Why do I need to collect your personal data?
• Know who you are, so that I can communicate with you in a personal way. The legal basis for this is legitimate interest.
• Provide services to you. The legal basis for this is the contract I have with you.
• Process your payment for the services I provide. The legal basis for this is the contract with have with you.
• Provide you with a useful and relevant website, optimising your experience where I can. The legal basis for this is legitimate interest.
What personal information do I collect and when do I collect it?
• Your name.
• Your date of birth.
• Your contact details, including a postal address, telephone number and email address, and a telephone number of someone I can contact in an emergency.
• Your GP contact details.
• The details of any other medical professionals involved with a client, when appropriate.
• Information generated during therapy sessions/email exchanges.
• Information required for invoicing purposes, such as insurance details, if applicable.
• For supervisees - information generated during supervision sessions relevant to the supervisee and their clients.
• For supervisees - professional information, such as qualifications, registration with relevant regulatory bodies, details of other supervisors / tutors, indemnity insurance certificate, DBS checks, professional membership, ICO registration certificate.
I will collect this information from you at the start of therapy or supervision.
On visiting this website, the following information may be automatically collected:
• Technical information, including the Internet Protocol (IP) address used to connect your computer to the internet.
• Information about your visit to the website, e.g. date and time, pages visited. I do not identify you from this information.
Where do I collect information from?
I may obtain personal information from a number of sources, depending on the nature of the service I am providing you with and the work we are completing together, such as:
• From clients.
• From supervisees and supervisors.
• From insurers/solicitors where my fees are being paid through insurance arrangements.
• From a GP or other health care professional, where appropriate.
• From professional regulatory bodies.
• From publicly available material.
How do I use the information that I collect?
• To carry out business activities relating to the provision of my online therapy service (e.g. making appointments, delivering therapy, notifying you of any changes, keeping a record of invoices). In order to liaise with you regarding these, I may use your name and contact details, such as your telephone number, email address or postal address. These details will also be accessible to my supervisor in the event of my death or serious illness/injury, in order that they can inform you of this. Please note - in this instance my supervisor will only have access to your contact details, they will not have access to your therapy/supervision record.
• To allow you to participate in certain features of the website e.g. my email contact form requests your name and email address.
• For payments via PayPal I will use your name and email address.
• For the purposes of regulatory or legal proceedings.
• Where I believe there is a risk of harm, for the purposes of safeguarding against such harm.
Where do I keep the information?
I may take notes during sessions on paper. I make a brief copy of these notes, which is stored with your contact details in a file on a cloud based storage system, as described above. Any paper notes that I keep are kept in a locked filing cabinet and do not contact any personally identifiable information. Similarly, any information about you that is stored on my computer is password protected and does not include any personally identifiable information.
For how long do I keep the information?
• There are safeguarding concerns with respect to any individual.
• There may be professional or ethical matters which I am obliged to report to a training organisation or professional regulatory body.
• There is an ongoing possibility of regulatory or legal proceedings.
• I have a legal obligation to hold the data.
Who do I share the information with?
• A GP or other health care professional in connection with therapy, in addition to any relevant agency when there are safeguarding concerns.
• My supervisor for the purposes of meeting my professional requirements for regular supervision.
• Insurers or other third parties, such as solicitors, for the purposes of arranging payment of my fees.
• Professional service providers, for example accountants, for the purposes of the proper management of my practice. Relevant organisations where there are safeguarding concerns with respect to any individual.
• The relevant professional regulator where it is necessary to report potential breaches of ethical principles or codes of professional conduct.
• Relevant bodies or organisations where I am legally obliged to do so.
How can you access the information I hold about you?
Updated 7th February 2019