Created on 30/12/2022

 

Name: Charlotte Sharpe Counselling and Psychotherapy

Website: https://www.charlottesharpe.co.uk/

E-mail: charlotte.sharpe.therapy@gmail.com

ICO Registration: ZA655767

 

Introduction

The scope of this document is to outline the Privacy Policy of Charlotte Sharpe Counselling & Psychotherapy. I have implemented this policy to ensure the information I collect during your assessment and treatment is kept safe and secure and is only used for the purpose it was given.  Your privacy and the security of your data is very important to me and so I adhere to the current data protection legislation, including the General Data Protection Regulation (GDPR EU/2016/679), the Data Protection Act 2018, and the Privacy and Electronic Communications (EC Directive) Regulations 2003.

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What type of information do I collect about you and how do I get it?

In order to provide a professional and safe service, I collect information about you that includes personal data (e.g. name, email address, etc) and sensitive ‘special category’ data (such as details about your presenting difficulties). This is largely collected directly from you but it may also be provided to me by referring agencies such as your GP.

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I currently collect and process the following personal information:

• Your name, date of birth, address, phone number, and email address

• An emergency contact name and phone number

• Your GP name and contact details

• Names and DOB of any dependent children

• Payment information

 

Sensitive data collected:

• Presenting difficulties and current circumstances

• Relevant medical information (including therapy history and any prescribed medications)

• Relevant relationship history

• Gender and sexuality (if relevant to our work)

• Any illicit substance use

• Completed outcome measures

• Signed therapy agreement

• Session notes

 

Why do I collect information about you?

Under the GDPR I must have a lawful basis for processing your information. Accordingly, it is in my legitimate interests as a Registered Member of the British Association of Counselling and Psychotherapy (BACP) to collect your personal data and sensitive data. It is also required by my professional liability insurer. The type of data collected, and my lawful basis for collecting it, will vary according to each stage of your interaction and/or treatment pathway with me and is outlined below.

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• If you are in contact with me to consider therapy or are currently in therapy with me I will process your personal data where it is necessary for the performance of our contract.

• If you are in therapy with me, my lawful reason for processing the ‘special category’ information that you disclose to me, is that it is necessary for the provision of health treatment (in this case therapeutic assessment and treatment) and a contract with a health professional (in this case, a contract between me and you)

• If you have had therapy with me and our work together has ended, I will use legitimate interest as my lawful basis for holding and using your personal information.

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You do not have to agree to share information with me and can remove our consent at any time. You can do this by contacting charlotte.sharpe.therapy@gmail.com However, in many cases please note that I may not be able to offer you a service if you do not share information with me.

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How will I use the information that I collect?

• To respond to your inquiries and communicate with you about appointments

• To provide you with a therapeutic assessment and treatment

• To liaise with third parties involved in your care e.g. GP, where appropriate, and with your consent

• To create invoices

 

How will I store and erase the information that I collect?

I am committed to taking all reasonable steps to protect any personal, sensitive, and identifiable information that I hold about you. How your data is stored, and the timeframes for retention and deletion at each stage of your engagement/ treatment pathway are outlined below:

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Website & Cookies

Members of the public who make enquiries via the website or email are consenting to their data being shared with me, to arrange therapy.

 

My website is operated via a third party. Therefore, when you visit my website, Wix collects standard internet log information and details of visitor behaviour patterns to help optimise the use of the website. However, this information is processed in a way that does not identify individuals. I use legitimate interests as my lawful basis for holding and using your personal information in this way when you visit my website.

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Like the majority of websites, I use cookies to help my website run effectively and monitor traffic. A cookie is a small amount of data that is sent to your computer or mobile phone browser from a website’s computer and is stored on your device’s hard drive.

However, no user-specific data is collected by Wix or myself. My website has the option to decline the use of cookies. Except for essential cookies, all cookies expire within a reasonable period of time.

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​Email correspondence, contact forms, and text messages

When you contact me via email or a contact form on my website I will collect personal data such as your name, telephone number, email address, postal address, nationality, GP details, emergency contact details, and relevant mental health history to satisfy your enquiry.

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Email correspondence between us is stored in my Gmail account, which uses encryption. I will delete emails on a monthly basis, however, please be aware that email is not an entirely secure mode of communication and you may prefer to communicate sensitive information to me directly in session.

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If you have used a contact form on my website your inputted data will be temporarily stored on the web host Wix before being sent to me.

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If you decide not to proceed with me any data will be deleted after one week.

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Your phone number may be stored in my SMS if we have communicated in this way. I will delete any SMS messages on a monthly basis.

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My smartphone and my computer are password protected.

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Assessment and session notes

If you decide to proceed with ongoing sessions I will keep a written record of your aforementioned personal details to help our sessions run smoothly. These details will be kept securely in a locked filing cabinet and/ or in a password-protected document, separately from your written session notes.

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The sensitive information that I collect during your assessment will also be kept separately from your written session notes and kept securely in a locked filing cabinet and/ or in a password-protected document.

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All notes taken during sessions will be in paper format, anonymised using a code, and kept securely in a locked filing cabinet, separately from any personal data and assessment information.

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After we have finished working together your records will be kept for 6 years from the end of our contract, in accordance with my professional liability insurer, BACP, and HMRC timeframes, before they are securely destroyed. This is so that I have a reference for our work, should you choose to return to therapy or should I be required to provide information in the event of legal action or court instruction? I will delete electronically held data and shred written information. If you want me to delete your data sooner than this, please tell me.  

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 Payment

If you choose to pay me by electronic bank transfer then I may hold a record of this transfer through my bank. This data is secured by the bank’s security systems.

 

How will I process/ share the information that I collect?

​Reports to referrers

If you were referred to me via your GP, with your consent, I may write to them with an assessment and /or discharge summary. Reports will be sent securely via a password-protected document or Royal Mail recorded delivery.

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​Supervision

As is best practice, the content of our sessions will be discussed with my supervisor, who is an experienced counsellor/ psychotherapist/ counselling psychologist/ clinical psychologist, bound by confidentiality and their relevant professional bodies' ethical framework. Your identity is kept anonymous and only your initials are used.

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Therapeutic will

In the event of my death, should you be in therapy with me, my Therapeutic Executor, a BACP (or equivalent) registered individual would access your contact details advise you of this and ensure the ongoing security and deletion of your data as appropriate.

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Risk & Safeguarding

The content of our sessions together is confidential. However, I am legally and professionally obliged to share information with third parties without your prior consent in the following circumstances:

1. If I am sufficiently concerned that you may harm yourself or someone else

2. Where children or vulnerable adults are deemed at significant risk of current harm (physical, sexual, psychological, or, financial abuse)

3. Acts of terrorism

4. Drug or people trafficking

5. Where I am ordered to share information by a court of law

 

Your data protection rights

Under data protection law, you have rights including:

• Your right of access - You have the right to ask me for copies of your personal information.

• Your right to rectification - You have the right to ask me to rectify personal information you think is inaccurate. You also have the right to ask me to complete information you think is incomplete.

• Your right to erasure - You have the right to ask me to erase your personal information in certain circumstances.

• Your right to restriction of processing - You have the right to ask me to restrict the processing of your personal information in certain circumstances.

• Your right to object to processing - You have the the right to object to the processing of your personal information in certain circumstances.

• Your right to data portability - You have the right to ask that I transfer the personal information you gave me to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, I have one month to respond to you.

Please contact me at charlotte.sharpe.therapy@gmail.com if you wish to make a request.

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How to complain

If you have any concerns about how I use of your personal information, you can make a complaint to me at charlotte.sharpe.therapy@gmail.com

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:           

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

 

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk