Logo%20D Blue

Counselling in the Bath area and online.


The short version:
I care about your privacy. I only collect personal data if I have a good reason – and I’m open and honest about what I collect. I store your data as securely as possible, I don’t use it to send you marketing material. I
will not knowingly share any of your personal data with any third parties for any purposes.

The longer version:
The General Data Protection Regulation 2018 (GDPR) provides the legal framework that defines how personal information can be used and my legal duty to protect any information I collect from you.
The regulations state that:

Your personal information is only used for the purpose for which we collected it.
Only information that I actually need is collected.
Your personal information is only seen by those who need it to provide
a service to you the client/s.
I will not pass your personal information on to any other organisation without your consent unless I am required to do so by law.
Personal information is retained only for as long as it is required for the purpose collected. However the British Association of Counselling & Psychotherapy (BACP) and under Contract Law, advice is to keep all information collected for 7 years.
I will, where necessary, keep your information up to date.
Your information will be protected from unauthorised or accidental disclosure.
I will provide you with a copy of your personal information upon request.
Inaccurate or misleading data will be corrected as soon as possible.
These principles apply whether I hold your information on paper or in electronic form.

I collect different types of data for different reasons.

Basic Information:
This includes your name, address, telephone numbers and email address. I use it to make contact with you to arrange or cancel appointments, or send you letters and emails. I like to have alternative contact details for ease of contact, especially in time limited situations. However you could, if you wished, restrict the number of ways I am able access you.

I will not, under any circumstances give your details to any third party without your explicit consent, unless I am required to do so by law. Additionally I will not send you any marketing material.

More Detailed Personal Information:
This includes information like your date of birth, marital status, ethnic origin, employment status and number of dependents. This is useful information that helps to build a picture of who you are and helps me as your counsellor to understand your circumstances. Whilst useful it is not essential and it is your right to refuse to give any or all of this information.

Initial Appointment Notes:
During your initial appointment [and in other sessions] you may be tactfully and professionally asked about your life. This may include details of childhood, major events in your life, losses and traumas. This information can be sensitive or emotive, but it is essential for counselling to take place. What you tell me, assists in our work together.

This information may sometimes be recorded in my notes. It is securely stored electronically. It is only ever shared anonymously within my counsellor supervision.

Ongoing Session Notes
I make brief notes at the end of each session. These help me to clarify my thoughts, and to remember significant points from each session. Any other event that may change the nature of the counselling work is also recorded. These notes are anonymised and are kept electronically and securely.

Other Information:
This is information like the dates and times of your sessions and any missed sessions. This is recorded in your client log and is kept securely.

Processing of Data:
I do not process your data, and if I wished to I would seek your permission.

How Long Do I Keep Your Personal Information:
The Information Commissioner’s Office’s (ICO) guidance is that I should keep your personal information for no longer than I need to. In line with professional norms your notes will be kept securely for seven years from the date of your final session, after which they will be securely destroyed.

How Secure is my Data from Accidental or Unauthorised Disclosure:
No system can be 100% secure, especially from a determined attack. However, I will take all reasonable precautions to protect your data. This is not only from a cyber-attack, but also from flood, fire, physical theft and accidental deletion.

Electronic data is fully encrypted and stored professionally using two factor authentication.
All client records are automatically anonymised to prevent any confidentiality breaches.
Electronic data is automatically backed up, onto secure UK based servers.

How Do I Access my Personal Data:
You can, at any point request to have a copy of any or all of the data we have about you. This can include:

Your client information and contact details.
Copies of letters or emails. This includes letters sent to you, letters sent by you, letters sent on your behalf to third parties and letters received from third parties.
A list of sessions attended.
A copy of my session notes.

You can request your data verbally or in writing. I will email to confirm.

You can request to have your data received in various ways: Electronically as a password protected PDF or another format, in person, or by recorded delivery.

You can request for your data to be sent to a third party. For example; another therapist, your G.P or your solicitor. However I may wish to contact them directly to ensure that they will handle your personal information securely.

I will not make a charge for this request and I will complete the request within 30 days.

What is the Lawful Basis for Holding Data:
Most of the information I collect from you is needed to provide a service to you. Because of this the lawful basis is ‘Legitimate Interest’ rather than ‘Meaningful Consent’.

‘Legitimate interests: the processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.’

I sincerely hope that I have provided you with a clear understanding of my Privacy Policy. If however you wish to explore any part of the policy in more detail, please do not hesitate to contact me, I will be happy to help. My email is: allen@allendaniels.co.uk

Allen Daniels 2024