in advance wherever possible and give you the opportunity to withdraw consent for your information to be processed.